ML20205A424
| ML20205A424 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/04/1986 |
| From: | Briggs L, Eselgroth P, Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20205A379 | List: |
| References | |
| 50-410-86-33, NUDOCS 8608110365 | |
| Download: ML20205A424 (7) | |
See also: IR 05000410/1986033
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-410/86-33
Docket No. 50-410
License No. CPPR-112
Category B
Licensee: Niagara Mohawk Power Corporation
300 Erie Boulevard, West
Syracuse, New York 13202
Facility Name: Nine Mile Point Nuclear Station, Unit 2
Inspection At: Scriba, New York
Inspection Conducted: June 30 -July 11, 1986
Inspectors:
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L. BMgs, Lead Reactor Engineer
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M. Myans, Reactor Engineer
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Approved by:
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P. Eselgroth/Ghief, Test Programs
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Section,01(DRS
Inspection Summary:
Inspection on June 30 -July 11, 1986 (Report No.
50-410/86-33)
Areas Inspected:
Routine, unannounced inspection by two region based inspec-
tors of licensee action on previous inspection findings, preoperational and
preliminary test results evaluation review, post maintenance test witnessing,
QA/QC interface with the preoperational test program, independent verification
and plant tours and meetings.
Results: One deviation was identified.
(Paragraph 3.3)
NOTE:
For acronyms not defined, refer to NUREG-0544, " Handbook of Acronyms
and Initialisms".
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DETAILS
1.0 Persons Contacted
Niagara Mohawk Power Corporation
- R. Abbott, Station Superintendent
- G. Afflerbach, Startup Manager
- S. Agarwal, Special Projects
B. Bulger, Project Advisory Engineer (SWEC)
- G. Doyle, Nuclear Quality Assurance (NQA) Operations, Supervising Quality
Engineer
- P. Eddy, Site Representaitve NY State PSC
- J. Gallagher, Site Licensing Engineer
- W. Hansen, Manager, NQA
- A. Kovac, Supervisor, Audits
- T. Lee, Special Projects
- J. McKenzie, Supervisor, Quality Surveillance
- D. Quamme, Project Director
- M. Ray, Manager, Special Projects
L. Ringlespaugh, Test Coordinator
L. Schiavone, Test Engineer
- I. Weakley, Special Projects
Other NRC Personnel
- W. Cook, Senior Resident Inspector, Operations
- R. Gramm, Senior Resident Inspector, Construction
- Denotes those present at the interim exit meeting on July 3,1986.
- Denotes those present at the final exit meeting on July 11, 1986.
2.0 Follow-up of Previous Inspection Findings
(0 pen) Unresolved Item (410/86-27-01) - Licensee to include list of de-
ficiencies, the status of the deficiencies, and the supporting closure
documentation in all preoperational test packages. The inspector reviewed
five recently approved preoperational test result packages during this
inspection (See paragraph 3.0).
For three test packages reviewed, the
inspector noted minor documentation errors in the MATRIX of deficiency
reports (DRs) and problem reports (prs) included in the test summary of
each package.
In two of the packages reviewed, the inspector noted that
several DR's and PR's were not annotated as Joint Test Group (JTG) open
action items on the licensee's Master Tracking System (MTS).
This anno-
tation is necessary to ensure that DR's and PR's receive JTG approval
prior to closure. The inspector discussed these findings with a licensee
representative and stressed the importance for adequate tracking of de-
ficiencies.
The licensee representative stated that more effort would
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be given to deficiency tracking.
This item will remain open pending
additional review of approved preoperational test results during a sub-
sequent routine NRC inspection.
3.0 Preoperational and Preliminary Test Results Evaluation Review
3.1 Scope
The completed test procedures listed below were reviewed during this
inspection to verify that adequate testing had been conducted to
satisfy regulatory guidance, licensee commitments and FSAR require-
ments and to verify that uniform criteria were being applied for
evaluation of completed test results in order to assure technical and
administrative adequacy.
N2-P0T-29-1, Reactor Recirculation System, Revision 3, Station
Operations Review Committee (SORC) approved on June 12, 1986,
N2-P0T-29-2, Reactor Recirculation Flow Control System, Revision 2,
SORC Approved on May 30, 1986,
N2-POT-71, Uninterruptable Power Supplies - 2VBA*UPS2A/28, Revision
1, SORC approved on May 2, 1986,
N2-POT-100A-1, Division 1 Diesel Generator, Revision 2, SORC approved
on June 25, 1986,
N2-P0T-100A-2, Division II Diesel Generator, Revision 2, SORC ap-
proved on June 23, 1986,
MD.0100.A03, Standby Diesel Generator Reliability Test, Revision 0,
Test Group Manager (TGM) approved on January 14, 1986,
MD.0100.A04, Standby Diesel Generator Air Start Capacity Test, Re-
,
vision 0, TGM approved on March 21, 1986.
The inspector reviewed the test results and verified the licensee's
evaluation of test results by review of test changes, test except-
ions, test deficiencies, test summary "As-Run" copy of the test
procedure, acceptance criteria, performance verification, recording
conduct of test, QC inspection records, restoration of system to
normal after test, independent verification of critical steps or
parameters, identification of personnnel conducting and evaluating
test data, and verification that the test results have been approved.
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3.2 Discussion
N2-POT-29-1
During the review of N2-POT-29-1 the inspector reviewed several Test
Summary entries that involved non intent procedure changes. Test sum-
mary entries involve minor non-intent changes and clarify information
concerning the preoperational test procedure.
The inspector noted
that the changes appeared more appropriately to fit the SAP-106C de-
finition of test exceptions; which are, changes to a procedure that
do not change intent or scope of acceptance criteria. Test exceptions
also require approval by a level III test engineer. Minor changes
can be made by test summary entries which do not require further
management review until the licensee results approval review.
This matter was discusse'; with one of the licensee's test group man-
agers (TGM). The TGM e>plained Sow, when and why a test exception
would be generated. He also infoimed the inspector how the manage-
ment of the startup and test departicent understands and interprets
the SAP-106C definition of what a test exception is and when it must
be used. The TGM explained that the first paragraph of Attachmerit
12.1 of SAP-106C requires a test exception to be used to change a
proced;re when unpredictable or uncontrollable events, system status
changes or field conditions that were not or could not have been in-
cluded in the procedure during its development occur. The test sum-
mary entries noted by the inspector, as explained by the TGM, were
not uncontrollable and would have been foreseen if a different set of
system prints (NSSS supplier vice architect engineer) from those used
to develop the test procedure, had been used.
The inspector agreed
that using the licensee's logic, a similar conclusion would be reached.
The inspector did note that when failures (unforeseen) occurred they
were noted as test exceptions.
The inspector agreed that the licensee was in literal compliance with
SAP-106C and that a clearly auditable trail of events was available
using the test summary.
3.2 Division I and II Standby Diesel Generators
During the review of the preoperational and preliminary test results
for the Division I and II Standby Diesel Generators, the inspector
noted that the results of preliminary test MD.0100.A03, Standby Diesel
Generator Reliability Test, had not been reviewed by the licensee's
Joint Test Group (JTG) although the preoperational test results had
already been jig reviewed and approved. This preliminary test veri-
I
fled diesel ger.erator reliability by means of 69 consecutive valid
starts (35 starts for each diesel generator) as required in Regula-
tory Guide (R.G.) 1.108, " Periodic Testing of Diesel Generator Units
Used as Onsite Electric Power Systems at Nuclear Power Plants",
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Revision 1, August 1977, paragraph C.2.a(9). The inspector held se-
veral discussions with the licensee concerning this item. The licen-
see stated that the reliability test is not listed as an acceptance
criterion in NMP-Unit 2 Final Safety Analysis Report (FSAR), Chapter
14, Table 14-2-125, Standby Diesel Generator. The licensee therefore
concluded that the preliminary test does not constitute preoperational
test acceptance criteria and does not require JTG results approval.
However, NMP-2 FSAR Section 1.8, Table 1.8-1 and Section 14.2.7 com-
mit to compliance with RG 1.108 which requires the 69 consecutive
starts (35 per diesel) during the preop program to demonstrate relia-
bility. NMP-2 FSAR Chapter 14 paragraph 14.2.4.1 states that test
results obtained during preliminary testing may be used in place of
retesting during preoperational testing provided the preliminary test
and its results are approved by the JTG.
It should also be noted
that FSAR Chapter 14 paragraph 14.2.12.1 qualifies the table 14 in-
formation as test abstracts with a summary of the acceptance criteria.
3.3 Findi'gl
Failure to JTG review the results of preliminary test MD.0100.A03,
" Standby Diesel Generator Reliability Test" is a deviation (410/
86-33-01) from a licensee commitment made in FSAR Chapter 14, Para-
graph 14.2.4.1.
In addition to the above, several open test deficiencies require
resolution by the licensee.
Deficiency Reports (DRs) 13569, 15353
and 13928 concerning N2-P0T-100A-1 and DR's 15106 and 15122 con-
cerning N2-POT-100A-2 will be carried as an unresolved item (410/
86-33-02) pending licensee resolution and subsequent NRC review.
4.0 Post Maintenance Test Witnessing
4.1 Discussion
The inspector witnessed a portion of the Emergency Diesel Generator
(EDG) No. 3 post maintenance testing being conducted per Interim Oper-
ations Surveillance Procedure N2-0SP-EGS-M001, " Diesel Generator Oper-
ability Test Division 1/2", Revision 1 and Interim Operating Procedure,
N2-IOP-100A, " Standby Diesel Generators", Revision 0. Maintenance was
recently performed on the EDG (No. 1 and 3) air start valve seals as
discussed in NRC IR 50-410/86-31. The testing was conducted to verify
system operability after maintenance.
4.2 Findings
No violations were identified.
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5.0 QA/QC Interface with the Preoperational Test Program
The inspector reviewed several recent Nuclear Quality Assurance Surveil-
lance Reports (QASR) regarding different activities of the licensee's
startup department. The following QASR's were reviewed:
--
QASR 86-10442 and 10472, Test Results Review of N2-P0T-100A-1,
" Division 1 Diesel Generator" (review completed June 20, 1986) and
N2-POT-78, " Remote Shutdown System" (review completed June 4, 1986).
The QA inspectors used QA checklist SQA-S-145-86, Revision 1, to
check various attributes of the completed procedure. All QA comments
and open items were adequately resolved.
QASR 86-10522, review of preventive maintenance for crane 2MHR-CRN
--
4, completed on June 17, 1986. The QA inspector found the preventive
maintenance performed to be in compliance with QA checklist
PO-MM-86-001, Revision 0.
- --
QASR 86-10546, surveillance of the performance of preoperational test
N2-POT-61-1, Primary Containment Purge System, conducted on June 25,
1986.
The QA inspector noted that no Field Revision Forms or Test
Exceptions were written during testing.
Several deficiencies were
encountered and documented on deficiency reports (DRs) 20502, 20961,
20962, 20970 and 21022. All attributes of QA checklist SQA-S-090-85,
Revision 1 were adequately satisfied.
5.1 Findings
No violations were identified within the scope of this review.
6.0 Independent Verification
The inspector independently compared the status of DR's and PR's as noted
in preoperational test result packages to the status listed on the lic-
ensee's Master Tracking System as discussed in paragraph 2.0.
7.0 Plant Tours and Meetings
7.1 Plant Tours
The inspector toured various areas of the facility to observe work
in progress, housekeeping, cleanliness controls and status of con-
struction and testing activities.
During one of the tours the inspector noted that a small cable (No.
2SVVNGX037) had been disconnected from the acoustic monitor for
safety / relief valve 2SVV*NBE229. The inspector also noted what
appeared to be three electrical wall penetrations (2WX113N03,
2WC113N02 and 2WK113N01) that did not appear to have a fire seal of
adequate depth. The items were discussed with the licensee.
The
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problem with the disconnected cable had been identified by the lic-
ensee on Deficiency Report (DR) 19968 on May 30,1986.
For the three
penetrations the licensee provided information (Dwg NMP-F-01-03) that
showed the minimum depth of fire barrier' or air barrier foam to be
twelve (12) inches.
The penetrations in question were 42 inches
deep and although foam sealant was not full depth it did contain at
least a 12 inch depth of foam. The licensee also provided the com-
pleted installation and inspection record forms for the penetrations
in question.
7.2 Meetings
The inspector randomly attended the licensee's morning Startup Plan
of the Day meeting during which the current status of preoperational
testing activities and any holds or delays are discussed. Other
items such as surveillance and outage activities are also discussed.
7.3 Findings
No unacceptable conditions were observed.
8.0 Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable, an item of noncompliance
or a deviation. The unresolved item identified during this inspection is
discussed in Paragraph 3.3 of this report.
9.0 Exit Interview
A management meeting was held at the conclusion of the inspection on
July 11, 1986 to discuss the inspection scope, findings and observations
as detailed in this report. An interim exit meeting was also held on
July 3,1986 to discuss preliminary inspection findings (see Paragraph I
for attendees at both meetings). No written information was provided to
the licensee at any time during this inspection.
The licensee did not
indicate that any proprietary information was contained within the scope
of this inspection.