ML20215F380
| ML20215F380 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/03/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20215F381 | List: |
| References | |
| CAL-86-12, NLR-N86142, NUDOCS 8610160181 | |
| Download: ML20215F380 (13) | |
Text
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a Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Pubhc Service Electric and Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609 339-4800 Vice President -
Nuclear October 3, 1986 N LR-N8 614 2 Dr. Thomas E. Murley, Regional Administrator Region I United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
LOSS OF OFFSITE POWER TESTS CONFIRMATORY ACTION LETTER 86-12 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION Your Confirmatory Action Letter (CAL No. 86-12) dated September 24, 1986 requests an analysis be provided to Region I prior to restart of Hope Creek Generating Station which addresses the observations from the September 11 and 19, 1986 Loss of Offsite Power (LOP) tests.
The following information responds to this request as delineated in item number four (4) of the CAL.
A complete assessment of each observation recorded during the two LOP tests is contained in Attachment 1.
Each observation was evaluated for root cause, applicability of preoperational and subsequent testing, corrective actions, retest requirements, and reportability.
Attachment II is a tabulation of actions that were taken prior to conducting the second cold LOP test, and actions that will be executed prior to plant restart, or subsequent to restart.
Attachment III contains the actions PSE&G committed to take at the September 19, 1986 meeting onsite with NRC personnel.
These actions address the Bailev 862 Solid State Logic Modules.
8610160181 861003 hDR ADCCK 05000354 f-TN PDR Y
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M To Dr. Thomas E. Murley 2
10/3/86 Item 4(a) of the CAL requests "a discussion of why the preoperational test program and subsequent testing did not identify the deficiencies that resulted during the LOP testing".
There are a variety of reasons why these recent test observations were not identified during the preop phase:
1.
Some observations were due to equipment malfunction which occurred subsequent to the preop program or surveillance test.
2.
Some observations made during the recent LOP testing were not related to preop or surveillance testing (e.g.,
Hot LOP #6 RCIC Pressure Control Procedure Request).
3.
Some observations raised were not a deficiency but were an inquiry or concern of the individual observer.
4.
The issue was not identified during the preop loss of power test because the preop test ( BB-3) did not de-energize the non-vital buses (surveillance testing is done in a similar manner).
The preoperational testing program was conducted in a thorough, saf e, and quality-conscious manne r.
It complied with all regulatory requirements and withstood the scrutiny of numerous audits and inspections by various organizations.
The BB-3 procedure was conducted in conformance with the FSAR.
It was reviewed and approved by the cognizant organizations on site, reviewed by NRC personnel, and was consistent with corresponding tests performed at other plants in Region I.
It is therefore concluded, after a thorough review of the current issues, that the preoperational test program met its intended func tior, and was not deficient in failing to identify current LOP items.
Item 4(b) of the CAL requests " consideration of contributing f actors such as design control, quality assurance, and training".
The LOP observations on design control focus on a failure to implement FSAR commitments into the design documentation.
Three parameters required to be powered from an uninterruptible cource per Table 7.5-1 of the FSAR were not
To Dr. Thomas E. Murley 3
10/3/86 reflected in the design.
This oversight occurred in the coordination between Bechtel control system and electrical disciplines for non-lE power assignments.
A complete review of power assignments per Table 7.5-1 has been conducted to ensure design conformance.
No other required parameters were found to have an erroneous power supply assignment.
PSE&G believes the oversight to be an isolated occurrence and not indicative of a broader breakdown of design control in the coordination of power assignments between the Bechtel control system and electrical disciplines.
Quality Assurance has performed a review of the LOP results, including the observations in Attachment I.
The review concluded that a number of observations are non-discrepancies or non-0 and therefore, not subject to quality assurance controls.
A review of the remaining items has ascertained that no breakdowns in the quality assurance / control program contributed to the discrepancies noted in the observations.
Due to minor data base differences that exist between the plant and the training otpartment, the observers of the LOP tests made some it. correct observations.
These observations were negative checks in nature and in no case did these observations lead to a licensed operator taking incorrect action.
PSE&G is taking action to correct these data base differences as detailed in Attachment II.
Item 4(c) of the CAL requests an assessment of "the broader implications of your findings on other plant systems".
Some of the observations involve discrepancies in Bailey SoliG-State Logic Modules (SSLM) which are used on other plant systemse Based upon the sample of SSLMs checked for configuration, we believe the observations relating to configuration control of Bailey subcomponents are isolated cccurrences and that the nature of the observaticns and the low number involved provide reasonable assurance that required safety functions will perform properly when called upon to do so.
The active testing performed to date, including the second Cold LOP which exercised 55 devices associated with Bailey logic as well as the devices normally exercised during an LOP, confirms that there is reasonable assurance that the Bailey SSLMs will perform as designed when required.
Bailey system reliability has been addressed in earlier meetings with Region I and NRR.
PSE&G has committed to a reliability testing and analyses program which will provide data with which to evaluate the statistical reliability of the system.
We are on schedule with our commitments in this regard.
l
Dr. Thomna E. Murley 4
10/3/86 Attachment III details additional. actions with respect to Bailey SSLMs in addition t o the reliability program detailed in PSE&G letters dated June 13 and 24, 1986 (C. McNeill, PSE&G to E.
Adensam, NRC).
The NRC HCGS Safety Evaluation Report Supplement
-6 concluded that there is reasonable assurance that the SSLMs at Hope Creek will perform the required safety functions during the first cycle of operation.
In order to ensure the reliability of the Bailey modules is maintained at a high level, PSE&G will commit to take action to have in place within one year, a bench tester capable of testing input / output logic functions in the module's dedicated circuit configuration.
It should be noted that none of the Bailey logic failures nor configuration issues discovered during the LOP tests has qualified as a reportable event.
Item 4(d) of the CAL requests " corrective actions which you plan to take including any additional preoperational testing".
The second cold LOP conducted on October 2, 1986 was structured to include the following additional actions:
Selected functional checks of the Safety Auxiliary Cooling System, functional checks of the Service Water Pumps, selected logic functional checks of the Drywell Cooling Fans, CRD Pump Operation functional,' valve manipulation sheet for Containment Instrument Gas, functional test of RACS, functional test of FRVS System, functional test of RWCU System, functional test of SBLC System, functional test of Emergency Instrument Air Compressor, functional test of Containment Atmospheric Control System.
The second Cold LOP test was performed successfully, and the aforementioned additional test actions were executed satisfactorily which confirmed the operability of the associated Bailey Logic Modules.
Additional corrective actions which have been taken, or are planned to be taken, are detailed in Attachment II.
L PSE&G believes Hope Creek Generating Station is ready to resume power operation and continue with the power ascension test program including a second Hot LOP at 20% power.
PSE&G l
respectfully requests your authorization to restart.
C. A. McNeill l
o.
t Dr. Thomas E. Murley 5
10/3/86.
C_ Mr. D.LH. Wagner USNRC Licensing Project Manager.
~Mr..R.
W.
Borchardt
' USNRC Senior Resident Inspector Mr.
E. Wenzinger USNRC AIT Manager
ATTACHMENT II l
The following commitments were made during the course of the NRC AIT audit to resolve the observations identified during i
the Loss of Power (LOP) test (known as the Hot LOP) and the
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subsequent cold, non-critical LOP test (known as the Cold LOP), as well as related concerns raised during the NRC review.
These commitments have been separated into items I
which require completion:
(a) prior to the second, cold, non-critical LOP test, (b) prior to the plant restart, and (c) at some time in the future at a date yet to be determined.
These commitments were identified to and discussed with the NRC AIT members during the course of the audit.
PSEEG's HCGS Quality Assurance Department is assuring plant management that these commitments are met and/or adhered to such that PSE&G can state that they are closed.
A.
Commitments required prior to conducting the second LOP test.
1.
As indicated in Hot LOP Observation #3, the LOP test procedure will be revised to check control room alarms before the second cold LOP test.
2.
As indicated in Hot LOP Observation #6, a change to the RCIC system operating procedure (OP-SO.BD-001(0))
is required and must include (i) instruction for use when changing the RCIC flow path from injecting into the CST to injecting into the RPV, and (ii) instruction for use when changing the RCIC flow path f rom injecting into the RPV to injecting into the CST.
3.
As indicated in Hot LOP Observation #7, a change to the LOP abnormal procedure (OP-AB.ZZ-135(O) ) is required to clearly state that both RACS pumps will auto start during a LOP without a LOCA.
Operations personnel will be trained accordingly.
4.
As indicated in Hot LOP Observation #9, circuit breaker 52-50201 will be instrumented during the second Cold LOP for evaluation.
5.
As indicated in Hot LOP Observation #12, Bailey cabinet LAC 6 53 will be instrumented (f or input f rom multiplexer cabinet 1BC676) and an observer will be stationed at the circulating water pumphouse during the second Cold LOP.
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6.
As indicated in Hot LOP Observation #12, more frequent control room panel lamp testing will be performed.
7.
As indicated in Hot LOP Observation #14, a training memorandum to all licensed operators describing the response of the FRVS during a LOP event is required and procedure OP-AB.ZZ-135(O) will be revised accordingly.
8.
As indicated in Hot LOP Observation #18, more frequent main control room FULL CORE DISPLAY lamp testing will be performed.
9.
As indicated in Hot LOP Observation #20, all open DCR's/DCP's which have not been implemented will be reviewed for their licensing bacis.
10.
As indicated in Hot LOP Observation #21, PSE&G and Bechtel Power Corporation are reviewing other systems listed in the FSAR as requiring an UPS to verify compliance with Reg Guide 1.97 commitments.
11.
As indicated in Cold LOP Observation ll, Instrumentation & Control procedure IC-GP. ZZ-031(O) will be revised to improve pin inspection.
12..:-As indicated in Cold LOP Observation #2, work performed against Startup Change Request SCR-J-256 will be reviewed and staple jumper configurations will be' checked against current prints.
13.
As indicated in Cold LOP Observation #4, the instrument air dryers will be aligned to their normal lineup so that only one tower will purge, air service supply valve SV-7595 will be repaired so that service air demand is isolated during a LOP test, and the time required to manually establish RACS water supply to emergency air compressor will be decreased.
Finally, operations procedures will be modified to include opening of valve HV-2598 and 2599 manually from the control room af ter the LOP test.
14.
As indicated in Cold LOP Observation #8, the outside air isolation damper (HD-9588AA) will be observed during the second Cold LOP.
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15.
As indicated in Cold LOP Observation #9, the yard 4
dump valve's pressure transmitters will be calibrated j
and their operation properly verified.
A strip chart recorder will be put on the transmitters, to determine the feasibility of adding a time delay to prevent nuisance actuations, during the second Cold i
LOP.
16.
As indicated in Cold LOP Observation ill, level indicator LI-R605-B21 and temperature recorder TR-R605-Ell will be provided with a non-lE UPS power supply.
17.
As indicated in Cold LOP Observation #13, troubleshooting will reverify logic in cabinet LAC 653 for correct operation and if everything proves acceptable, a loss of power to bus.10A110 will be performed.
Also, operating procedures will be reviewed to assure " Trip Acknowledge" action is adequately described and operators properly trained.
18.
As indicated in Cold LOP Observation #14, troubleshooting will reverify logic in cabinet IDC653 for correct operation and if everything proves acceptable, a loss of power to bus 10A101 will be performed.
Cabinet 1DC653 will be instrumented during the second Cold LOP tect.
19.
As indicated in Cold LOP Observation #16, the control room operators will be instructed that there will be no indication on the RACS pump amperage meters during a LOP.
j 20.
Additionally, RACS sequence logic will be verified in the second Cold LOP.
21.
Additionally, the loss of instrument air abnormal (OP-AB.ZZ-131(O)), and normal operating (OP-SO.KB-001(Q)) procedures and the diesel normal 1
operating procedure (OP-SO.KJ-001) will be revised, accordingly.
22.
Additionally, all equipment malfunctions still unresolved or indeterminate will be instrumented at their control centers to identify their malfunction (see Hot LOP Observations #9, 10, 12, and Cold LOP Observation #8).
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1 23.
Additionally, pursuant to Hot LOP Observation #10, the original (faulty) module will be reinstalled and a simulated LOP on that circuit performed to verify that this module did not cause the "B" SACS pump f ailure to start.
24.
Additionally,-an evaluation of the CREF Autostart on LOP will be performed.
25.
Additionally, Engineering will provide a complete evaluation of RACS logic.
B.
Commitments Required Prior to Restart 1.
As indicated in Hot LOP Observation #19, a design change is required to place the SRM/IRM drives on an uninterruptible power source.
2.
As indicated in Cold LOP Observation #5, the manual override shall.be repositioned and the valve verified as operating properly.
All similar valves will be identified to ensure the overrides are fully disengaged.
3.
As indicated in Cold LOP Observation #17, contact chatter of the digital points will be investigated.
i 4.
Additionally, operating procedures OP-OL.ZZ-014 through OP-OL.ZZ-020 will be revised to document a lamp test every shif t of panels 10C650,10C651, and i
10C80.
5.
Additionally, all prefabricated Bailey connectors will be verified to be fingertight.
6.
Additionally, all Q and non-O Rosemount pressure transmitters will be inspected to assure the gap between the housing and end covers is less than or equal to 0.035 inches.
7.
Additionally, unused ports on Rosemount pressure transmitters will be inspected to ensure proper plugging.
l 8.
Additionally, non-lE power supplies to those systems which only function during a LOCA are being reviewed to ensure no adverse impact during an LOP /LOCA.
9.
Additionally, the Resident Inspector will be notified of the test results per DCP-4-EMJ-86-091.
10.
Additionally, the engraving on marker plates in RPS power distribution panels C71-P001 and C71-P002 will be changed to give appropriate channel number.
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C.
Commitments required Post Restart.(i.e., at a date yet to be determined) 1.
As indicated in Hot LOP Observation #4, the ease of access to the diesel fire pumphouse door will be assured by the installation of a dummy lock cylinder.
2.
As indicated in Hot LOP Observation 48, diesel generator exhaust gases will be prevented f rom entering the~ diesel generator building through a modification to the exhaust hoods on the roof.
3.
As indicated in Hot LOP Observation ill, nuisance alarms will be reviewed for potential reduction.
4.
As indicated in Hot LOP Observation #12, reliability of the NAMCO EA-700 limit switch will be further investigated.
5.
As indicated in Hot LOP Observation #14, the applicable training lesson plans for the FRVS f ans will be updated and the simulator configuration reviewed.
6.
As indicated in Cold LOP Observation #5, the operator valve training course will be upgraded to instruct in the identification of the subject of "out of position" indication.
7.
As indicated in Hot LOP Observation #16, a design change is being considered to direct the governor control circuit into droop mode only when manually selected.
8.
As indicated in Cold LOP Observation #4, the following actions are required:
1 a.
Remove closure signal to valves HV-2598 and HV-2599 upon LOP to keep the valves open.
b.
Close valves HV-2582 A1. HV-2582 A2, HV-2577 and HV-7712 upon receipt of a LOP signal.
c.
Stop air dryer purge when all compressors are stopped.
d, Permit auto pergirg when emergency compressor is operating.
9.
As indicated in Cold LOP Observation #6, a design change will be initiated to obtain consistency between SACS loops to improve human factors.
10.
An. indicated in Cold LOP Obsorvation #10, the corvice water system design will be revised to ensure consistency between loops to improve human f actors.
11.
As indicated in Cold LOP Observation #16, a design change request will supply non-lE reliable power to the amperage meters as a plant betterment item.
12.
As indicated in Cold LOP Observation #17, a change to the RPS optical isolator output contacts to CRIDS will be made to show a tripped condition on a LOP.
13.
Additionally, Bailey will perform a f ailure mode analysis on modules examined and found to have failed input / output buffers.
14.
Additionally, the reliability analysis program for Bailey 862 Logic Modules will be revised to address backplain pin spreading over time and will include a determination of a worst case number of installation and removal cycles.
15.
Additionally, the organization of the 10CFR50.59 Safety Evaluation process will be investigated.
16.
Additionally, procedure SA-AP.22-020(O) will be revised as necessary to address possible EQ considerations.
17.
Additionally, DCR's/DCP's will be reviewed for applicability to 10CFR21.
The DCP procedure will be revised to include identification of station procedures affected by design changes and target date for procedure revisions required as a result of the design change.
18.
Additionally, a design change will be generated to implement vendor recommended changes for the turbine building chilled water system.
19.
Additionally, lesson plans addressing LOP observations related to FRVS start, RSCS control room display, SRM/IRM drive motors and the RACS pump amp meter will be reviewed and updated, as will the simulator plant difference list prior to 11/17/86.
Changes will be included in next operator requal cycle commencing 11/17/86.
The simulator test program will be revised to identify any lack of documentation f rom the vendor and assumptions made by the vendor without PSE&G awareness.
The test program will also evaluate all control room components down to actual vendor " wiring".
The testing will be completed within the time allowances of ANS-3.5-1986.
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20.
Additionally, information will;be providsd to Mr. P.
K. Eapen (NRC AIT member) on the acoustic monitor by 10/17/86.
21.
Additionally, PSE&G will commit to take action to have in place within one year, a bench tester capable-of testing input / output logic functions in the modules dedicated circuit configuration.
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ATTACHMENT III The four following commitments were made by PSE&G during the course of. the September 19, 1986 meeting with the NRC to resolve concerns regarding the LOP test observations related to Bailey 862 Modules.
1.
In order to further explore any Bailey 862 SSLM f ailure mode, PSE&G will direct Bailey to perform 'a failure analysis on any f ailed SSLMs and recommend actions for improvement, where appropriate.
PSE&G will include a summary of these failure analyses, recommendations and corrective actions, when necessary, in the final Bailey reliability report to be submitted prior to the end of the first refueling outage.
2.
PSE&G will investigate the possibility of testing all input / output logic functions through a computer program on an I&C bench prior to reuse of Bailey SSLMs.
The results of this investigation will be included in the final Bailey reliability report.
3.
PSE&G will retest and verify all s'afety-related functions of a Bailey SSLM by procedure, whenever a logic change is made to the module.
In addition, Quality Assurance will review and verify all reprogrammed SSLMs during the FPLA reverification program.
4.
PSE&G will require the Station Operations Review Committee (SORC) to review any Bailey 862 SSLM failures on a monthly basis through the first refueling outage.
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