ML20234E883

Safety Insp Rept 50-412/87-56 on 870731-0807.No Violations Noted.Major Areas Inspected:Control Room activities,post- Trip Reviews & Licensee Response to Abnormal Events & Operational Control of Maint/Surveillance Activities

ML20234E883
Person / Time
Site:	Beaver Valley
Issue date:	09/04/1987
From:	Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20234E851	List: ML20234E849 ML20234E883
References
50-412-87-56, NUDOCS 8709220553
Download: ML20234E883 (19)

See also: IR 05000412/1987056

Text

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V. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report No. 50-412/87-56 ,

Docket No. 50-412

License No. NPF-64

Licensee: Duquesne Light Company

Post Office Box 4

Shippingport, Pennsylvania 15077

Facility Name: Beaver Valley Unit 2

Inspection At: Shippingport, Pennsylvania

Inspection Conducted: July 31 - August 7, 1987

Inspectors:

L. Tripp, Section Chief, PB3, Region I (Team Leader)

J. Beall, Senior Resident Inspector, BVPS-2

P. Wen, Startup Specialist, Region I

F. Young, Senior Resident Inspector, BVPS-1

S. Pindale, Resident Inspector, BVPS-1

L. Prividy, Resident Inspector, BVPS-2

A. Asars, Resident Inspector, Haddam Neck

P. Tam, Project Manager, NRR (Part Time)

Approved by:  !

LV. Trfph, Section Chief, RPS 3A, Region I

I/h[

Diate'

Inspection Summary: Inspection on July 31 - August 7,1987 (Report No.

50-412/87-56).

Areas Inspected: This special safety inspection (404 hours0.00468 days <br />0.112 hours <br />6.679894e-4 weeks <br />1.53722e-4 months <br />) reviewed on shift

activities through 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC inspector coverage of preparation for startup,

initial criticality and low power physics testing activities in preparation for

operation at full power. Specific items reviewed included control room

activities, post-trip reviews and licensee's response to abnormal events,

operational control of maintenance / surveillance activities, independent

verification of key valves in the plant, testing and surveillance, licensee's

compliance with technical specifications, QA/QC involvement and upper

management's day-to-day involvement in plant activities.

Results: The licensee's startup of the plant including activities to allow

achie,ement of higher operational modes, initial criticality and low power

operations were found to be systematic and well controlled. The necessary

management structure, controls and procedures to support further power

8709220553 870916

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escalation were in place and functioning well. Twenty-four hour coverage by '

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resident and startup specialists during these evolutions identified no signi-

ficant regulatory concerns. All prerequisites and technical specification

requirements for entering higher modes were properly completed. Inspectors

noted that all personnel assigned functions related to initial criticality

testing performed their duties in a well-controlled, professional manner.

Personnel had been properly trained and briefed and were familiar with the

procedures for testing performed during this time. Approved procedures were

used and properly implemented throughout the approach to criticality. One

event occurred during this inspection period that was considered operationally

significant by the inspection team. This event was manual trip of the reactor

on August 7, due to dropped control rods. This operational event was reviewed

in Section 2.3.1 of this report. Programmatic controls for maintenance and

surveillance testing activities for Unit 2 are the same as those for Unit 1 as

implemented through the Station Administrative and Operating Manual chapters.

This in place system was found to be well understood and well implemented by

all station personnel. The licensee has instituted a program to reduce the

number of annunciated control room alarms. Some problems were noted in

operational personnel making the transition to an operational plant, that is,

the inspectors noted that some operator; still had not fully discarded the

construction oriented view of the plant.

In general, continued strong licensee performance during this phase was evident

as was similarly observed during the preoperational testing program.

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TABLE OF CONTENTS {

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1.0 Introduction l

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1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . 3 l

1.2 Major Milestones During Startup & Low Power Operation. . . . .. 3

1.3 Summary of NRC Inspection Activities . . . . . . . . . . . . . . 4

2.0 Plant Operations

2.1 Control Room Activities .... ................ 4

2.2 Control Boarcs and Annunciators. ................ 7

2.3 Post-Trip Review & Incident Response . .... ......... 7

2.3.1 Manual Reactor Trip Due to Dropped Control Rods ... 8

2.3.2 Inoffice Review of Licensee Event Reports (LERs) . . . 9

2.4 Operations Control of Maintenance & Surveillance Activities. . . 10

2.5 Independent Verification . . . . ..... .... . . . . . . 11

2.6 Compliance with Technical Specifications . ........ . . 11 i

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3.0 Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4.0 Low Power Physics Testing (LPPT)

4.1 Program Summary. . . . . . . . . . . . . . . . . . . . . . . . . 13

4.2 Test Observation . . . . . . . . . . . . . . . . . . . . . . . . 13

4.3 Test Results Reviewed. . . . . . . . . . . . . . . . . . . . . . 14

4.3.1 Initial Criticality. ..... .......... . . 14

4.3.2 Reactivity Computer Checkout . . . . . . . . . . . . . 14

4.3.3 Critical Boron Concentration ... ...... . . . 14 1

4.3.4 Isothermal Temperature Coefficient (ITC) . . . . . . . 15 {

4.3.5 Control Rod Worth Measurement. ..... . . . . . . . 16

4.3.6 Zero Power Flux Mao. . . . . . . . . . . . . . . . . . 16

4.4 Summary of LPPT Program . . . . . . . . . . . . . . . . . . . . 16

5.0 QA/QC Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6.0 Management Involvement ........ . . . . . . . . . . . . . . . 18  ;

7.0 Exit Interview. . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

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DETAILS

1.0 Introduction

1.1 Background

On the issuance of Facility Operating License NPF-64 dated May 28,

1987, Duquesne Light Company was authorized to perform low power

testing and tests requiring power operations at/or up to, but not to

exceed, 5% of the reactor core power. Authorization to operate

beyond 5% power was still under consideration by the NRC. As a

result of the July 8,1987 Commission meeting to consider a full

power license for Beaver Valley, Unit 2, the Commission requested the

staff provide a written summary of the licensee low power operating

experience at Unit 2 before commencing actions authorizing the staff

to issue a full power operating license. To form the basis for the

written summary required by the Commission, a team inspection of

activities at Unit 2 was performed starting approximately two days

before riticality running through power operations up to 5% power. l

This inspection consisted of round-the-clock coverage of the

licensee's final preparations for entering Mode 2, initiai

criticality, pcter operations testing and completion of prerequisites

for entering Mode 1 (more than 5% power). Special emphasis was

placed on the areas of management involvement and their attention to 1

daily plant operations, plant operations staff knowledge and their i

ability to handle off-normal events, and activities that were i

required to support the unit during this time such as surveillance,

maintenance a:.d testing. The purpose of this inspection report is to {

document the findings of the team inspection during this period.

1.2 Major Milestones During Startup and Low Power Operation

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During the period of July 31 - August 7,1987, the significant Beaver

Valley Unit 2 Startup milestones included:

(1) completing pre-requisites for entering Mode 2;

(2) taking the reactor critical; and

(3) low power physics testing.

A chronological summary of plant preparations during this period and

significant milestones prior to this time are listed below:

Date Time Operational Highlight or

Milestone

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5/28/87 5:00 pm Received a low power

license.

6/1/87 3:30 am Completed fuel loading.

6/6/87 6:05 am Entered Mode 5.

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7/8/87 10:00 am Commission briefing concerning

full power license.

7/15/87 9:50 am Plant entered Mode 4.

7/17/87 5:00 am Plant entered Mode 3.

7/21/87 12:10 am Pressurizer safety valves

were noted to be weeping

slightly.

7/31/87 4:00 pm Team inspection commenced 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

shift coverage.

8/3/87 10:07 pm- Begin deboration for criticality.

8/,4/87 6:25 am Reactor declared critical (Mode

2).

8/4/87 10:30 am Increase power to a point of

adding sensible heat, initiated

reactor physics testing.

8/6/87 9:50 am Completed zero power physics

testing.

8/7/87 9:35 am Initiated manual reactor trip

due to dropped rods in Group 2 l

Bank D. i

1.3 Summary of NRC Inspection Activities

This inspection included completion of pre requisites for entering

Mode 2, initial criticality and zero power physics testing. The team

remained sensitive to adverse impact on shift supervisor safety

duties due to NRC shift inspectors questions and discussions on

matters of a programmatic nature. Accordingly, shift inspectors

referred implementation matters or status questions to the nuclear

shift supervisors and other on-shift operations personnel, and

referred programmatic questions to off-shift licensee personnel.

Non-shift team inspectors interfaced primarily with licensee support

groups and performed followup inspection for on-shift NRC inspector

concerns. The team's observations and findings regarding initial

plant startup, criticality and low power operation testing and the

licensee's response to operational events are discussed in the report

sections that follow.

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2.0 Plant Operations

2.1 Control Room Activities

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The inspectors extensively reviewed control room activities during

the inspection period. Particular attention was given to shift

turnovers and briefings, operator conduct, licensed and non-licensed

operator performance and knowledge of plant conditions, logs and

night orders, materials available to operators, and ongoing plant

evolutions, surveillance, and startup testing. The inspectors noted

the following:

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Shift turnovers and briefings were thorough and descriptive,

allowing the shift change to be smooth with minimal disruption

of on going testing and plant evolutions. In particular, the

shift change during the final approach to criticality was i

observed by the inspectors to be exceptionally informative. '

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Both licensed and non-licensed operators had a good under- l

standing of plant system status and evolutions.

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The inspectors observed ongoing Operational Surveillance Tests

(OSTs) and other plant evolutions. Control room operators were-

familiar with the procedures and steps necessary to execute

them; this included operation of various computers such as those

associated with the radiation monitors and safety parameter

display system as well as the plant computer.

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Control room documentation was reviewed for adequacy of descrip-

tions and details of events. Control room staff logs were

accurate and contained sufficient detail of plant operations to

clearly represent plant activities. Generally, the shift super-

visor logs contained detailed descriptions of events and ongoing

investigations, such as the troubleshooting and maintenance

efforts on the Gaseous Waste System diaphragms and leakage.

Operational Surveillance Tests (OSTs) which identified equipment

requiring maintenance work adequately described the deficiency i

encountered during test performance and the corrective actions I

taken. Night orders were used as reminders and notification of

unusual station circumstances. The current orders were reviewed  ;

and found to be informative and relevant to special plant I

conditions.

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Control room system status boards and prints were updated by the

operations personnel posting equipment clearances. Generally,

these boards / prints were current. During one shift turnover, an

operator identified that the status print incorrectly

represented the position of a pressurizer PORV block valve. The

board was corrected immediately and it was re-emphasized to the

personnel posting clearances that the boards must be updated

promptly and accurately.

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Generally, the matet !als provided to the control room operators .

were adequate. The inspectors noted that the operators' i

materials are arranged differently than the IJnit 1 materials.

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For example, the Operating Manual Chapters have been separated  !

so that the Annunciator Response Procedures (ARPs) and the OSTs  !

are in individual binders rather than together in a rack as' they

are at Unit 1. The information is stored in two small book

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cases facing the_ control boards rather than on top of the status

board cabinet as at Unit 1. The operators explained that this

arrangement was used at the simulator and they felt it allowed

i' quicker and easier access to the ARPs,. Emergency Response

! Procedures, and other information.

l - The inspector reviewed the contents of selected binders and

l' found that several ARPs were missing. The licensee stated that

the missing ARPs would be provided in the future and that these

,. were.less important annunciators. Further reviews of materials

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revealed that the tank curves were not marked as controlled

copies and curves were not available for the Accumulators, Steam

Generator Blowdown Tank, the' Primary Component Cooling Water

Surge. Tank and several building sumps.in safety-related

buildings such as the containment and the auxiliary building.

The licensee has elected not to provide sump curves but will

provide' curves for the other tanks mentioned. The inspector

also noted that the laminated copies of curves, such as rod

insertion' limits and other safety system parameters, used by

operators on the main control board were not marked as

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controlled. The inspector determined that the curves in use are

! the current revision and the licensee has agreed to mark the

copies as controlled. The resident inspectors will verify the

proper implementation of the tank curves and control of the

l various parameter curves.

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The licensee conducted a practice Emergency Preparedness and

Planning drill on August 5, while startup testing continued.

The inspectors noted that the drill was conducted without

adverse effects on the plant. Drill players in the control room

kept the drill activities quiet and separate from the control

room activities and did not cause any undue distractions.

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Inspectors also accompanied several auxiliary operators on

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assigned building tours throughout the plant. It was noted

through identification of inconsistencies on these tours that

personnel had not completed the transition from the construction

site to an operating plant. Operators were found to be diligent

l- and knowledgeable of their assigned duties but they still

l possessed a construction-oriented view of the plant. The

l operators wera very experienced having worked at Unit 1, but

i their Unit 2 experience had been as a construction site. For a

plant under construction, ladders, unrestrained pr,.surized gas

bottles, unsecured equipment carts, open junction boxes, and

various other symptoms of work in progress are normal and

acceptabla. The question of equipment operability with

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consideration given to unsecured material and open wiring was

discussed with operators.and plant management; they were

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-actions including counseling all operators and conducting area

walkdowns as well as correcting the specific deficiencies

identified by the inspectors.

2,2 Control Boards and Annunciators

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The inspectors reviewed the control boards and annunciators to assess

L-- system availability. Operators were questioned to determine their  ;

knowledge of system status, abnormal plant conditions, and  ;

annunciator. meaning.

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Operators were found to be generally aware of the reasons for each

lit annunciator and responded appropriately to alarmed conditions.  !

Many annunciators appear misleading in that they alarm for a variety l

of conditions and the operator must refer to the computer status '

screens (CRTs) located adjacent to the annunciator panels to deter- l

utne which plant condition is abnormal. Operators rely heavily on  !

the CRTs for. important-plant status information. This could lead to

difficulties should the CRTs be inoperable, which occasionally ,

occurred- during control room observations. Operator performance and

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dependence on the.CRTs, which are powered from a non-1E source, will

continue to be assessed as part of routine resident inspection

followup.

The inspectors noted that there were a large number of nuisance

alarms. Many were due to narrow alarm setpoint ranges or would

normally be M t during operation such as for high or low tank levels.

In the~beginning of August, 1987, the licensee initiated a program to

identify, evaluate and resolve all continuously annunciated control  ;

room alarms. The alarms are logged on each shift, and the program is j

currently in the data collection phase. Data collection is expected ,

to be completed by approximately October 31, 1987. Both Operations d

and Engineering personnel will be involved in the evaluation and l

resolution phases. The licensee has been requested to provide Region

I an update concerning the progress and effectiveness of this

program.

The inspector also noted that many vertical board chart recorders

contained paper with incorrect scales.. All of these were adequately I

marked to indicate the correct scale. fhe licensee has placed orders j

for paper with correct scales and will install it when it becomes

available.

2.3 Post-Trip Reviews and Incident Response

The inipector reviewed the licensee's program to evaluate and docu-

ment operational events, including post-trip reviews. Operational i

events requiring NRC notification (per 10 CFR 50.73) are described in  !

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Section 2.3.2. The licensee implements Station Administrative

Proceoure (SAP) No. 13, Preparation of Draft Incident Reports (DIRs),

Critiques and Unit Off Normal Reports (UONRs). SAP 13 provides

programmatic guidance to resolve and document station abnormal

occurrences and is common for both Units 1 and 2. The DIR is the

draft report of an abnorc.a1 occurrence or other reportable event as

described in plant Technical Specifications or 10 CFR. UONRs docu-

mant abnormal conditions / events which do not meet the criteria for

submitting an incident report, yet are of such a nature that they may

be used for data collection and evaluation purposes. DIRs are filed

for such events as reactor trips and engineered safety feature

actuations. Post-trip reviews are documented and included as part of

the DIR. The DIR addressing the operational event during the inspec-

tion is discussed in Section 2.3.1. During the inspection, one DIR

and three UONRs were necessitated due to operational events and were

completed by the licensee. The reports were reviewed by the inspec-

tor, and found to be acceptable with one exception as described

below.

On August 6,1987, as a result of improper operator switching, a 4 KV

bus was locked out or overcurrent. The loss of the 4 KV bus caused

an auto-bus transfer (AST) of an associated 480 volt bus. During the

trar,sient, a number of radiation monitor power failures occurred.

The radiation monitors are supplied power from the 480 volt bus. One

of the radiation monitors that was affected initiated a realignment

of the supplementary leak collection and release (SLCR) system such

that the normally unfiltered ventilation flow was redirected and sent

through the main filter banks to the elevated release path on top of

the containment building. Operators responded in accordance with

plant procedures, and the off-normal conditions were restored within

40 minutes of the initiating event. Inspector review of design basis

documentation found that the SLCR system is an engineered safety

feature. During review of the associated UONR (No. 2-87-20), the

inspector determined that the August 6 ESF actuation was not reported  ;

as required per 10 CFR 50.72. This discrepancy was brought to

licensee management attention. Through discussions with the plant

manager, it was subsequently determined that this event should have

been reported. Therefore, the licensee made the required ENS report

to the NRC on August 12, 1987, and the associated licensee event

report will b submitted by the licensee.

2.3.1 Manual Reactor Trip Due to Dropped Control Rods

On August 7, 1987, with the plant in Mode 2 and at approxi- .

mately 2% power, a manual reactor trip was initiated when l

four control rods fell into the reactor core. At 9:30

a.m., the r9 actor operator attempted to manually position  ;

Bank D control rods from 39 steps when all four control  ;

rods in Group 2 of the bank dropped into the core. At 9:35 l

a.m., a manual reactor trip was initiated in accordance I

with plant procedures to realign the control rods. The NRC

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was notified.'of the reactor trip via ENS per 10 CFR 50.72

reporting requirements. This event was. documented by the

licensee in DIR No. 2-87-21.

Based upon similar past experience at Unit I and at other

. Westinghouse PWR plants, the licensee-suspected that the-

circuit card-associated with the firing circuit for the

. moveable gripper coils for the affected rods was the likely

source of the problem. Since they did not have equipment

on site to. test the card, they elected to replace it. This

corrective action initially appeared to have resolved the

problem in that the licensee was able to move the affected

control rods. At the end of this inspection period, August

7, 1987, the reactor remained in Mode 3 (Hot Standby).

Although not covered by this. inspection report, the reactor

was taken critical at 4:38 a.m,, on August 10 to resume

initial.startup testing, At 4:43 a.m. on August 10, the

same four control rods fell into the core and another ',

manual reactor trip resulted. -The problem was subsequently

resolved and is. detailed _in NRC Inspection report

50-412/87-54. The trip' recovery and post-trip review for

.the August 7 incident were found to be. acceptable.

Adequate management attention and licensee investigation

was evident.

2.3.2 Inoffice Review of Licensee Event Reports (LERs)

The inspector reviewed LERs submitted to the NRC to verify

that the details of the event were clearly reported,

including the accuracy of the description 'of the cause and  ;

the adequacy of the corrective action. The inspector '

determined whether further information was required from i

the licensee, whether generic implications were indicated )

and whether the event warranted onsite followup. The

following LERs were reviewed: l

LER 87-01: Reactor Trip Due to Loss of Vital Bus No. 1

LER 87-02: Inadvertent Preoperational Safety Injection !

Actuation

LER 87-03: Reactor Trip Due to Simulated Loss of Steam

Generator Level Signal

LER 87-04: Operation and Violation of Technical

Specifications

LER 87-04-01: Revision to LER 87-04.

. No significant deficiencies were identified. These LERs  !

were also reviewed as discussed in Inspection Report

50-412/87-54.

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2.4 Operations Control of Maintenance and Surveillance Activities

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Programmatic controls for maintenance and surveillance testing

activities for Unit 2 are the same as those for Unit 1, as imple-

mented through the. Station's Administrative and Operating Manual

ChapterProcedures(SAP,OM). The Nuclear Shift Supervisor (NSS) is

responsible,to ensure that shift operations are conducted in i

accordance with plant procedures, Technical Specifications, SAPS., and j

Nuclear Group directives. The NSS is also required to be i

continuously aware of the unit status of systems, equipment and

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intended operations which may affect the reactor or result in the 1

release of radioactivity. The Nuclear Shift Operating Foreman

directs the operating forces in accordance with testing, maintenance

and operational requirements. He also assures that equipment

clearances are properly executed.

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Day-to-day work activities were observed by the inspector and i

determined to have received adequate preplanning and supervisory

oversight. Daily planning meetings provide coordination for control

of the scheduled activities and for the necessary support from the

various station groups. The daily work activities were performed in i

accordance with station requirements with respect to taking systems

or components out of service and restoration processes. Throughout j

the inspection ,plant operators demonstrated a thorough knowledge of '

plant conditions, including off-normal configurations in effect as a l

result of maintenance or surveillance testing. The operators were

also found to be knowledgeable of the reason why specific plant

equipment was out of service.

In the area of control of the contral room station status prints, the

need for closer attention was apparent. Station status prints are

plastic covered, controlled valve operating drawings provided for

operator use on plant systems. They are to reflect correct tystem

status conditions at all times per OM Chapter 48.3.D, Administrative

Control of Valves and Equipment. During a tour of the main steam

valve area, the inspector found that manual isolation valve No.  ;

2SVS-23 (for the "A" steam generator atmospheric dump valve) was open I

as required per the normal system arrangement for the system.

However, the associated station status print in the control room i

showed that the valve was shut. This discrepancy was brought to the

licensee's attention, who immediately recognized that the system .

status print was incorrect for 2SVS-23. Operations shift personnel '

knew that the valve was open per NSA requirements. The licensee

subsequently determined that the operator who signed off the

equipment clearance, which required restoration of 2SVS-23 following

maintenance, failed to update the system status board. A second

example of the inadequate control of status prints was noted during

an inspector welkdown of selected auxiliary feedwater system valves.

The inspector found that the casing vent valve for the "B" motor

driven auxiliary feedwater pump was shut per NSA requirements.

However, the system status print showed the valve to be opened. The

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licensee stated that this case also represented the failure of an

operator to adequately control / update the associated system status

print.

For the above cases of inadequate control of the system status

prints, the onshift plant operators were aware of actual valve

positions. However, these two examples were cause for concern in

that inaccurate information could be translated from the system

status prints. In response to the above events, the licensee

stressed the importance of maintaining accurate system status prints

to onshift personnel. No further discrepancies were noted.

In summary, for the area of control over maintenan;e and surveillance

testing activities, the licensee demonstrated that the programmatic

controls were generally being implemented properly. NRC concerns in

this area were immediately resolved by the licensee. No additional

discrepancies were identified in this area.

2.5 Independent Verification

As part of the validation of Unit 2 readiness for full power license,

the inspection team independently verified the position of key safety

related ECCS and AFW valves with the aid of a non licensed operator.

In addition, the in place procedures to address valve positioning and

independent verification were reviewed. Sampling of these selected

valves found that all valves were in the correct position as required

by plant conditions. Discussions with plant operators indicated that

operations personnel were knowledgeable of the in place system to j

assure proper alignment of these valves and the system used to inde-  !

pendently varify positions of the valves.

2.6 Compliance with Technical Specifications j

Technical Specifications were used extensively by plant operators

concerning operability requirements for specific plant systems.

Through onshift observations and discussions with plant operators,  ;

the inspectors concluded that the operators demonstrated an adequate ]

working level knowledge of plant technical specifications. The  !

licensee developed and maintained checklists to ensure that all

required prerequisites were met prior to mode changes. The inspector

reviewed the checklists for conformance to t'-hnical specifications

and for completeness. No deficiencies wers. [entified. During

onshift observations, the inspectors routinely selected plant control

room components / systems to verify that limiting conditions for opera-

tion (LCO) compliance were met. No LCO requirements were found to

have been exceeded or unrecognized by plant operations personnel. No

concerns were identified in this area.

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3.0 Maintenance

L Scheduling, controlling and performance of maintenance activities were

reviewed to determine the effect this area had on overall operations of

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the unit. A sampling of work in progress and interviews with key

maintenance personnel were performed as the basis for the assessment in l

this area.

Specific inspection points covered by the inspector and adaitional

observations are as follows:

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The maintenance personnel are basically well experienced from

previous Unit 1 activities.

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The primary mechanism to authorize maintenance activities is the

Maintenance Work Request (MWR) which is common to both Unit 1 and 2.

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Many of the implementing procedures for maintenance work (corrective

and preventive) and maintenance surveillance procedures (MSPs) are

similar for both units.

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The inspector reviewed MWRs 877871 and 877884 which had been issued

on 7/21/87 and 7/26/87, respectively, to determine set pressure for

the "A" and "B" pressurizer safety valves. The maintenance personnel

responsible for this task were knowledgeable, organized and aware of

the overall maintenance requirements. The inspector noted that QC

inspection reports were completed covering this work. The inspector

was advised that a similar process will occur in the upcoming mainte-

nance outage when the "B" and "C" safety valves will be changed to

correct a safety valve leakage problem.

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The inspector met with an operations coordinator concerning the

disposition of damaged aluminum conduit containing heat trace cable

for the sodium hydroxide chemical addition tank (CAT). The conduit

is located outside, at ground level near the CAT. The operations

coordinator demonstrated that operations had properly assessed this i

problem and assigned proper priority in dispositioning it, although l

the damaged conduit was not resolved at the end of the inspection. I

The problem had been identified initially on June 24, 1987, and '

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Nonconformance and Disposition Report 52133 had been issued to

resolve it. Engineerbg had issued a resolution and operations was

coordinating a fix such that the conduit would be replaced and a l

nearby sample line which was the root cause of the problem would be

relocated well in advance of the onset of cold weather. Based on

discussions with maintenance and QC personnel, attendance at daily

plan-of-the-day meetings led by outage management personnel, and I

review of several maintenance work requests (MWR) and associated j

inspect. ion reports, the inspector concluded that the maintenance i

activity is being properly planned, autnorized, controlled and QC j

inspected, Also, the inspector noted that operations had a syste- J

matic approach to assign correct priorities to a maintenance task so

that both schedule and safety considerations were properly addressed.

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l In summary, the inspector concluded that the maintenance activity is being q

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4.0 Low Power Physics Testing (LPPT)

4.1 Program Summary

The licensee's approach to criticality and low power physics testing

were performed in accordance with approved station procedures. These

procedures were reviewed previously by NRC Regional specialists and

found acceptable (see NRC Inspection Report 50-412/87-27). The scope

of this review was to. witness and monitor the iicensee's implementa-

tion of the applicable procedure. Specific emphasis was placed in

the following areas:

--

Low power physics tests conduct with respect to compliance with

approved test procedures;

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Briefings with the test crew and operations personnel prior to

performing each test;

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Test pre-requisites and initial conditions;

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Operation actions; and

--

Summary analyses.

The licensee conducted the initial approach to criticality test in

accordance with test procedure IST 2.02.02, " Initial Approach to

Criticality," Issue 2, Revision 0. The reactor trip breakers were

closed on 7:13 pm, August 3, 1987; the licensee then commenced

control rod bank withdrawal. When the Control Bank D (CBD) reached

the position of 160 steps, RCS boron dilution was initiated. Initial

criticality was achieved on 6:25 am, August 4, 1987. The RCS boron

concentration at criticality was 1351.5 ppm, with CoM..ol Bank D

(CBD) position at 157 steps; the measured boron concentration was

within the predicted range (1340 +/- 50 ppm).

After the unit reached criticality, the licensee conducted the low

power physics testing in accordance with test procedure IST 2.02.03,

" Low Power Physics Test," Issue 1, Revision 0. NRC inspection

findings of the initial approach to criticality and LPPT evolution

are documented in the following paragraphs.

4.2 Test Observation

At various times during the inspection period, the inspectors .

witnessed portions of the LPPT in progress. The tests witnessed {

included. .

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' . initial criticality;

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reactivity computer checkout;. .

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critical boron concentration measurement; -!

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isothermal; temperature coefficient measurement;

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. control rod worth measurement; and, d

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flux mapping. .

Test witnessSg, included observations of the attributes listed in i

Section 3.2 cr Inspection Report.50-412/86-20. No unacceptable

conditions'were identified.

4.3 Test Results Review

Hot zero_ power physics test results were reviewed and compared with

' Technical Specifications and with acceptance criteria detailed in.the

test procedures. The details and findings ~of the review are

described below: i

4.3.1 Initial Criticality

Initial criticality of Unit 2.was achieved on August 4,

1987, with~ reactor coolant system. boron concentration of

1351.5 ppm and CBD position at 157 steps. This boron

concentration when corrected'to the hot zero power, all rod

out (ARO) configuration, was 1363 ppm. The. predicted value ')

based on the same ARO configuration was 1350 ppm. The

measured deviation from prediction was, therefore,

1363_-1350 = 13 ppm. This result was within'the test

acceptance criteria of +/- 50 ppm.

4.3.2 Reactivity Computer Checkout

The inspector independently verified tnat the reactivity

computer was adjusted with the correct inputs of delayed

neutron fraction and decay constants and noted that the

results of the " cold" calibration checks were satisfactory.

The reactivity computer was further checked using NI-44

input when the reactor reached criticality. Comparisons of

predicted and measured reactivities, based on doubling time

measurements, were all within test acceptance criteria of

4%.

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4.3.3 Critical Boron Concentration

The inspector reviewed test data and noted the following

results. i

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Predicted Value Measured Value

Configuration (ppm) (ppm)

ARO 1350 +/- 50 1367-

CBD Inserted -

1230

Difference between the

critical boron concentration

with ARO and with CBD

inserted 131 +/- 13 137

Test results met acceptance criteria.

4.3.4 Isothermal Temperature Coefficient (ITC)

The inspector reviewed test data and noted the following

ITC results.

Predicted Value Measured Value

Configuration (pcm/F) (pcm/F)

ARD -0.11 +/- 3.0 -0.03

CBD Inserted -2.91 +/- 3.0 -2.83

The corresponding moderator temperature coefficients (MTC) ,

were determined to be as follows: '

Measured Value TS Limit

Configuration (pcm/F) (pcm/F)

ARO +1.75 <0 -j

CBD Inserted -1.05 <0

The measured MTC at ARO condition was a positive value

which exceeded the TS limit. The licensee took correct

actions, including establishing administrative restrictions

on rod withdrawal and boron concentration limits. The

inspector reviewed the related calculations and verified j

that the administrative restrictions were calculated in .

accordance with BVT Procedure 2.1-2.49.3, " Operating Limits

to Ensare a h'egative Moderate Temperatur> Coefficient."

The calculations were technically adequate. Through

control room tours, the inspector noted that these

administrative restrictions were being implemented by

operations personnel.

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4.3.5 Control Rod Worth Measurement

The inspector reviewed test data and noted the following

test results:

Predicted Worth Measured Worth

Rod Bank Test Method (pcm) (pcm)

CBD Dilution 1342 +/- 134 1413.5 i

!

CBC Rod Swap 914 +/- 137 947.7

CBB Rod Swap 1233 +/- 185 1328.2

CBA Rod Swap 564 +/- 100 567.4

SBB Rod Swap 1020 +/- 153 1048.0  ;

SBA Rod Swap 1088 +/- 163 1099.7

TOTAL 6161 +/- 616 6404.5

The measured rod worth test results met acceptance

criteria.

The measured boron difference between the ARO and CBD

inserted configuration is 137 ppm (Section 4.3.3).

The metsured differential boron worth therefore is:

1413.5 pcm or 10.32 pcm

137 ppm ppm

This result is within the acceptance criteria of 10.24 pcm

plus or minus 10%. ppm

4.3.6 Zero Power Flux Map

The inspector reviewed the zero power flux map and noted

that the predicted power distribution generally agreed with

the predicted values. The measured quadrant power tilt of

1.0051 was within the test acceptance of <1.02.

No unacceptable items were identified.

4.4 Sunimary of LPPT Program

Low Power Physics Test was accomplished in accordance with approved

procedures, data were acceptable, and test objectives were met.

Licensee performance during coproath to criticality and subsequent

LPPT was deliberate, and carefully controlled. TS surveillance

requirements associated with the special test exceptions during LPPT

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were correctly addressed in the test procedure IST-2.02.03, " Low

Power Physics Test," and were adequately performed. Problems

identified during the test, such as positive MTC value at the hot

zero power all-rods-out condition, were disseminated to the appro-

priate groups and corrective actions were implemented.

Overall, the licensee's startup test program continues to be

effective and acceptable.

i

5.0 QA/QC Involvement

The inspector had discussions with licensee personnel in the QA surveil- 1

lance, QC, testing and operations group to determine the level of QA/QC l

involvement concerning the surveillance of operational activities and to

evaluate the activities of the QA Surveillance Group. Also, the inspector l

reviewed QA documentation which describes the QA surveillance group organ- l

ization, qualification and responsibilities, including instructions on I

what type of correspondence is generated from the group. l

Based on these discussions and reviews, the inspector had the following

comments and observations.

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While the licensee is firmly committed to a QA surveillance effort of

operations / testing activities through the startup test program, it

appears that there is upper management support for this type of

effort into commercial operation. This observation is supported by

the fact that the QA surveillance group has been conducting surveil-

lance of periodic tests at Unit 1 for the past month. ,

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QA surveillance group personnel have adequately covered a

comprehensive sampling of operations / testing activities at Unit 2.

Generally, witness points have been clearly marked in the official

copy of the test procedure to alert the responsible test engineer

that QA desires to witness that particular portion of the test. The

inspector found what was determined to be an isolated case where

witness points desired by QA were inadvertently omitted from the

official copy of the test procedure. However, QA surveillance

personnel did witness much of this test procedure so the inadvertent

omission of the QA witness point markings was not significant.

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While QA surveillance findings were properly documented in deficiency

reports and adequately addressed and resolved by the responsible

group, the inspector found that the findings were generally

administrative comments dealing with procedure accuracy and

compliance. The future course and focus of the QA surveillance group

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efforts appears to be limited to administrative issues and does not

include technical issues that could be potential problems at Unit 2

such as feedwater regulating valve problems, balance of plant

problems that could challenge safety systems, ventilation system

problems, etc. Unless licensee management provides the proper  ;

direction to attain a focus on such technical issues, use of the QA

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surveillance group or other QA effort as a management tool to

identify potential problems could be considered severely limited.

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The current staff of the QA surveillance group consists of 5

permanent Duquesne Light Company employees and 4 consultants. Plans ;

are currently underway to increase the peruanent staff to 7. ~

However, outside training opportunities to broaden the group's

perspective on current industry issues are somewhat limited due to

budget restraints.

In summary, the inspector concluded that the QA surveillance group is

adequately covering and witnessing the various testing at Unit 2. Also,

the insF.etor concluded that QA personnel have primarily focused on

administrative aspects, however, the licensee should consider devoting

more attention to technical issues in its future QA surveillance efforts.

This would enable management to identify potentially serious technical or

safety problems.

6.0 Management Involvement

To assess licensee's management effectiveness in managing and controlling

plant operations, a review was conducted in the following areas:

--

Observation of management involvement in day-to-day activities.

--

Evaluation of adequacy of control room planning and daily activities

(including daily meetings).

--

The review of mechanisms used for flow of information between

different departments into management.

--

Observation and evaluation activities of onsite committees, offsite

review committee and independent safety evaluation group.

--

Observation and evaluation of control of activities such as

housekeeping, fire protection, radiation protection and security.

The inspection team found that the licensee's management and various

oversight groups such as the Onsite Safety Committee (OSC) and Joint Test

Group (JTG) maintained a detailed involvement in site activities. Good

management control and planning of daily activities were implemented by

the use of two daily meetings (8:00 am and 4:00 pm). These meetings were

viewed as an excellent mechanism for dissemination of information to all

groups involved in the startup program. Specific responsibilities for

each task were identified and well checked. Management's attention in all

areas such as housekeeping, radiation protection and security were

considered to be adequate during the startup program. Basic startup

activities were slow and methodical which positively attributed to the

almost error free startup program. There was an excellent balance of

management involvement without undue pressure to naintain schedules and

milestones,

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7.0 Exit Interview

The inspectors discussed the inspection scope and findings with the

licensee management at an exit interview conducted on August 7, 1987. The

following personnel attended the exit meeting:

A. B. Bennett, System Engineer, DLC

J. O. Crockett, Senior Manager, Nuclear Operations, DLC

J. P. Godleski, TCT Engineer, DLC

K. E. Halliday, SOE, Stone and Webster Engineering Corp.

J. D. Johns, Supervisor, QA Surveillance, DLC

E. L. Martin, Compliance Engineer, DLC ,

T. F. McGourty, Principal Engineer, DLC l

T. P. Noonan, Assistant Plant Manager, DLC

M. J. O'Neill, Engineering Manager, DLC .

D. G. Szucs, Lead Compliance Engineer, DLC l

G. R. Wargo, Assistant Director, QC

R. C. Wittschen, Licensing Engineer, Stone and Webster Engineering Corp.

T. G. Zyra, Director, T&PP, DLC

As discussed at the meeting, the inspection results are summarized in the

cover page of this inspection report. The licensee's representative

indicated that the subjects discussed contained no proprietors l

information. l

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