IR 05000354/1985030

Insp Rept 50-354/85-30 on 850624-28.No Violation Noted.Major Areas Inspected:Preoperational Test Program Implementation, Procedure Review & Verification,Qa/Qc Overview & Plant Tours

ML20134E624
Person / Time
Site:	Hope Creek
Issue date:	08/02/1985
From:	Briggs L, Dev M, Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134E601	List: IR 05000354/1985030 ML20134E599
References
50-354-85-30, NUDOCS 8508200349
Download: ML20134E624 (11)

Text

0 -.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-30 Docket N License No. CPPR-120 Priority --

Category B Licensee: Public Service Electric and Gas Company 80 Park Plaza - 71C Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancock's Bridge, New Jersey Inspection Conducted: June 24 - 28, 1985 Inspectors: [ ,EA Briggs, tgaf Rea tor Engineer Mf'Bf>

da'te ev, Re o En~gine r 82- Erf

. ' d' ate Approved y: / ~

8'z/86 P.' Ese1 grot Chief /datt Test Progr s Section, DRS Inspection Summary: Inspection on June 24 - 28, 1985 (Report No. 50-354/85-30)

Area's Inspected: Routine, unannounced inspection (70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />) by two region-based inspectors of preoperational test program implementation, QA/QC overview, preoperational test procedure review and verification and plant tour Results: No violations were identifie esoB200A g 85001305000354 PDR PDR G

to

_ - _ . . - - _ _ _ . _ _ - _-. _._ -

.

.

DETAILS 1.0 Persons Contacted

• A. Barnabei, Principal Quality Assurance (QA) Engineer R. Bravo, Principal Startup Engineer, Construction Completion

• J. Carter, Startup Manager J. Cox, Principal Startup Engineer, Methods / Administration

• E. Dalton, Supervising Engineer

• R. Donges, QA Engineer C. Fresh, Lead Control, Methods / Administration Document Control

• A. Giardino, Manager QA, Engineering and Construction

• R. Griffith, Principal QA Engineer

• C. Jaffee, Startup Engineer R. Johnson, Site Engineer ,

T. Johnson, Mechanical Resident Engineer (Bechtel)

• C. Lambert, Supervising Engineer

• E. Logan, Site Manager, Construction

• M. Metcalf, Principal QA Startup Engineer Other NRC Personnel

• R. Blough, Senior Resident Inspector

• J. Lyash, Resident Inspector

• Denotes those present at the exit meeting conducted on June 28, 198 The inspector also contacted other personnel of the licensee's operating and QA/QC staf .0 Preoperational Test Program Implementation Test Organization and Personnel Training 2. Requirements / References (

'

--

Hope Creek Generating Station (HCGS) FSAR Chapters 14 and

--

Quality Assurance Instruction (QAI)-2-11, Hope Creek Quality Assurance Program for Phase I and II Startup, Rev. Startup Administrative Procedure (SAP)-2, Organization and responsibilities, Rev. 3.

.

--

SAP-3, Bechtel/Public Service Startup Interface Activities,

! Rev. !

l

--

SAP-6, Startup Quality Assurance Program, Rev. O

!

,

!

_~ -_,. . _ . _ . _ , -, ,,...,___--._-.__,_._,_..-.,-......_r,..._ . _ _ . . , _ _ -

, , . . . _ _ .__

.

.

--

SAP-15, Personnel Certification, Rev. ANSI N45.2.6-1973, Qualification of Inspection, Examination and Testing Personnel for the Construction of Nuclear Power Plant Regulatory Guide 1.8, Personnel Selection and Trainin .1.2 Program Review The inspector reviewed the licensee's Test and Startup Organiza-tion relative to the programs listed in paragraph 2.1.1 to verify that:

--

The personnel performing test and startup quality control activities meet the specified qualification requirements;

--

The responsibilities of key test personnel are defined;

--

The method and responsibility for appointing test personnel is comprehensive and understood by management;

--

The lines of authority and responsibility are defined;

--

The organizational interfaces for organizations involved in the test program are adequate; and,

--

The training records and the Test and Startup personnel interviewed reflect adequacy of their training, QA/QC indoctrination, and understanding of administrative controls for testin .1.3 Program Implementation The licensee Startup Administrative Procedure No. 2 identifies the Public Service Startup Group (PSSUP) organization and de-fines its responsibilities. The organization is at a fully staffed status, as delineated in the Project Startup Division Organization - Support chart, dated June 13, 1985. The PSSUG is comprised of a Startup Manager (Public Service) and a Startup Director (Bechtel), assisted by Principal Startup Engineer-Methods /Adainistration, Principal Startup Engineer-Construction Compliance and Principal Startup Engineer-Testing with addition-al support by Public Service and Bechtel on-site engineering, technical and administrative personnel. The QA Startup Engineer and his staff perform a staff function to PSSUG, and identify to the Startup Manager or his designee all quality related prob-lems associated with Q/F listed activities. The General Elec-tric Operations Manager and his staff at the site interface and

.

.

support the Startup Manager for the NSSS Test and Startup Pro-gram at the Hope Creek Generating Station. SAP-2 also delin-eates PSSUG interfaces with different groups or entities essen-tial to the test and startup program as described in SAP-2, Paragraph The Startup Manager interfaces with the Principal Construction Engineer - site construction on the matters related to moni-toring of construction quality, cost and schedule, and Bechtel startup procurement activities. He also interfaces with the General Manager Hope Creek Operations on matters relating to utilization of operations personnel, facility, and development and review of test and startup programs and procedures and their implementation for all quality control test and startup activ-ities which include Component and System Turnover (C/ST) pack-ages, spare parts program, and Phase II Preventive Maintenance Program. The Operations /Startup Coordinator interfaces with the Integrated Test Engineer, the Principal Startup Engineer-Test-ing, and the Site Engineering Construction Scheduling Group to establish job priorities, coordination, review, and completion of Test and Startup activities. The Startup Manager also interfaces with the Manager - QA Engineering and Construction for all matters related to review and evaluation of Admints-trative programs, procedures, corrective actions, significant deficiencies, C/ST turnover packages, and audit of Test and Startup activities, including NRC inspections. He also inter-faces with the Bechtel Construction Manager for interorganiza-tional support for Phase I and II test programs and compon-ent/ system and facility turnover activities. On the matters related to problems involving engineering evaluation of system or facility turnover, the Startup Manager interfaces with the Site Engineering Manager - Hope Creek for timely resolution. He additionally interfaces with the Managers - Research and Testing Laboratories for specialized laboratory support to the Test and Startup Program and with the Substation Supervisor -Camden Relay Division for ascertaining availability of specialized training and procedures in the areas of power distribution protective relay and protective circuit calibration during the Test and Startup Progra The inspector discussed the Test and Startup Organization with the Principal Startup Engineer - Methods / Administration regard-ing responsibility, authority and qualification and training of personnel performing Test and Startup activities. The inspector also reviewed the qualification / certification and training records of three randomly selected individuals - Level I (1),

Level II (1) and Level III (1).

.

.

.

A typical training package contained a Medical Certificate, a list of required reading materials, topics of discussion, per-formance evaluation, Certificate of Qualification (Levels I, II and III), personal resume (update) and completion of the QA training course. The Methods / Administration document control administrative support group maintains the training schedule, course outlines, training meeting attendance sheets, and train-ing makeup session documentation for Test and Startup personne Based on the above sampling review the inspector determined that for those reviewed the qualification and training of the in-dividuals performing quality control test and startup activities is adequate and the lines of authority and their responsibil-ities are comprehensive, defined and implemented and that interorgeaizational interfaces relative to Test and Startup Phase I and II are adequat No violations were identifie .2 Design Changes and Modifications 2. References / Requirements

--

Final Safety Analysis Report (FSAR) Sections 13 and 1 Technical Specification (draft), Section ANSI N45.2.11-1974, Qaulity Assurance Requirements for the Design of Nuclear Power Plant CFR 50 Appendix B, Quality Assurance Criteria for Nu-clear Power Plant CFR 50.59, Changes, Tests and Experiments

--

ANSI N18.7-1976, Administrative Controls and Operational Quality Assurance for the Operational Phase of Nuclear Power Plant SAP-6, Startup Quality Assurance Program, Rev. SAP-7, System Turnover Test Plan, Rev. SAP-9, Corrective and Preventive Maintenance, Rev. SAP-10, Startup Deviation Report Program, Rev. SAP-12, Design Change and Retest Control, Rev. .

.

--

SAP-15, Personnel Certification, Rev. SAP-18, Temporary Modification Control, Rev. 2

--

SAP-23, Startup Design Information Request, Rev. .2.2 Program Review The inspector reviewed the licensee's Test and Startup Program for design changes and modifications to determine that:

--

The review, processing and implementation of design changes and modifications are conducted according to the procedural control The cognizant engineer is aware of the design changes and modification The testing and retesting of the system / component has been conducted, as required, prior to work completio QA/QC involvement for review and approval of the design changes and modifications is adequate.

2.2.3 Program Implementation l The licensee has developed the Startup Deviation Report (SDR)

Program through which all design, construction and test /startup deviations for Q and F listed components / systems or balance of plant items are identified during the Phase I and Phase II Test

! Progra The SDR is assigned a unique identification number and associated Design Change Package (DCP) numbe It indicates

,

system / subsystem identification, deficiency description, dis-position, verification, QA certification, and Startup Manager approval for closure. Revisions to any SOR receives the same level of review and approval as the original. The inspector i reviewed the following design change packages:

l l Reactor Protection System DCP-59, SDR-SB-0057, Q, RPS, " Repair Protection System H11P609/611".

'

Dwg. Nos. 10855-N1-C71-1020-6, SH 9 & 11 Rev. BR E-2187-0(Q), Rev. 0 10855-E-1664-1(Q), SH6, Rev. 6 l 10855-N1-H11-P609-78, SH5, and 6, Rev. BR 4 and SH21, Rev. BR 1 10855-N1-H11-P611-82 SH 6, 10 and 20 Rev. BR 0

_ _ - - _ . . .. _ _ . - _ _- .

9-

2. Condensate Storage and Transfer System DCP-62, SDR-AP-0005, Q, " CRC Panel 10C621" Dwg. Nos. 10855-N1-H11-P621-32(5) Rev. BR 4 10855-N1-H11-P621-32(8) Rev. BR 4 3. Nuclear Boiler and Reactor Recirculation System DCP-81 SDR-BB-0029, Q, " Bailey Logic Correction" Dwg. Nos. 10855-J200(Q)-1441, SH1, Rev. 3/c

~

10855-J200(Q)-1447, SH2, Rev. 3/c 10855-J200(Q)-3085,SH1 10855-J4042-0(Q), SH9, Rev. 1 4. 480 VAC (Class 1E) Substation Power DCP-233, SDR-PG-0073, Q, " Add Seam Weld..."

Dwg. Nos. 10855-E 117 (Q)-54, Rev. BR 1 10855-E 117 (Q)-55, Rev. BR 1 10855-E 117 (Q)-56, Rev. BR 1 10855-E 117 (Q)-57, Rev. BR 1 10855-E 117 (Q)-58, Rev. BR 1 10855-E 117 (Q)-59, Rev. BR 1 10855-E 117 (Q)-60, Rev. BR 1 10855-E 117 (Q)-61, Rev. BR 1 5. Condensate Storage and Transfer System DCP-7400, SDR AP-0088, Q, " Addition of Pipe Support" Dwg. Nos. 10855-1-P-AP-017-H65 (Q) Rev. 0 10855-1-P-AP-017-H66 (Q) Rev. 0 10855-1-P-AP-017-H67 (Q) Rev. 0 6. , Nuclear Boiler and Reactor Recirculation System DCP-60, SDR-BB-0026, (Q), " CRC Panel 10C631" Dwg. No. 10855-N-H11-P631-30(1), BR 2 7. Liquid Radwaste System DCP-Voided SDR-HB-0199, Non-Q, " Level Element Cable Installation".

- _ _ _ - _ _ _ _ _ _ _

_ ___ _ _______ ____ _____ __

.

.

DCP-60, Item No. 6 above, was cancelled because the work had already been completed. Item No. 7 was voided because the deficiency was identified in SDR No. HB-0100, and consequently, no DCP identifica-tion number was assigned. The inspector determined that the design change packages examined were complete, and reflected the implemen- l tation of procedural controls for review, processing, and final dis-position and approval to close out of the startup deficiency report for design changes and modifications. The information provided in the packages was adequate to verify the program implementation. The Startup QA Engineer and his staff have reviewed, concurred and approved design changes, and performed surveillance and monitoring as well as witness the mandatory witness points of work completio No violations were identifie l 3.0 QA/QC Overview The inspector reviewed the Startup QA Program and associated activities /

documentation to determine the adequacy of QA/QC involvement in the pre-operational test program - test organization, design changes and modifica-tions, and training of personnel performing quality control test and start-up activities. The QA Startup Engineer performs a staff function to PSSU He performs liaison with the startup management on all quality matter His staff performs surveillance of startup activities, review of startup

.

!

deficiency reports, technical procedures, turn over documents, and reviews test results for compliance, completeness and legibility, and performs surveillance at mandatory witness points (MWPs) as require The QA Startup Engineering staff validates, initiates and reviews all Q/F listed SDRs, concurs with and verifies their disposition; evaluates poten-tial reportability as required by 10 CFR 50.55(e), and 10 CFR 21; monitors repatitive conditions; and performs surveillance of SDRs to ascertain com-pletion of prerequisites for preoperational testin The qualification / certification of the personnel performing quality control test and startup activities at Hope Creek is conducted according to ANSI N45.2.6, and Regulatory Guide 1.8. QA-Engineering and Construction conducts a mandatory QA Training course outlined in QA Manual-40, for all individuals participating in Q/F testing activitie Based on the above observations and review the inspector determined that the QA involvement in the Preoperational Test Program in the areas of test organization, design changes and modifications, and personnel training is adequat No violations were identifie _ - _ _ _ _ _ _ _ _ _

.

.

4.0 Preoperational Test Procedure Review and Verification 4.1 PTP Review and Verification The PTPs listed below were reviewed in preparation for test witness-ing, for technical and administrative adequacy and for verification that testing is planned to adequately satisfy regulatory guidance and licensee commitments. They were also reviewed to verify licensee review and approval, proper format, test objectives, pre-requisites, initial conditions, test data recording requirements and system return to norma PTP-BE-1, Reactor Core Spray, Revision 0, June 25, 1985; and,

--

PTP-SF-1C, Rod Worth Minimizer System, Revision 0, June 14, 1985 4.2 Findings During review of PTP-BE-1 the inspector had several questions concern-ing core spray injection valve stroking with maximum differential pressure. GE Preoperational Test Specification, GE 22A2271 AZ, GE 12, Low Pressure Core Spray, Revision 2, states that the injection valves should start to open with 730 psid or the maximum psid practicabl The licensee intends to stroke the injection valves with full core spray pump shutoff head on one side of the valve and atmospheric pressure on the opposite side. This was discussed with the senior site GE representative and determined to be acceptable.

The inspector had no further questions.

Review of PTP-SF-IC (a non-Q procedure) indicated that one prerequi-site was overlooked. The Rod Sequence Control System (RSCS) was not I bypassed. Failure to bypass the RSCS as stated in the GE preopera-tional test specification could cause erroneous test results due to RSCS interaction with the Rod Worth Minimizer system. The licensee reviewed PTP-SF-1C and subsequently agreed that RSCS should be by-passed. PTP-SF-1C will be revised to ensure bypassing of the RSCS is incorporated into the test prerequisites. This item will be re-viewed during a subsequent routine inspection. This item was also discussed at length with the startup manager subsequent to the exit meeting on June 28, 198 No violations were identifie .

!

.

-- -

..

.

.

One additional item identified in Inspection Report 50-354/85-13, Paragraph 2.3, concerning attachment of GTP-25, Final Air Balance and GTP-24, Filter Testing to PTP-GT-1, Drywell Ve :tilation, was reviewe PTP-GT-1 has been revised by on-the-spot (OTS) change No.-5 to re-quire GTP-24 and 25 to be attached to PTP-GT-1 to ensure they are PORC reviewed for test results as part of the PTP-GT-1 test packag The inspector had no further question .0 Plant Tours The inspector made several tours of the various areas of the facility to obPrve work in progress, housekeeping, cleanliness controls and status of construction and preoperational test activitie .1 Findings During one of the plant tours the inspector noted water coming out of a floor drain in the 'A' RHR pump room. Approximately one to two inches of water had accumulated on the floor. A portable welder was sitting near the floor drain in the vater. This was reported to site safety department by the inspector and subsequently remove t Floor drains and equipment drains in Emergency Core Cooling System (ECCS)

vaults are required to be connected in a manner that will not allow back flow into an ECCS vault. The inspector questioned the possibility of com-mon mode flooding between ECCS Vaults since many of the drains were ex-posed to vault atmosphere. A review of P&ID M-97-1 Sheet 2 of 3, Revision 4 indicated that the system was divided into a dirty radwaste (DRW) and a clean radwaste (CRW) system. The DRW system was separate and independent

,

for each ECCS vault with check valves at the DRW sump to prevent backflood-

'

ing. The CRW however, indicated several connections between the ECCS vault The CRW system consists of numerous four inch equipment drains in each ECCS

,

Vault. A review of FSAR Section 9.3.3, Equipment and Floor Drainage Systems, indicated that system design was such that backflooding could not occur.

'

'

The inspector questioned the licensee concerning the above. The licensee produced several plumbing and draining drawings that identified each drain in each ECCS vault. The licensee and the inspector using the appropriate drawing located each drain in three ECCS Vaults. The drains that were open to atmosphere were all part of the DRW system. With the exception of several drains that had temporary fittings to allow drain system testing, all CRW drains were covered with a plate welded to the equipment drain pipe and the drain funnel or with a blank welded plate if they were c.-

signated as not to be used, in accordance with Bechtel drawing P-8000-0 Revision 10. Closure of CRW drains in accordance with design drawings will eliminate the possibility of backflooding through the CRW n stem. The inspector also noted that drain clean-out connection cover plates were to l

- --. _ - - , - -_ - -

- _

-

- -_ -- - . .- .. .. .._.. _ - - . .- - - - -.

. ,

.

.

be screw in plugs which could casily be removed and present a possible common mode flooding pat The inspector stated that this item is un-

, resolved pending removal of temporary fittings and final drain closure t

and development of approved administrative controls to prevent unauthor-ized removal of clean out connection plugs (354/85-30-01).

6.0 Unresolved Items Unresolved items are matters about which more information is required in l order ~to ascertain whether they are acceptable, an item of noncompliance 1 or a deviation. An unresolved item is identified in paragraph .0 Exit Interview i

A management meeting was held at the conclusion of the inspection on June 28, 1985, to discuss the scope and findings as detailed in this report (see Paragraph I for attendees). No written information was provided to the licensee at any time during the inspection.

i

i l

!.

.

.

1

,

I

e

,_-.,,*,3- , - - - . _,# . . -wm_--..-.,,,,,_,---m=-,.-- ,y. m., ,m_,--w_,,-, ,-..y- ,m, , , , , ,y, e,,.---.-,_. --,... - , _ . .