IR 05000443/1989081

Forwards Ba Boger & Encl Team Insp Rept 50-443/89-81 on 890612-23 Re Insp of Util Low Power Startup Test Program,Per Informing Board of Event During 860622 Natural Circulation Test

ML20246E283
Person / Time
Site:	Seabrook
Issue date:	08/21/1989
From:	Reis E NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#389-9080 OL, NUDOCS 8908290062
Download: ML20246E283 (13)

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/,.,'o,j UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20655 pgqite yWiC l

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~s***** / AUG 211989 89 MG 23 P2 39

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Ivan W. Smith Esq., Chairman D r. Gustave A. Linenberger . Jr.

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D C 20555 Washington, DC 20555 i

Dr.. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555

In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL.

(Seabrook Station, Units I and 2)

Docket Nos. 50-443, 50-444 Off-Site Emergency Planning - K

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Dear Administrative Judges:

In a letter of June 26, 1986 I informed the Board of an event during the June 22, 1986 natural cirulation test at Seabrook and that the Staff was sending an Augmented Inspection Team to investigate the incident. That team !

issued its report on August 17,1989 (Inspection No. 50-443/89-82 and that report is attachment 5 to the affidavit of Thomas T. Martin and Peter W.

Eselgroth submitted with August 18, 1989, "NRC Staff Response to Interveners'

' Motion to Admit Contention, or in the Alternative, To Reopen the Record, and ,

Request for Hearing'" filed with the Board. l

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I also enclose for the Board's information Report Nc. 50-443/89-81, of August 11, 1989, dealing with an inspection of the Applicants' Low Power Startup Test Program. l

Sincerely, i

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Edwin J is Deputy Assistant General Counsel j Reactor Licensing Branch  ;

Enclosure:

As stated

REGION I

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Docket No. 50-443 Public Service Company of New Hampshire ATTN: Mr. Edward A. Brown, President and Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject: Inspection No. 50-443/89-81 This letter refers to the team safety inspection led by Mr. James M. Trapp of this office on June 12-23, 1989 at Seabrook Station, Unit No. 1, Seabrook,

'New Hampshire, of activities authorized by NRC License No. NPF-67. A discussion of our findings was held by Mr. Trapp with Mr. D. Moody of your staff at the conclusion of the inspection.

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Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.

The inspectors found the Low Power Startup Tests, with the exception of the Natural Circulation Test, were conducted in conformance with license and pro-cedural requirements (see Inspection Report 50-443/89-82 for details and concerns related to the Natural Circulation Test). The inspectors found the startup testing staff to be knowledgeable and familiar with the content of the startup test procedures. The startup staff provided detailed instru:tions to the operating staff describing plant configurations required for conducting the startup tests. The preliminary evaluation of test results showed acceptable correlation between measured and predicted results.

Within the scope of this int.pection, no violations or unresolved items were observed.

No reply to this inspection is required. Your cooperation with us in this matter is appreciated.

Sincerely, A

ruce A. Boger, Acting Director Division of Reactor Safety

Enclosure:

NRC Region I Inspection Report No. 50-443/89-81

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"b' AUG 11 1989 Public Service Company .2 z: of New Hampshire

REGION I==

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Report No. 50-443/89-81 Docket No. 50-443 License No. NPF-67 Licensee: Public Service of New Hampshire P.O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: June 12-23, 1989

., Inspectors: P. Drysdale, Reactor Engineer, DRS P. Eselgroth, Chief, PWR Section, 08, DRS

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K. Kimura, Engineer, Lawrence Livermore National Laboratory D. Moy, Reactor Engineer, DRS G. Schwenk, Sr. Nuclear Engineer, NRR

& 8 - 1 - 8'l J. Trap;p Team Leader' cate Approved by: -

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7 'f Dr. P. K. Eapen, Chief, Special Test- ' da t'e Programs Section, EB, DRS Inspection Summary: Unannounced team inspection conducted June 12-23, 1989.

(Inspection Report No.50-443/89-81)

Areas Inspected: The licensee's implementation of the Low Power Startup Test

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Program. This included witnessing pre-critical preparations, approach to criticality, and startup testing performed with the reactor critical.

Results: In general the inspectors found the Startup and Operations personnel l

to be knowledgeable and informed as to the intent of the Low Power Test Program.

The Low Power Test Program was conducted in.accordance with approved procedures.

All preliminary test results reviewed, showed acceptable agreement with previously calculated design values. During the performance of the Natural Circulation l Test, the inspectors identified a condition where the operators failed to comply with a procedural step which required a manual trip of the plant. Inspection findings regarding this issue are documented in NRC Inspection Report 50-443/89-82.

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!- 1.0 Persons Contacted I i 'A. Licensee Personnel

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• R. Belanger, Lead Engineer Compliance

• S. Buchwald, QA Supervisor J. Burson, Shift Test Director i *J. Cady Jr. ISEG Supervisor A. Chesno, Startup Engineer R. Couture, Startup Engineer

• D. Cov111, Surveillance Supervisor

• E. Desmatais, IRT

• J. Grillo, Operations Manager P. Gurney, Asst. Startup Manager

.G. Kann, Startup Manager

• G. Kline, Technical Support Manager

• J. Marchi, Audit and Evaluation

"D. Mclain, Production Service Manager A. Merrill, Startup Engineer

• D. Moody, Plant Manager

• T. Murphy, I&C Supervisor

, *D. Perkins, Operational Programs

• J. Peterson, Asst. Operations Manager L. Rau, Shift Test Director J. Tefft, Shift Test Director

"W. Temple, NRC Coordinator

• J. Vargas, Manager of Engineering

• C. Vincent, QC Supervisor T. Waechter, Shift Test Director

• L. Walsh, Manager of Operations Support B. NRC Personnel N. Dudley, Senior Resident Inspector, Seabrook Station D. Haverkamp, Section Chief, DRP, Region I L. Prividy,Sr. Reactor Engineer, DRS, Region I

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• Denotes personnel present at exit meeting held on June 23, 1989.

2.0 Cycle 1 Startup Testino procram

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The purpose of this inspection was to observe the licensee's performance and to verify that the startup program was conducted in accordance with the license and Technical Specification requirement: and FSAR commitments.

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The low power physics testing procedures were reviewed previously as y

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detailed in NRC Inspection Reports Nos. 50-443/86-31, 86-48, and 88-13.

The licensee's startup procedures reviewed during these inspections are provided in Attachment A.

The startup test program was conducted according to test procedure 1-ST-1,

"Startup Test P ogram Administration," Rev. 2. 1-ST-1 outlined the steps in the test program, set special precautions, and referenced detailed tests and data collection in separate test ' procedures.

Initial criticality of Cycle I was achieved on June 13; 1989, and the Low Power Startup Physics Test program was completed on June 22, 1989.

The' inspectors independently verified that the predicted values and acceptance criteria which were obtained from "The Nuclear Design and Core Physics Characteristics of the Seabrook Unit 1 Cycle 1," dated December 1985, (WCAP-10982).were incorporated into the test procedures. The inspector reviewed the test results to ascertain,that the results met the requirements of the Technical Specifications and FSAR commitments and were within predetermined acceptance criteria.

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3.0 pre-critical Tests The inspector reviewed pre-critical calibrations and functional tests results and verified the following:

Procedures were provided with detailed instructions;

• Technical content of procedures was sufficient to result in satisfactory component calibration and test;

Instrumentation and calibrated equipment used were traceable to the National Bureau of Standards;

Acceptance and operability criteria were in compliance with Technical Specifications.

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3.1 Control Rod Drop Time The rod drop time measurement was performed in accordance with procedure RX 1700, " Rod Drop Time Surveillance", and Instrument and Control Procedure IX1666.911. The inspector reviewed the test results, to verify that all Rod Cluster Control Assemblies (RCCAs) were tested.

Rod drop times of selected RCCAs were independently verified. All RCCA drop times were less than 2.2 seconds (Technical Specifications requirement). The rod drop data were consistent with rod drop measure-ments taken earlier using Startup Procedure 1-ST-7 " Rod Drop Time Measurement."

No unacceptable conditions were identified.

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3.2 Approach To Critical'ity

.The inspectors. witnessed the-approach to criticality per. formed in accordance with Startup. Test Procedure 1-ST-16 Rev. 4, " Initial Criticality.". Criticality was achieved by withdrawing control bank D to Step 140.and diluting the RCS boron concentration to criticality.

-1/M plots were maintained by the licensee startup staff during the approach to criticality. The approach to criticality was well

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controlled by'the start-up staff and control room operators, and was

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conducted in accordance with test procedureL1-ST-16.

No unacceptable conditions were identified.

4.0 Post Critical Tests 4.1 The inspectors witnessed the conduct of the startup test program and verified the following:

Conformance to license and procedural requirements;

Adequacy of operating a:1d startup staff knowledge and ability;

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Adequacy of the test program records, including preliminary evaluation of test results.

4.2 Reactivity Computer Operational Verification The operational verification of the reactivity computer was conducted in accordance with test procedure 1-ST-16,' Rev. 4, " Initial Criticality,"

and RN-1736, Rev. 2, " Reactivity Measurements." The verification is

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performed by inserting a predetermined positive reactivity ir,to the

. core. The reactor power dorbling time is then measured using two calibrated stop watches, and converted to ar, equivalent reactivity using design parameters. The error between the measured and calculated reactivity values is then used to ensure proper reactivity computer operation. The largest measured error during this test was 2.7%,

which is'below the 4% acceptance limit. The Reactivity Computer Checkout was conducted in accordance with approved procedures. The licensee staff performance and test results were acceptable. The inspectors had no further questions regarding this test.

4.3

Boron Endpoint

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The licensee measured the boron endpoints in accordance with Startup lest Procedure 1-ST-17, Rev. 2, " Boron Endpoint," and RN-1736, Rev. 1, i " Reactivity Measurements." The inspectors witnessed all boron endpoint L measurements and noted the following preliminary results:

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,1 Measured Value Predicted Value Bank Configuration (PPM Boron) (PPM Boron) PCM/ PPM All Rods Out (ARO) 1174 1150 - -11.24 D In1. 1114 1092 -11.41 D+C In 1018 998 -11.26 D+C+B.In 917 901 -11.61-D+C+B+A In 825 801 -11.25 All Rods In (ARI)-Rod H-10 522 490 -12.36 withdrawn

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The acceptance criterion for the ARO boron endpoint is t50 PPM. _The boron endpoint acceptance criterion for other measured control rod configurations is t1000 PCM (Percent Milli Rho). All boron endpoints measured met the acceptance criteria. The largest difference was between the measured and predicted values.of 395 PCM for the ARI-Rod H-10 withdrawn test case. The tests were conducted in accordance

.with approved procedures. These results were independently verified

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by the. inspectors to be within their respective acceptance criteria.

The inspectors determined that the conduct of these tests was accept -

able and had no further questions regarding t'iese measurements.

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4.4 Isothermal Temperature Coefficient Isothermal Temperature Coefficients (ITCs) were measured and docu-mented in accordance with 1-ST-18, Rev. 2, " Isothermal Temperature Coefficients," and RN-1736, Rev. 1, " Reactivity Measurements." The inspectors witnessed all ITC measurements and reviewed the preliminary test results. The preliminary test results measured during this test were as follows:

Measured Value Predicted Value Bank Configuration (PCM/*F) (PCM/*F) ._

ARD -1.43(D/206 Steps) -1.21(D/228 Steps)

D-IN -2.27(D/30 Steps) -2.01 (D/0 Steps)

C+D-IN -6.88(B/206 Steps) -5.92 (C/0 Steps) 1 The preliminary ITC results. evaluation indicates that the ITC measure-

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ments are within the 13 PCM/*F acceptance criteria. The inspectors observed that the measured ARO Moderator Temperature Coefficient (MTC)

is positive. A positive MTC is allowed during physics testing by Technical Specification Special Test Exception 3/4.10.3 but not allowed during normal Mode 2 operation. The licensee procedure RX-1704,

" Moderator Temperature Coefficient Surveillance," provides the necessary administrative controls to implement the above technical specification test exception. The inspectors determined that the conduct of the above tests was acceptable and had no further questions in this regard.

4.5 Control Rod Worth Measurement The control rod reactivity worth measurements were performed in accordance with Startup Test Procedure 1-ST-20, Rev. 2, " Rod Worth

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l Measurement," and RN-1736, Rev. 1, " Reactivity Measurements." The inspectors witnessed all rod worth measurements performed by the licensee and independently verified the test results. The rod worth measurements were performed using both dilution and rod swap methods.

The results indicated below are preliminary and used the dilution method for rod worth measurement:

Measured Worth Predicted Worth Bank (PCM) (PCM)

C/D 669 645 C/C 1052 1045 C/B 1153 1116 C/A 1026 1090 S/E 486 535 S/D 680 673 S/C 1021 1010 S/A+SB(H-10 out) 1555 1591 The acceptance criteria for control rod worth measurements is 115%

or .1% Delta-Rho, whichever is greater, for individual control banks and 10% for the total rod worth. All control banks measured met the acceptance criteria.

During the stuck control rod worth measurement an urgent rod stop alarm was received because the operators failed to reset the rod control alarms prior to moving the next bank of rods. The applicable procedure did not have a step to reset this alarm. The stuck control rod worth measurement is a one time measurement and it is not required to be repeated during future reloads.

The control rod worth measurements were performed in accordance with approved procedures and the results were acceptable. The inspectors verified the measured shutdown margin met Technical Specification, requirements for the ARI condition with the highest worth rod stuck out test case. No unacceptable cor,ditions were identified during the red worth measurement terts.

4.6 pseudo Rod Ejection Test The pseudo rod ejection test was performed by placing the control banks at the Technical Specification rod insertion limits (RIL) and withdrawing Rod D-12 (control bank D) to the fully withdrawn position.

1-ST-21, Pseudo Rod Ejection Test was the governing procedure for this test. With this control rod configuration, the reactivity worth of rod D-12 and incore flux was mapped. The results indicated that the worth of rod D-12 was 480 PCM, and the peak Fq (Total peaking factor) was 7.91. The acceptance criteria stated in the FSAR for the pseudo rod ejection test are reactivity worth of rod D-12 < 860 PCM, and the peak Fq < 13. The measured results were within the FSAR acceptance criteria. The results were independently verified by the -

inspectors and found to be acceptable. No unacceptable conditions were identified during this test.

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E 4.7 Power Distribution Measurements The inspectors witnessed flux distribution measurements taken with a number of different control rod configurations. Power distribution measurements are made using procedures 1-ST-19, Rev. 2, " Flux Distribu- 4 tion Measurements at Low Power," RN-1733, Rev. O, " Flux Mapping System," '

and RN-1732, Rev. O, "Incore Analysis." These test procedures provided adequate detail for operating the moveable incore system and analyzing incere flux maps. The acceptance criteria for low power flux distribu-tions is t10% for relative assembly power > 0.9, and 215% for relative assembly power <0.9 of the predicted to measured assembly-wise power.

The preliminary results indicated that the acceptance criteria were satisfied for all low power flux measurements. The inspectors reviewed the incore results and expressed a concern that the incore code was not deleting traces which failed validity checks. The licensee acknowledged this concern and stated that it would be addressed prior to finalizing the intore analysis. The inspectors had no other concerns regarding power distribution measurements.

4.8 Effective Full Power Minute (EFPM) Determination

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A license condition of the Seabrook 5% power license is that the licensee should not exceed a burnup of .75 Effective Full Power Hours (EFPH) which is equivalent to 45 Effective Full Power Minutes (EFPM).

To assure compliance with this condition, the licensee tracks cycle burnup by developing a computer logging program. The computer program was run on the plant process computer and used intermediate range detector amps to determine core thermal power. The intermediate range detector amps require normalization to indicate core thermal power. This normalization was performed using procedure RN-89-1-7, Rev. 00, " Core Exposure Tracking During The Low Power Test Program."

The inspectors reviewed the licensee calculation No. RECALC-89-0004 used to determine the normalization between core the.rmal power and intermediate range detector readings. The inspectors concluded that the calculations were performed in accordance with the licensee guidance " Functional Description for the Program used tc calculate accumulated core exposure during low power physics testing," mi the resulting normalization for intermediate range detectors amps was reasonable. The inspectors expressed a concern when the r,ormaliza-ticn factor was irput to the computer prior to a final review and 4pproval of the calculation. The normalization fat. tor was corrected and re-input in the computer following the review and approval of the calculation. The inspectors verified that this change in normaliza-tion factors did not affect the cumulative EFPM fc11owing the sccond normalization factor update. The total measured cumulative burnup ,

during the Low Power Test Program was 19.18 EFPM. The inspectors '

verified on a sampling basis that the EFPM computer was in reasonable agreement with the intermediate range detector amps and core exposure.

The inspectors had no further questions concerning this issue.

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~4.9 . Natural Circulation Test The natural circulation test was conducted on June 22, 1989 in 3 accordance with test procedure 1-ST-22, Rev. 2, " Natural ~ Circulation  !

Test." The test was initiated by securing all four reactor coolant pumps (RCPs) while maintaining the reactor cr:tical with a thermal power level of approximately 2%. Approximately seven minutes after the RCPs were secured, steam dump valve MS-PV-3011 failed open causing a cooldown of the Reactor Coolant System (RCS). The ensuing cooldown caused the volume of water in the .RCS to decrease which resulted in

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a decrease in pressurizer level. Startup Test Procedure 1-ST-22, '

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Rev. 2, Attachment 9.3, required that the reactor be manually tripped if the pressurizer level decreased below 17%. Pressurizer level decreased below 17% and remained below 17% for approximately five minutes. During the time the pressurizer level was below the manual reactor trip criterion, no attempt was made by the licensed operators in the control room to manually trip the reactor. During the period.

of time the. pressurizer level was below 17%, startup organization staff did not recommend to the operating staff to manually trip the reactor. Following restoration of pressurizer level, the reacter was manually tripped due to the rapidly increasing pressure. For details

. of this event, see NRC Inspection Report 50-443/89-82.

5.0 Conclusions The following observations were made by the inspection team while providing twenty-four hour a day coverage during the low power test program. Obser-vations made during the natural circulation test are provided in NRC

' Inspection Report 50-443/89-82. Listed below are the program strengths identified during.the low power testing inspection:

The Reactor Engineering staff was dedicated, and very knowledgeable in the content of the startup test procedures. The Reactor Engineers provided detailed instructions to the' plant operating staff on cen-figuration changes needed to conduct specific tests. The staff implemented the program in accordance with the test procedures.

a The effectiveness of the shift startup engineers progressively grew r stronger during the low power test program. The thift startup

) engineers became very effective in coordinating startup activities conducted during the shift.

The licensed operating staff was observed to perform well. The operators were observed to follow procedures and were cognizant on detcils uf test set!vities. There was excellent communications between the operating staff and the startup engir,eers.

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QA/QC provided continuous on shift coverage during the low power test

{ program. All QA/QC witness points reviewed were properly dispositioned by the QA/QC staff on shift. -

In general the Startup Test and Reactor Engineering procedures provided adequate detail to perform zero power physics testing. No significant procedural errors were identified during the low power test program.

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. Review of' preliminary test results showed agreement with the design calculations.

l 'The following are weaknesses identified during observations of the. low power test program.

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A single point of contact, on the startup staff, was not designated to direct the licensed operators in making reactivity and reactor power changes. When this was pointed out to shift test director changes were made to have a single reactor engineer on shift review and approve any reactivity or power changes requested by the

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startup staff.

Training of startup support staff on data evaluation techniques was identified as a weakness. The corporate personnel delegated to

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perform preliminary data evaluation had strong backgrounds in startup j' testing, but were not adequately trained in data evaluation techniques to be used at Seabrook. Preliminary and final test results will be reviewed by a cognizant reactor engineer prior to approval. The above weaknesses were corrected adequately by the licensee upon identification by the inspector.

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Attachment A Start Up Procedures Reviewed

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1-ST-1 Start Up Program Administration I-ST-7 Rod Drop Time Measurement 1-ST-16 . Initial. Criticality 1-ST-17 Boron Endpoint Measurement 1-ST-18' Isothermal Temperature Coefficient 1-ST-19 Flux Distribution Measurements 1-ST-20 Control Rod Worth Measurements 1-ST-21 Pseudo Rod Ejection Test 1-ST-22 Natural Circulation Test RN 1732 Incore Analysis RN l'733 Flux Mapping System RN 1736 Reactivity Measurements-Rx 1700 Rod Drop Time Surveillance Rx 1704' Moderator Temperature Coefficient Surveillance Rx 1705 Nuclear Enthalpy Rise Hot Channel Factor Surveillance

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