IR 05000322/1985031

Insp Rept 50-322/85-31 on 850729-0812.Violation Noted: Failure of Test Personnel to Implement Governing Startup Test Procedures for Activities Affecting Quality

ML20133C185
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/18/1985
From:	Eselgroth P, Florek D, Kucharski S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133C166	List: IR 05000322/1985031 IR 05000729/2008012 ML20133C161
References
50-322-85-31, NUDOCS 8510070260
Download: ML20133C185 (10)

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i U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-31 Docket N '

License No. NPF-36 Category C Licensee: Long Island Lighting C East Old Country Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear Power Station Inspection At: Shoreham, New York Inspection Conducted: July 29, 1985 - August 12, 1985 Inspectors: - b D. Florek, ).e d Rea r Engineer Idate

$ / shy Ruchir's Reactor Engineer ' date Approved by: M f P. Eselgrot Chief, Test Program Sectiai date Inspection Summary: Inspection on July 29 - August 14, 1795 (Inspect ion Report 50-322/85-31)

Areas Inspected: Routine, unannounced inspection of the startup 1.'st profram during test condition heatup including startup test witnessing, and -tartup test results evaluation; licensee action on previous inspection findii 's; QA/QC interfaces; independent measurements / calculations; and tours of t o facility. The inspection involved 128 hours0.00148 days <br />0.0356 hours <br />2.116402e-4 weeks <br />4.8704e-5 months <br /> onsite by two region based inspectors.

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Results

One violation was identified for failure of test personnel to conduct test activities in full compliance with the governing procedure (see

) Section 3.3).

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8510070260 850926 PDR ADOCK 05000322 G PDR.

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DETAILS 1.0 Persons Contacted Long Island Lighting Company and Contractors D. Bouchie, Lead STD&A, Engineer

• R. Grunseich, Supervisor, Nuclear Licensing

• A. Himle, PATP Test Coordinator R. Lawrence, Project Advisory Engineer

• R. Macina, Reactor Engineer

• S. Petty, QC Supervisor

"G. Rhodes, Operations Compliance Engineer

• J. Riley, GE Operations Manager

• J. Scalice, Operations Manager W. Steiger, Plant Manager

• denotes those present at exit meeting on August 12, 1985

U.S. Nuclear Regulatory Commission J. Berry, Senior Resident Inspector Designee E. Conner, Project Engineer R. Fuhrmeister, Reactor Engineer 2.0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (322/85-28-01) This item dealt with completion of review of open vessel startup testing results, definition of plateau review activities prior to proceeding into the next test condition and activities for removal of a plant hold following a level 1 startup test exceptio Inspection Report 50-322/85-29 reviewed licensee actions on test result review and proposed draft changes to the startup test admini-strative procedure and indicated the item would remain open pending approv-val of the change to the startup test administrative procedure. The in-spector reviewed Review of Operations Committee (ROC) approved SPCN 85-1045 dated July 22, 1985. This item is close .0 Startup Test Program References:

Shoreham Nuclear Power Station (SNPS), Final Safety Analysis Report

SNPS Safety Evaluation Report

Reguiatory Guide 1.68 " Initial Test Programs for Water Cooled Reactor Power Plants"

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SNPS Power Ascension Phase Planning Schedule l

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• SP-12.075.01 Administration of Startup Testing 1 ,

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• ANSI N18.7-1976 "Administrutive Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants 3.1 Startup and Surveillance Test Witnessing i

i Scope

! The inspector witnessed portions of the following tests and related

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i i * SP-24.202.01 High Pressure Coolant Injection (HPCI) Surveillance

! Test at 150 psig l

j * STP-15.8.1 HPCI Startup Test at 150 psig

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• SP 23.109.01 Station startup procedure for the feedwater and j feedwater control system a STP-5.6.1/8.2/8.3 Control Rod Drive Testing

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SP-24.119.01 Reactor Core Isolation Coding (RCIC) Pump Surveillance i Test at Rated Pressure j * HPCI pump operability test at Rated Pressure

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Portions of the activities associated with achieving rated i pressur The tests and activities were reviewed against the attributes identified j in inspection report 50-322/85-29.

Discussion

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The HPCI surveillance test was performed on July 31, 1985. No problems

occurred during this test. The system was initiated at a pressure of 135 psig and demonstrated its ability to functio The pressure was then in-i creased to 160 psig so that STP 15- section 8.1 could be performed. Sec- 1 l tion 8.1 is the HPCI operability test CST to CST at 150 psig. There were '

no problems during the performance of this test. Two hot quick starts i

were also performed. The inspector checked the strip chart recorder to

verify 4250 gpm flow was developed within 25 second On August 1, 1985 the licensee performed SP 23.109.01 section 8.1. I which involves setting the minimum flow valve, rolling the reactor feed-

water pump turbine, tripping it, and then restarting the turbine and i slowly bringing it up to 1000 RPM. This was performed at a reactor

! pressure of 350 psig. The "A" Reactor Feed Pump Turbine (RFPT) was tested, and

the min flow valve was set at 20% which allowed the "A" pump to develop

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2400 gpm.

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I When the "B" RFPT was tested it was discovered that the flow transmitter

, line was improperly installed. Once this was repaired the "B" RFPT was tested again then shut down and placed in standby. The feedwater system

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is not a safety related system.

, On August 3, 1985 and August 4, 1985 the Control Rod Drive (CRD) selected

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scram. timing test was run for five (5) selected rods at 600 and.800 psig reactor pressure, as follows: Rod 22-23, 50-19, 22-34, 18-27 and 30-3 The scram times to notch 05 were below the technical specification maximum time limit of 3.49 seconds.

, During the heatup to rated temperature no divergence in the reactor

vessel water level indications were observed as described in inspection

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report _50-322/85-29. Thus the licensee corrective action appeared to be acceptable to resolve the reactor water level divergence problem.

! On August 6,1985 at approximately 2140 hrs, the reactor achieved 920 i psig. At this pressure high frequency oscillations in the position of j the turbine bypass valve (TBV) were observed. At this time the "A" l pressure regulator was in contro The licer.see reduced reactor pressure l and the oscillations were reduced. The licensee swapped over to the "B" i pressure regulator and reestablished rated pressure. No oscillations

, were noted. The licensee is continuing to determine the cause of the "A" i pressure regulator related oscillations.

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! On August 7, 1985 at 0905 hours0.0105 days <br />0.251 hours <br />0.0015 weeks <br />3.443525e-4 months <br /> the licensee attempted to perform the RCIC

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operability test at rated pressure. The reactor was at 917 psig with one l TBV open 25%. This was the first attempt at operation of RCIC at rated

pressure. During the attempt a valve packing leak on MOV-43 was identi-l fied by the operator stationed at the RCIC turbine and the turbine'was

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secured. The licensee adjusted the valve packing and the test was per-i formed again at 1110 hrs. Reactor conditions were the same as the pre-

, vious attempt. Approximately 3% of a bypass valve movement was observed

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during the test. The surveillance test acceptance criteria were satisfie The inspector observed senior licensee management overseeing the activities i being performed.

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On August 8, 1985 the licensee attempted to perform the surveillance operability test on HPCI. Prior to the performance of the test the

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licensee performed tune up activities on portions of the HPCI control The licensee made two attempts to start HPCli however the turbine stop valve would not open. Licensee investigation determined the cause to be i'

insufficient hydraulic pressure to open the stop valve. The licensee repaired HPCI and on August 9, 1985 performed another attempt at the HPCI operability test. The reactor was at 958 psig and the bypass valves ~

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approximately 33% open. HPCI satisfactorily initiated but the control room operator was unable to throttle the test return valve against the i

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q pump discharge pressure when the valve pressure difference approached 1000 i

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psig. The licensee was required to achieve greater than 1233 psi Attempts to manually adjust the test valve were not successful. When suppression pool temperature achieved 104 F the turbine was manually shut down per the technical specification limits on suppression pool tempera-l ture. The licensee adjusted the torque setting on the' test return valve and repeated the HPCI test on August 10, 1985. The HPCI satisfactorily passed the surveillance during this attempt. The initial turbine bypass i

position was 33% open and reactor pressure was 958 psig. With the HPCI l' developing 4250 gpm with a discharge pressure of 1250 psig the bypass valve was fully closed and reactor pressure dropped to approximately 952 psi This was the first time HPCI was operated at these conditions. During the

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HPCI testing the inspector observed coordination among the operations i personnel and that the personnel were assessing the entire plant perform-I' ance not just focusing on the HPCI performanc t Over the period August 8-12, 1985 the inspector witnessed portions of the

. control rod testing which included insert withdraw testing, scram time j testing and friction testing. The control rods tested were those rods in the "B" control rod sequence. The inspector witnessed testing activities j both in the control room and by the hydraulic control units'. Seven tests were witnessed. The scram times of these rods witnessed met the accep-

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tance criteria and were conducted at the required initial conditions. The i normal insert time for rod 18-27 required adjustment and the friction testing of rod 18-27 required a repeat performance. The inspector i observed that field actuation of control rod: was under the direction of j the operator at the controls. Additional discussion regarding friction j testing is found in the findings section.

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Findings

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During the performance of the control rod drive friction test of selected rods on August 8, 1985, the inspector witnessed portions of the test l preparation and test implementation in the control room and in the field l at the hydraulic control units (HCU). '

The inspector concluded that the test was not being performed in full

! compliance with the governing proceJure. This conclusion is based on the i

following observations and sequence of events:

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During final test preparation in the field the inspector inquired of the l test engineer whether the pressure differential test box is connected to

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the specific HCU with the rod withdrawn or fully inserted and whether any I of the valves at the HCU were required to be operated as part of this

. test. The test engineer indicated that there were no such requirements.

] The inspector witnessed two friction tests (rods 22-23, and 22-39)

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conducted in the field for which the differential pressure test box was l connected with the rod withdrawn from the core (based on test engineer i information) and the cooling water isolation valve open (inspector obser-i

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vation). Communication was established between the field and control

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6"x . room. Rod 18-27 required adjustment for slow normal insert speed and was

~a djuste Rod 18-27 failed the test criteria for a continuous insert fric-tion test and required a more precise settling test which was performe The cooling water valve was not closed during this test. The inspector reviewed the test results and also reviewed the document referenced in STP-5, General Electric K-document (GEK)-71240. The inspector then noted that STP-5' required preparation of the friction test in accordance with GEK-7124 GEK-71240 requires connection of the pressure differential test box with the rod fully inserted and required the cooling water valve to be closed during testing. The inspecter noted, however, that there was some conflict in the GEK wherein section 4-89 indicates that the cooling water need not be valved out for performance of the continuous insert friction test, but was required to be closed for the settling friction test. However, Section 4-56 requires closing the cooling water valve when performing a friction tes The inspector informed the test director and Watch Engineer that the fric-tion test was not being performed in accordance with the test procedur L The licensee took the following corrective actions: TPC-85-585 was pre-pared making it clear in the procedure that when friction testing is per-formed, the pressure differential test box is connected with the rods fully inserted and the cooling water valve is closed. The licensee provided counseling to the test personnel which included that all test personnel have the required referenced procedures in the field and that these are reviewed prior to the test performance. The inspector also noted that the STP-5 did have a prerequisite in step STP-5.8.2.1.10 that GEK 71240 Section 4.56 and 4.88 be reviewed prior to the test performance. The licensee j re performed the friction test on rod 18-27 with the cooling water valve  ;

j closed. The licensee utilized the GEK section 4.88 to justify not repeat-ing the continuous insert friction tests on control rods 22-23 and 22-39 with the cooling water valve closed. This was acceptable to the inspector.

5 On August 9,1985, the inspector witnessed friction testing on control rod  ;

50-19 after the licensee corrective actions were taken and no further pro-blems wera note The inspector stated that this is one of three examples of licensee test i

personnel not following the governing procedure and is considered a

violation. This is summarized in section 3.3.

i 3.2 Test Results Evaluation i Scope The inspector reviewed the test results listed in the discussion section

,7rior to the completion of the licensee review process. The inspector

utilized the attributes identified in inspection report 50-322/85-29.

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Discussion A summary of each test review is found belo STP-5. " Insert Withdraw Timing of Selected Rods at Rate Pressure" The rods were satisfactorily tested. Adjustments were made if required per the procedur STP-5. " Friction Testing of Selected Rods at Rated Pressure" All rods except 18-27 passed the friction test See the finding section regarding additional informatio STP-5. Scram Times of Selected Rods at 600 and 800 psig reactor pressure" All test acceptance criteria were satisfied for the selected rod STP-9. " Water Level Measurement at the End of Heatup" All levels sensors except level sensors 1821-LT-154/155 and IC61-LI-004 satisfied the acceptance criteri See the finding section for additional discussion STP-14. "RCIC Testing at rated Pressure" The inspector reviewed the testing completed to date on RCIC at rated pressure. The RCIC quick start at rated pressure CST to CST was not yet completed at the conclusion of this inspection. The response to step changes identified no divergent oscillations.

Findings On August 11, 1985 during inspector review of test results for STP-5.8.2

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and on August 9,1985 during review of STP-9.8.1 the inspector identified two items wherein the test personnel did not perform the analysis in a manner as specified in the governing procedur During the friction test data evaluation on rod 18-27 after the re performance of the test to close the cooling water supply valve (see section 3.1), the inspector noted that the licensee had indicated the rod had passed the settling test acceptance criteria in STP-5. t i

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Inspector review of the data identified that the test personnel utilized a different method to evaluate the data than was defined in the test procedure and when done as described in the test procedure, the control rod did not satisfy the test criteria. The startup test STP-5 requires, in section 8.2.2.2, determination of the maximum and minimum differential l

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pressure for the settling test and the difference in these value The <

) minimum value must be greater than 30 psid and the difference must be ,

l less than 10 psid. Inspector evaluation of the test data indicated the

minimum value of settling pressure was 30 psid and the maximum was 44

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psid. The difference of 14 psid indicated the rod did not satisfy the

} test criterion. The licensee acknowladged the inspector finding and

. -indicated a test exception would be prepared with the resolution to be

, taken as described in GEK-7124 The approach is to cycle the control j rod several times and repeat the test. The licensee specific actions will be evaluated in a subsequent inspection however the technical approach is acceptabl . During inspector review of STP-9.8.1 the inspector noted that test personnel

! had indicated that all the reactor water level indicators were acceptable

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even though test data indicates 1821-CT-154/155 and IC61-LI-004 did not  !

! meet the acceptance criteria. The test personnel noted in the procedure

! that these level indications did not satisfy the acceptanca criteria but l judged that they were acceptable in any event. The licensee administrative

procedure for the startup test program, SP-12.075.01, requires the test i director to prepare a test exception whenever the test results fail to

] satisfy an acceptance criterion. The test personnel did not prepare a i test exception for this failure. Following identification by the inspector, i the licensee prepared the~ required test exception with the resolution to 1 include additional calibration checks on the appropriate portion of the

level indication circuit.

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Theinspectorstatedthattheabovearetwoadditionalixamplesofthe

licensee test personnel not following the governing procedure. This is considered a violation. This and the other examples are summarized in

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j 3.3 Test Personnel performance

, During the course of the inspection the inspector held several discussions

! with startup test personnel and witnessed many of their activities. In i summary, the test personnel appear knowledgeable of their responsibilities

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and task assignment However, the inspector noted three examples as discribed in sections 3.1 and 3.2 wherein test personnel appear not to j have followed the governing procedur The three examples are summarized

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During the conduct of the friction testing of the selected

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rocs the test personnel did not assure the differential pressure test box

was connected to the HCU with the rod fully inserted ; d did not close the

! cooling water valve when conducting the settling test. During the data evaluation of the settling test of rod 18-27, the test personnel did not i properly determine the maximum and minimum settling pressure over the full

stroke and the pressure difference and did not note that the difference i exceeded the test acceptance criteria. During test personnel data evalua-

, tion of water level measurements, test personnel did not follow the admini-l strative procedure for preparation of a test exception when the test data j did not satisfy the acceptance criteria.

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10 CFR 50 Appendix B Criterion V requires in part that " activities affect-

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ing quality shall be prescribed by documented procedures and shall be ac-complished in accordance with these procedures." Technical Specification , 6.8.1 contains similar requirements.

Contrary to the above, during the startup testing program three examples l were identified wherein test personnel did not implement the governing

procedure for activities affecting quality. On August 8, 1985 while

performing control rod drive friction tests on selected control rods the

test personnel did not connect the pressure differential test box with the control rod fully inserted and conduct settling friction :est on rod 18-27 with the cooling water valve closed as required in STP . 8.2. As of

! August 9, 1985, test personnel did not prepare a test exception for those i

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level indicators (1821-LT-154/155 and 1C61-LI-004) that did not meet the test acceptance criteria of STP-9.8.1 as required by SP-12-075.01. On

August 10, 1985 test personnel did not evaluate the settling friction test i of control rod 18-27 in the manner prescribed in STP-5.8.2 in that the rod j had been identified as passing the acceptance criteria when the analysis

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performed in accordance with the procedure would indicate the rod did not pass the acceptance criteria. The inspector indicated that this is con-

! sidered a violation. (322/85-31-01) The inspector noted that the licensee i took prompt corrective action to resolve each of the specific examples

identifie The inspector notes that all of the above three examples were identified i

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to the licensee by the inspector prior to the performance of their required I

independent review of the test personnel activities. The licensee indepen-dent review is established to assure that tests are conducted and analyzed in accordance with the test requirements. The inspector noted, based on discussions, that for each of the three examples, the licensee senior test personnel might have identified the inspector concerns during the indepen-dent review process. The inspector further notes that each of the examples by themselves as an isolated occurrence is of minor concern. However, the l inspector expressed concern with the frequency of the type of problems iden-

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tified considering that the on-shift test personnel are a key element in l determining go/no go situations for continuation of testing.

l 4.0 Independent Measurements / Calculations i

! The inspector conducted independent measurements of several control rod j

insert / withdraw stroke times. The inspector times agreed with the

! licensee derived values. The inspector also did independent analysis of l the data of friction tests as described in section 3.2.

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5.0 QA/QC Interfaces The inspector observed QC personnel conducting surveillance activities of startup tests being performed. The inspector observed QC personnel con-ducting surveillance activities during the conduct of friction tests when the friction tests were not being conducted as prescribed by the proce-dur Following the identification of this occurrence, and the other examples of test personnel not performing the analysis as described by the administrative and technical procedure, senior QC personnel contacted the inspector and identified additional actions and approaches that they will take to assure that the startup program is implemented properly. These actions would include more focus on the analysis and administrative procedure compliance in addition to the current witnessing of test per-formance in the fiel .0 Tours of the Facility The inspector made several tours of the facility during the course of the inspection including the turbine building, reactor building control structure and control roo No unacceptable conditions were note .0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items disclosed during the inspection are discussed in sections 2 & .0 Exit Interview At the conclusion of the sitt inspection on August 12, 1985, an exit

meeting was conducted with the licensee's senior site representatives l (denoted in paragraph 1). The findings were identified and discussed.

l At no time during the inspection did the inspector provide written inspection findings to the licensee. The licensee indicated that no proprietary information was contained in the scope of this inspection.

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