IR 05000423/1985057

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Insp Rept 50-423/85-57 on 851112-27.No Violations Noted. Major Areas Inspected:Surveillance Testing & Calibr Control, Maint,Emergency & Operating Procedures & Startup Test Program
ML20136J209
Person / Time
Site: Millstone Dominion icon.png
Issue date: 01/03/1986
From: Eselgroth P, Petrone C, Prell J, Wen P, Wink L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20136J191 List:
References
50-423-85-57, 52-423-85-57, NUDOCS 8601130269
Download: ML20136J209 (18)
v • d • e


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, U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-57 Docket N License:No. CPPR-113 Licensee: Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: November 12-27, 1985 Inspectors-iin PreT1, ctor Engineer

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/* Engineer

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Wink, Reactor Engineer / date (?/b /lz/f6 Charles Pe ne,LeadR/actorEngineer

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' date Approved by:

Peter Esel r'th, Chief, Test Program Section

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date Inspection Summary: Ro tine Announced Inspection Conducted On November 12-27, 1985 (Report No.50-423/85-57).

Areas Inspected: -Surveillance Testing and Calibration Control, Maintenance Procedures, Emergency Procedures, Operating Procedures, Initial Fuel Loading Procedure Review, Precritical Test Procedure Review, Startup Test Program and Licensee Actions on Previous Inspection Findings. The inspection involved 205 hours0.00237 days <br />0.0569 hours <br />3.38955e-4 weeks <br />7.80025e-5 months <br /> on-site by four region-based inspector Results: No violations were identifie .-

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DETAILS ~

1.0 Persons Contacted

  • Brown, Supervisor, Instrumentation and Control (I&C) - NNECO
  • K. Burton, Supervisor, Operations - NNECO

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  • R. Busch, Project Manager - NUSCO J. Chunis, Startup Engineer - NNEC0 R. Cikatz, Assistant Supervisor, Quality Control (QC) - NNECO
  • C. Clement, Supervisor, Maintenance - NNEC0 G. Closius, Supervisor, Quality Assurance (QA)/QC - NNECO K. Covin, Senior Control Room Operator - NNECO
      • K. Gray, Jr., Staff Assistant, Construction (CQA) - NUSCO J._Grogan, Plant Equipment Operator - NNECO
  • J. Harris, Supervisor, Engineering - NNEC0 J. Jenson, QA Specialist - NUSCO J. Kelley, Station Services Superintendent - NNECO J. LaWare, Lead Auditor, CQA -NUSCO
  • R. Lefebvre, Project Staff Engineer - NUSCO D. McDaniel, Reactor Engineer - NNECO

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      • D. ; Miller, Jr. , Startup Manager - NNECO D.-Moore, Assistant Operations Supervisor - NNECO J. Moore, Startup Engineer - Westinghouse
    • J. Orefice, Project Engineer - NNEC0 V. Papadopoli, Supervisor, CQA - NUSCO M. Pearson, Assistant Operations Supervisor - NNECO
      • J. Rhodes, Project Staff Engineer - NUSCO T. Rogers, I&C Engineer - NNECO J. Vernotzy, Engineer - General Electric

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U.S. Nuclear Regulatory Commission

  • A. Finkel, Lead Reactor Engineer
  • Rebelowski, Senior Resident Inspector
    • Nicholas, NRC Consultant
    • Summers, Project Engineer
    • Van Kessel, Reactor Engineer
      • Denotes those present at both the mini exit meeting on November 22 and the final exit meeting on November 27, 1985

2.0 Licensees * tions on Previous Inspection Findings (Closed) Open Item (423/85-37-02) Draft copies of operational procedures varied greatly among themselves as to the level of detail and comprehensi-veness. All draft procedures undergo review by the responsible depart-ment's supervisor and members of the Plant Operating Review Committee

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(PORC). Feedback provided by these reviews tend to standardize and make more consistent the level of detail and comprehensiveness between the procedures. The inspectors reviewed over 40 operational and surveillance procedures which had all been PORC approved. The level of detail and comprehensiveness was found to be uniform between these procedures. Based upon this review, this item is close (Close) Open Item (423/85-37-04) Most operating procedures, surveillance procedures, abnormal operating procedures and emergency operating proce-dures had not incorporated the required setpoints needed for acceptance criteria. A review of some 20 operating procedures, 11 surveillance procedures, 4 abnormal operating procedures and 11 emergency operating a procedures verified that all required setpoints had been incorporated into the procedures. This item is close (Closed) Open Item (423/85-37-05) During a previous inspection it was identified that a large percentage of surveillance procedures had not been reviewed and approved. During the present inspection a re-review of a sample of I&C and Operations Surveillance procedures indicated that nearly all surveillance procedures had been reviewed and PORC approved, with only final typing required for some of these procedures. The licensee had made satisfactory progress in the issue of these procedures which appeared adequate to support fuel load. This item is close (Closed) Unresolved Item (423/85-55-01) During a previous inspection a review of the Abnormal Operating Procedures (A0Ps) identified that only six of the 23 identified A0P's had been approved. During this inspection, the inspector re reviewed the A0Ps and the noted that all had been written and PORC approved, and with the exception of final typing and signature by the Unit Superintendent, were ready for use. The inspector also noted that due to consolidation of some A0P's and the addition of several others, the total number now identified for issue was twenty tw Based on the licensees' progress, it was clear that the remaining procedures could be signed and issued in a short time. The inspector had no further concerns about the status of the A0f's. This item is close (Closed) Unresolved Item (423/85-55-03) Certain alarms in the control room monitor more than one parameter or sensor. When one of these sensors gives an alarm, the operator may take-that sensor out of operation and then reset the alarm to monitor the remaining sensors. The licensee had not established any administrative controls for monitoring the sensor taken out of servic A sensor is taken out of service either by jumpering or lifting a lea This type of bypass is controlled by ACP-QA-2.06B, " Station Bypass Jumper Control" (NE0 8.01). ACP-QA-2.068 requires, among other things, that a log be maintained in the control room of all active jumper, lifted lead and bypass sheets. Departmental Instruction No. 3-0PS-10.02, Shift Turnover Report, requires that the oncoming Shift Supervisor and Senior Control Operator review this log and then initial the Shift Turnover

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-Report to indicate this review. Thus any alarm sensors which are by-

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passed are noted in the bypass log which the oncoming Shift Supervisor is required to read.

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Based on the above, this item is close '

(Closed) Unresolved Item (423/85-55-05) Regulatory Guide 1.33, Appen-dix A. paragraph 3 states that system operating procedures should include

" Instructions _for energizing, filling, venting, draining, startup, shut-down, and changing modes of operation...as appropriate." Procedures OP 3322 " Auxiliary Feedwater" and OP 3308, "High Pressure Safety Injection,"

do not include procedures for filling, venting and or draining the system OP 3301B, " Reactor Coolant System Fill and Vent," is used by the licensee for filling and venting the Reactor Coolant System, (RCS) after it.has been drained. In addition, work order packages contain fill and vent '

information for use when performing maintenance on RCS components. After

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maintenance is completed surveillance tests are performed to verify opera-bility. Based on the above, this item is-close (Closed) Unresolved Item (423/85-55-06) Regulatory Guide 1.33 specifies that an operating procedure be established for the Reactor Protection System-(RPS). The inspector could not establish that an operating pro-cedure had been established for the RP SP 3446 BH. " Solid State Protection System (SSPS) Operational Test," and SP 3446 F31, " Refueling SSPS Tests," are surveillance procedures used by the I&C department to establish operability of the RPS. This item is

- close (Closed) Unresolved Item (423/85-55-08)' OP3301D requires one reactor coolant pump -(RCP) remain operational for Reactor Mode 3 operation TS 3.4.1.2 however, states that 2 RCP's and 2 loops must be in operation if the reactor trip breakers are close Plant personnel indicated that there are possible operations in MODE 3 during which the reactor trip breakers are closed. OP3301 should be revised to accurately reflect TS 3.4.1.2 requirement The licensee has changed OP 33010 to require that 2 RCPs be in operation

' with the reactor trip breaker closed when in Mode 3. This item is close (Closed) Unresolved Item (423/85-59-02) During a review of the methods used by the licensee to control valve lineups during surveillance activities, the inspector noted that the responsibility for performing .

the valve lineup verifications was not clearly define Subsequently, the licensee revised their procedure ACP-QA-2.12, " System Valve Alignment i

Control," to clarify how I&C and operations should interface during valve lineup verifications. During this inspection, the revised procedure was reviewed and found acceptable. This item is close I I

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(Closed) Unresolved Item (423/85-59-03) During a previous inspection it was identified that several instruments had not been incorporated in the licensees' calibration procedure IC 3408A02. Subsequently the licensee revised and substantially increased the number of instruments included in the calibration program. During this inspection, the inspector re-reviewed this procedure and the licensee's calibration program and did not identify any additional discrepancies. This item is close (Closed) Unresolved Item (423/85-59-04) During a previous inspection it was identified that the temperature sensors installed in the plant to monitor equipment temperature required by the environmental equipment qualification (EEQ) program had not been included in the calibration program. Subsequently, the licensee added the list of EEQ temperature sensors to their procedure, IC 3408A02, Non-Technical Specification Instruments with Licensing Requirements." During this inspection, the procedure was re reviewed and found to contain a list of the EEQ tempera-ture sensors. This item is close .0 Operational Readiness 3.1 References / Requirements

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Millstone Nuclear Power Station, Unit 3, (MP-3) Technical Specifications (Final Draft), Sections 3/4 and 6

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MP-3 Final Safety Analysis Report (FSAR), Chapter 13

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_ Northeast Utilities Quality Assurance Topical Report, Revision 7

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10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants

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Regulatory Guide 1.33, February 1978, Quality Assurance Program Requirements 3.2 Program Review 3.2.1 Calibration of Safety Related Instrumentation The licensees program for the calibration of safety related instrumentation not specifically controlled by Technical Specifications was reviewed. The procedure, IC 3408 A02, "Non Technical Specification Instruments With Licensing Requirements,"

Revision 7, dated July 29, 1985 was found to contain appropriate assignment of responsibility, adequate instructions, and seven detailed instrument lists. These lists addressed instruments specified by Regulatory Guide 1.97; 10 CFR 50, Appendix R;

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Indicators for Technical = Specification Parameters; EEQ Tem-perature Monitoring; Miscellaneous Licensing Commitments; and, Computer Points for Technical Specification Parameters. The

. calibration frequency for each component was included on the checkoff list :The. inspector selected a sample of five safety related plant instruments, which are not specifically required to be cali-brated by Technical Specifications, and verified that each of

the selected instruments had been included in the master cali-bration program; that calibration procedures had been prepared and approved; and that calibration of the instruments had been performe At the time of the inspection, the licensee was in the process of updating the checklists contained in the procedures, and verifying that all- required calibration tests were included in the licensees Plant Maintenance Management System (PMMS)

computer based master calibration program. The inspectors review indicated that the licensee has an effective program

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in place to ensure that all. safety related plant instruments are included in a periodic calibration progra .2.2 Emergency Operating Procedures The status of the Emergency Operating Procedures (EOP) was reviewed to determine if they had been PORC approved and issued and to verify that all setpoints had been incorporated into the procedures. During a previous review of Revision 0 of the E0Ps, it was noted that many setpoints in the procedures were not incorporated and had been replaced by "Later". As of November 21 the licensee had completed the revision of all 43 E0P's and had PORC approved them. Approximately half of these had been retyped to incorporate PORC comments and were ready for final approval. The ifcensee plans to have all procedures approved in one wee The inspector. reviewed the following E0Ps to determine if all setpoints had been incorporated in the procedures:

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E0P 35-E-0, Reactor Trip or Safety Injection, Revision 1;

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E0P 35-ES-0.0, Rediagnosis, Revision 1;

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E0P 35 ES-0.1, Reactor Trip Response, Revision 1;

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E0P 35 ES-0.2, Natural Recirculation Cooldown, Revision 1;

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E0P 35 ES-0 1, Natural Circulation Cooldown With Steam Void In Vessel (with RVLMS);

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E0P 35 E-1, Loss of Reactor or Secondary Coolant, Revision 1;

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E0P 35 ES-1.1,'SI Termination, Revision 1;

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E0P 35 ES-1.2, Post LOCA Cooldown and Depressurization, Revision 1;

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E0P 35 ECA-0.0, Loss of All AC Power, Revision 1;

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E0P 35 ECA-0.1, Loss of All AC Power Without SI Required, Revision 1; and,

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E0P 35 E0A-1.1, Loss of Emergency Coolant Recirculation,

' Revision The inspector verified that all set points had been incorporated and, following final typing of the remaining procedures, would be ready for us No discrepancies were identifie .2.3 Abnormal Operating Procedures The licensees Abnormal Operating Procedures (AOP) werer reviewed to ascertain whether they would adequately control safety related functions in the event of a system or component mal-function indication. The inspector verified that all the A0P's specified in the FSAR, Chapter 13, Table 13.5-1 had been written and PORC approved by the licensee. As of November 22, 1985, approximately one third of the twenty one total A0P's had been signed by the station superintendent.and iscued to the fiel The remaining A0Ps needed to be retyped to incorporate the PORC comments. The inspector noted that the licensee had issued an additional 3 AOPs not specified in the FSAR. These A0P's covered failure of the refueling cavity seal, instrument failure response, and radiation monitor alarm respons A sample of four (out of twenty-one) A0Ps were reviewed for completeness and technical adequacy including setpoints, response actions, and actions to take if the expected response does not occur. The A0P's reviewed were:

A0P 3570 Earthquake; AOP 3572 Failure of Refueling Cavity Seal; A0P 3569 Severe Weather Conditions; and, A0P 3555 Reactor Coolant Leak The inspector did not identify any discrepancies during this review. The procedures appeared to be technically complete and only needed final typing prior to issue. The inspector had no further concerns about the preparation, review and issue of the ADP' r

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3.2.4 Surveillance Procedure The following operations and I&C surveillance procedures were reviewed to ensure they contained appropriate prerequisites, precautions, limitations, actions, step-by-step instructions, acceptance criteria, and checkoff lists. The completeness, accuracy and acceptability of test results were also evaluated during the review:

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SP 3441C12, Gamma Metric / Source Range Analog Channel Operational Test, Revision 0, Change 1, test completed satisfactorily on November 19, 1985; l

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SP 3450H31 Liquid Waste Effluent Flow Rate Analog Channel Operational Test, Revision 0, test performed satisfactorily on November 16, 1985;

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SP 3450F31 Waste Neutralization Sump Flow Rate Operational Check, Revision 0, test completed satisfactorily on November 19, 1985; and,

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SP 3646 A.5 Manual and Auto Transfer of Buses 34A and 34C; and 34B and 340, Test completed satisfactorily on November 19, 198 During the initial performance of the surveillance tests some errors were identified within the surveillance procedures. These errors were corrected by the license The procedures were generally com-plete and accurate. Following retyping to incorporate the final changes, they will be ready for us The following surveillance test procedures were reviewed for comple-teness and readiness for use: ,

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SP 3601F.4, Revision 0, Reactor Coolant System Pressure Isola-tion Valve Test

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SP 3602A.1 Revision 0, Rod Cluster Control Exercise

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SP 3603A.2-1, Revision 0, Testing of the New Fuel Handling Crane and Limit Switches

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SP3603AB, Revision 7, Testing the Spent Fuel Pool Bridge Inter-locks and Limit Switches

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SP3603C.1 Revision 0, Refueling Machine Operability Test

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SP 3641A Revision 2, Valve Lineup Check and Equipment Verification of the Fire Protection Water System

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SP 3446 Bil, Revision 0, Solid State Protection System (SSPS) Operational Test

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SP 3446F31, Revision 0,-Refueling SSPS Tests

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SP 3606.4, Draft C, Containment Recirculation Pump 3RSS -

PID Operational Readiness Test

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SP 3606.5, Draft B, Containment Recirculation Spray System Train A Valve Linedp Verification

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SP 3606.6, Draft A, Containment Recirculation Spray System  ;

Train B Monthly Valve Lineup Check

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SP 3610 A.3, Revision 0, RHR System Vent and Valve Lineup

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SP 3613 F.3, Revision 0, Containment Integrity During Core Alterations Or Movement of Irradiated Fuel Many of these procedures needed final typing to incorporate minor changes identified during test performance, otherwise they were complete and appeared satisfactory for use. The inspector did not identify any deficiencies with the procedure .3.2.5 Operating Procedures A sample review of the general and system operating procedures needed for initial fuel load and post core hot functional test-

.ing was made to verify they were consistent with Technical Specification, FSAR, and regulatory requirements; that all set-points had been established and that the format was consistent with ANSI N 18.7 requirements. The following procedures were reviewed:

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OP 3303A, Revision 0, Spent Fuel Bridge

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OP 33038, Revision 0, New Fuel Elevator

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OP 3303C, Revision 0, Fuel Transfer System

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OP 3303D, Revision 0, Fuel Handling Tools

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OP 3303E, Revision 0, Sigma Refueling Bridge

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OP 3303G, Revision 0, New Fuel Handling Crane

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OP 3303H, Revision 0, New Fuel Receiving Crane (3MHF-CRN3)

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OP 33018, Revision 1, Reactor Coolant System Fill and Vent

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OP 3309, Revision 0, Quench Spray

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OP 3313, Revision 0, Containment Purge Air

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OP 3314, Revision 0, Control Building Heating, Ventilation, Air Conditioning and Chill Water

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OP 3360, Revision 0, Nuclear Instrumentation

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OP 3210A, Revision 0, Refueling Preparation

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OP 32108, Revision 0, Refueling Operations

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OP 3209A, Revision 0, Reactivity Calculations - Estimated Critical Conditions

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OP 32098, Revision 0, Shutdown Margin

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OP 3314G, Revision 0, Intake Structure Ventilation

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OP 3314H, Revision 0, Emergency Generator Enclosure Ventilation

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OP 3201, Revision 0, Plant Heatup

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OP 3264, Revision 0, Control Room Annunciator Book The inspector verified that all operating procedures required for fuel load and post core hot functional testing were PORC approved and included all needed setpoints. Operating procedures needed for initial criticality, low power physics testing, and power ascension testing are lacking setpoint .3 Findings ,

No violations were identifie .0 Start Up Test Program 4.1 References

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Regulatory Guide 1.68, Revision 2, August,1978, Initial Test Programs for Water-Cooled Nuclear Power Plants Cooled Nuclear Power Plants

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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Millstone Nuclear Power Station, Unit No. 3, FSAR, Chapter 14, Initial Test Program

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Millstone Nuclear Power Station, Unit No. 3, Technical Specifi-cations, Final Draft

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Millstone Nuclear Power Station, Unit No. 3, Safety Evaluation Report

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Westinghouse - Millstone Unit 3 NSSS Startup Manual, Revision 1

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Westinghouse Nuclear Design Report, WCAP-10791, February, 1985

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Millstone Unit 3 Startup Manual, Revision 4, August 19, 1985

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ACP-QA-1.01, Revision 4, Millstone Administration

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ACP-QA-1.02, Revision 16, Organization and Responsibilities

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ACP-QA-1.04, Revision 20, Plant Operations Review Committee

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ACP-QA-3.02, Revision 34, Station Procedures and Forms

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ACP-QA-5.01, Revision 14, Non Conforming Materials and Parts

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ACP-QA-8.16, Revision 13, Training, Certification and Identi-fication of Qualified Inspection and Testing Personnel

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ACP-QA-9.04, Revision 17, Control and Calibration of Measuring and Test Equipment

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ACP-QA-9.07, Revision 0, Quality Assurance Surveillance Program

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Northeast Utilities Quality Assurance Program Topical Report, Revision 7 4.2 Program Review Scope The Millstone Unit 3 Startup Manual and Administrative Control Procedures ACP-QA-1.01, 1.02, 1.04, 3.02, 5.01, 8.16 and 9.04 were reviewed for their conformance to the requirements and guidelines of Regulatory Guide 1.68, ANSI N18.7 and Chapter 14 of the Millstone Unit 3 FSAR. The startup test program was reviewed for the following attributes:

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A startup test program has been developed and its basic phases identifie .___ ______ _-__

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The requirements of the test program are consistent with FSAR and Regulatory Guide Commitments

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Administrative documentation specifies the format and content of startup test procedures

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The test organization has been established and responsibilities have been assigned

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Interfaces between organizations involved in the test program have been clearly defined

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Methods have been established to control the release, revision and changes of test procedures

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Methods have been established to control the scheduling and coordination of testing

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Methods have been established to insure that test personnel are properly qualified and knowledgeable of the test procedures

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Methods have been established to identify, document and resolve test deficiencies

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Methods and responsibilities have been established for the evaluation and approval of test results

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Methods have been established to control the use of special test equipment 4.3 Fuel Loading Procedure Review -

Fuel loading procedures were reviewed for the following attributes and for conformance with FSAR and Regulatory Guide commitments:

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Management review and approval

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Procedure format

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Clarity of stated objectives

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Prerequisites

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Environmental conditions

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Acceptance criteria and their sources

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References

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Initial conditions

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Attainment of test objectives

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Test performance documentation and verification

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Degree of detail for test instructions

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Restoration of system to normal after testing

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Identification of test personnel

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Evaluation of test data

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Independent verification of critical steps or parameters The following fuel loading procedures were reviewed:

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3-INT-4000, Revision 0, November 8, 1985, Initial Fuel Load

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3-INT-4000, Appendix 4002, Revision 0, October 29, 1985, Opera-tional Alignment-Nuclear Instrumentation

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3-INT-4000, Appendix 4003, Revision 0, November 8, 1985, Core Load Instruments and Neutron Source Requirements

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3-INT-4000, Appendix 4004, Revision 0, November 8, 1985, Inverse Count Rate Ratio Monitoring

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3-INT-4000, Appendix 4005, Revision 0, November 8, 1985, Initial Core Loading

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3-INT-4000, Appendix 4006, Revision 0, November 2, 1985, Core Map The inspector identified several instances of missing information (identified in the procedures as "Laters") and a number of typo-graphical errors. Discussions with the Reactor Engineer indicated that information required to be added to the procedures was being formally tracked and that a test change would be processed to include this information and correct typographical errors prior to releasing the procedures for performanc .4 Post Core Hot Functional Test (PCHFT) Procedure Review The inspector reviewed the PCHFT procedures and discussed procedure content with licensee personnel to assure that the following criteria were met:

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FSAR, Technical Specifications, and specific licensee provisions, as applicable were incorporated

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Procedure reviews and approvals were performed in accordance with the licensee's administrative controls

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Test objectives were clearly stated

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Pertinent prerequisites were identified

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Acceptance criteria against which the test will be judged were clearly identified and that the procedure requires a comparison of the results against the acceptance criteria

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Step-by-step instructions for the performance of the procedure were complete to the extent necessary to assure that test objectives are met

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The procedure requires that temporary connections, disconnec-tions or jumpers be restored to normal or reference their control by another procedure

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The procedure provides identification of personnel conducting the testing and evaluating test data

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The procedures which were reviewed and discussed are the following:

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3-INT-5000, Revision 0, Post Core Hot Functional Test '

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3-INT-5000, Appendix 5001, Revision 0, Shutdown Margin

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3-INT-5000, Appendix 5002, Revision 0, RTO Cross Calibration

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3-INT-5000, Appendix 5004, Revision 0, Rod Control Slayer Cycler and CRDM Timing

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3-INT-5000, Appendix 5006, Revision 0, RCS Leak Detection

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3-INT-5000, Appendix 5007, Revision 0, Pressurizer Heaters and Spray

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3-INT-5000, Appendix 5008, Revision 0, Rod Drop Testing

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3-INT-5000, Appendix 5009, Revision 0, Precritical RCS Flow Measurement

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3-INT-5000, Appendix 5010, Revision 0, RTO Bypass Loop Verification

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3-INT-5000, Appendix 50I1, Revision 0, Movable In-Core Detector-Operation

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3-INT-5000, Appendix 5015, Revision 0, Digital Rod Position Indication Operational Test

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3-INT-5000, Appendix 5016, Revision 0, Loose Parts Monitoring System

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3-INT-5000, Appendix 5017, Revision 0, Precritical RCS Flow Coastdown Measurement

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3-INT-5000, Appendix 5018, Pevision 0, Rod Control Operational Test

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3-INT-5000, Appendix 5031, Revision 0, Chemical and Volume Control System

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3-INT-5000, Appendix 5032, Revision 0, Boron Thermal Regeneration System The inspector informed a licensee representative that the following items had not been correctly incorporated into the test procedures:

(1) Appendix 5007: Effect of pressurizer heaters and normal spray, and changes in charging and steam flow on margin to saturation temperature was not included in the test procedur This commitment was made in FSAR 14.2.1 (2) Appendix 5015: The alarm function test of Digital Rod Position Indication (DRPI) was not included in the test procedure as specified in FSAR Table 14.2- The licensee's representative acknowledged the inspector's finding Before the end of inspection period, the inspector reviewed the revised test procedures and noted that item (1) has been incorporated in test Procedure Appendix 5007 and item (2) has been incorporated by adding a mainboard alarm test associated with OPRI in the same test procedure (Appendix 5015).

A computer method is proposed to be used in test procedure Appendix 5008, to measure the rod drop time. The subject of this method's qualification was discusted with a cognizant licensee representativ The inspector acknowledged that an I&C calibration procedure is being written to qualify this method. The qualification / calibration will be performed prior to actual rod drop tes The inspector had no further question .5 Preoperational Test vs Surveillance Test Compliance During the preoperational testing program, the licensee used some preoperational tests to satisfy certain surveillance test require-ments. A review was made of the following preoperational tests and

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~their results-that will be used to satisfy those surveillance test requirements needed prior to entering MODE 6 operations:

PREOP TEST # . STEP SURVEILLANCE # TITLE INT 2004 7.9.5, & 1 .7. Service Water System (Pump and Valve) respond to ESF signal

' PreService , 4.4.1.4.21 RHR Loop Operability Inspection Program per4.0.5(ASME)

- Various Tests ( .8.4. Thermal Overload-T3312BIE0I Calibrated T3309-1M04,etc.)

4.- T3346A P001 7.12 4.8.1.1.2.F.13 Diesel Generator Lockouts Prevent Start Special Test 7.6 & .8.1.1.2. Diesel Generator 85-3-35 will start on ESF while in TEST This sample verified that all surveillance testing conditions were satisfactorily me In order to make this verification the inspector compared the test against Technical Specification requirements, reviewed test results, and verified that all UNSATS were dispost-tioned in a conservative manne .6 Fuel Loading On November 25, 1985, at 1705 the applicant received an NRC license which permitted fuel loading and performance of low power testin On November 26,1985, at 1624 the inspector witnessed the licensee load the first fuel assembly, which contained a neutron source, into the reactor vesse Prior to and during the loading of the first and subsequent fuel assemblies, the inspector performed the following:

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reviewed the shift log to see if it was current and to identify any items which could cause a delay in fuel loading,

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load had been completed. This included witnessing the calibration of the Source Range Monitor per SP 3441C12, Gamma and Source Range Op Test.

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verified that personnel and tool access controls into containment had been established and were in place,

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verified that a Senior Control Operator (SCO) dedicated to fuel loading, was inside containment, controlled all fuel movement operations and had a current license

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-verified through discussions with several operators that they were using the most current approved procedures, were well trained and understood their duties

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verified that radiation monitors were in place and properly calibrated and that knowledgeable Health Physics personnel were present and controlled activities during movement of the radioactive sources

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verified that an audio speaker was connected to the Source Range monitor inside containment and functioned properly

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witnessed a change of shift of fuel loading personnel and verified they were properly briefed before assuming their duties

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verified that the core map and the spent fuel pool map located in the Control Room was being kept current as fuel was transferred to the reactor vessel

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verified that the prerequisites required prior to fuel load were met

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verified that communications were established and maintained between the Control Room and the refueling are .7 QA/QC Interface with the Startup Test Program The inspector reviewed the Northeast Utilities Quality Assurance Program Topical Report and administrative control procedure ACP-QA-9.07, Quality Assurance Surveillance Program. Discussions were held with the site QA Supervisor, the Assistant QC Supervisor, the Construction QA (CQA) Supervisor, and the CQA Lead Auditor to determine QA/QC involvement with the Startup Test Progra The site QA organization will assign QC inspectors to perform sur-veillance on certain startup tests. These inspectors will have the responsibility for assuring that they witness these preidentified tests. Approximately 6 NNEC0 QC inspectors, 30 contractor QC inspec-tors will be used to follow the startup test progra ..

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Construction QA (CQA) will also be performing surveillance of pre-identified startup tests. These will be more formal than the site's QA effort. A minimum of six QA auditors will be following this program. In addition, the Berlin Headquarters audit group will audit some of the startup activitie Overall QA/QC effort and staffing during Starup testing at MP-3 seems more than adequate without sacrificing quality assurance at the other unit .8 Findings No violations or deficiencies were identified. However, due to the

. fact that several test procedures are still being drafted and that many procedures are still in the final review and approval process, it was not possible to completely verify that the test program is consistent with FSAR and Regulatory Guide commitment This item will remain unresolved (423/85-57-01) pending licensee action to approve and issue all startup test procedures and sub-sequent NRC revie .0 Unresolved Items Unresolved items are matters about which more-information is required in

, order to ascertain whether they are acceptable, deviation or violation An unresolved item is discussed in Paragraph .0 Management Meeting Licensee management was informed of the scope and purpose of the

. inspection at an entrance meeting conducted on November 12, 1985. The findings of the inspection were discussed with licensee representatives during the course of the inspection. Two mini exit meetings were con-ducted with licensee management: the first on November 15, 1985, and the second on November 22, 1985. A final exit meeting was conducted on November 27, 1985, at the conclusion of the inspection (see paragraph 1 for attendees) at which time the findings were presented to licensee managemen At no time during this inspection was written material provided to the licensee. Based on the NRC Region I review of this report and discussions held with the licensee representatives at the exit, it was determined that this report does not contain information subject to 10 CFR 2.790 restric-tion __ _ _ _ _ ._. - _ _ - - _ _ _ _ - --

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