ML20134D319

Insp Rept 50-440/85-42 on 850622-0802.Violations Noted: Failure to Provide Adequate Preoperational Test Procedures & Administrative Controls for Temporary Alterations

ML20134D319
Person / Time
Site:	Perry
Issue date:	08/13/1985
From:	Dave Hills, Lanksbury R, Oduyer G, Odwyer G, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134D285	List: IR 05000440/1985042 IR 05000622/2008002 ML20134D282
References
50-440-85-42, NUDOCS 8508190184
Download: ML20134D319 (18)

See also: IR 05000622/2008002

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85042(DRS)

Docket No. 50-440 License No. CPPR-148

Licensee: Cleveland Electric Illuminating Company

Post Office Box 5000

Cleveland, OH 44101

Facility Name: Perry Nuclear Power Plant, Unit 1

Inspection At: Perry Site, Perry, Ohio

Inspection Conducted: June 22 through August 2, 1985

Inspectors: 3MI[

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Test Programs Section Dat'e

Inspection Summary

-Inspection on June 22 through August 2, 1985 (Report No. 50-440/85042(DRS))

Areas Inspected: Routine, unannounced inspection of previous inspection

findings, preoperational test procedure verification, preoperational test

procedure review, preoperational test witnessing, preoperational test results

verification, preoperational test results review, overall preoperational

test program review and preoperational test program implementation. The

inspection involved a total of 146 inspector-hours onsite by 3 inspectors

including 20 inspector-hours during off-shifts. In addition, there were

121 inspector-hours spent offsite.

Results: .0f the eight areas inspected, no violations or deviations were

identified in six areas. Within the remaining two areas, three violations

were identified (Paragraphs 4.a, 4.b, and 4.f - failure to provide adequate

preoperational test procedures; Paragraph 9.a - failure to provide adequate

administrative controls for temporary alterations; Paragraph 9.b - failure

to provide adequate administrative controls for jurisdictional tagging).

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DETAILS

1. Persons Contacted

• M. D. Lyster, Manager, Perry Plant Operations Department

• F. R. Stead, Manager, Nuclear Engineering Department

• C. M. Shuster, Manager, Nuclear Quality Assurance Department

• G. R. Leidich, General Supervising Engineer, Nuclear Test Section

• G. H. Gerber, Element Supervisor, Administration, Nuclear Test Section

• R. J. Tadych, General Supervising Engineer, Operations

• D. J. Takacs, General Supervising Engineer, Maintenance

• B. D. Walrath, General Supervising Engineer, Operations Quality Section

• P. A. Russ, Compliance Engineer, Perry plant Technical Department

• B. S. Ferrell, Licensing Engineer, Nuclear Engineering Department

• M. W. Gmyrek, Senior Operations Coordinator, Perry Plant Operations

Department

• K. E. Turosky, Associate Staff Analyst, Perry Plant Technical

Department

The inspector also interviewed other licensee employees including members

of the quality assurance, technical, operating, and testing staff.

• Denotes persons attending the exit meeting of July 31, 1985.

2. Licensee Action on Previous Inspection Items

(Closed) Open Item (440/85017-03(DRS)): Final Safety Analysis Report

(FSAR) discrepancies identified during the review of TP IE22-P001, "High

Pressure Core Spray (HPCS)." The relief valve described in FSAR

Section 6.3.2.2.1 as being located between the two isolation valves of

the test line to the condensate storage tank has been replaced by a

bypass line and check valve. The inspector verified that a FSAR Change

Request has been initiated to correct the discrepancy. In regards to

HPCS injection valve IE22-F004 opening time prescribed in FSAR

Section 6.3.2.2.1 as 12 seconds following receipt of a signal to open,

the actual design requirement is an opening time of 27 seconds following

the initiation of a Loss of Coolant Accident (LOCA) signal. The

inspector verified that this design requirement had been properly tested

in the preoperational test and that an FSAR Change Request has been

initiated to correct the discrepancy. The inspector has no further

concerns in this area.

(Closed) Noncompliance (440/85013-09(DRS)): Alarm Response Instructions

(ARI) for the preoperational test program not being generated and made

available to control room operators. The inspector verified that Test

Program Instruction (TPI)-6 has been revised to ensure consistent

implementation with regards to ARIs. This prescribes initiation,

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revision, and' implementation of ARIs.to be in accordance with Perry

Plant Operations Department Procedure OAP-0506. The inspector has

no further concerns in this area.

.(Closed) Open Item (440/85017-02(DRS)): Responses to Field Questions

046362 and 046363 to be reviewed. The inspector reviewed the identified

documents and found them satisfactory. The inspector has no further

concerns in this area.

(Closed) Open Item (440/85029-02(DRS)): Test addendum to be provided to

add clarifications to TP-IE21-P001, " Low Pressure Core Spray," test

results package. _The inspector reviewed Test Addendum No. 1 and verified

that the-identified clarifications had been addressed. The inspector has

no further concerns in this area.

(Closed) Open Item (440/85017-11(DRS)): Licensee management to provide

uniform guidance on the implementation'of test exceptions and work

authorizations. The inspector verified that procedural requirements

for test exceptions and work authorizations have been identified to

applicable personnel in the. training program. The inspector has no

further concerns in this area.

.(Closed) Open Item (440/85017-04(DRS)): Licensee management to stress to

personnel the importance of keeping the System Test Engineer completely

cognizant of activities affecting systems under Nuclear Test Section

control. The inspector verified that this item has been stressed to

applicable personnel through the training program. The inspector has

no further concerns in this area.

(0 pen) Noncompliance'(440/85013-01(DRS)): Failure to provide adequate

preoperational test procedures. The inspector verified that additional

examples of this violation, pertaining to TP IE12-P001, " Residual Heat

Removal System," Revision 1, as identified in Inspection Report

50-440/85017, have been corrected by incorporation of Test Change

Notices 55 and 57 into the test procedure. Additionally, the inspector

verified that other examples of this violation pertaining to TP IB33-P002,

" Recirculation Flow Control Valves," Revision 1, that were -identified

in the same report have been corrected in Addendum 1 to that procedure.

However, further examples of this violation have been identified in-

Paragraph 4.h of this report for TP IC41A-P001, " Standby Liquid Control

System," Revision 0. As a result of concerns over inadequate

preoperational test procedures, the licensee formed a Management

Procedure Review Team (MPRT) to determine the extent of the problem and

to present recommendations for corrective actions. In implementing the

MPRT recommendations, the licensee-has developed Special Project

Plan 1102, " Test Procedure Assurance Review." The intent of this plan

. is to ensure preoperational test procedure adequacy by providing an

additional review of all preoperational and selected acceptance test

procedures, reinforcement of attention to detail to ensure technical

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adequacy of the test procedures, increased supervisory involvement

during the evolution and conduct of test procedures and revisions,

-additional training for test personnel, a re-review of licensing

commitments, a periodic status of progress, and a final summary of

these efforts. The effectiveness of these activities will be further

evaluated and tracked by this inspection item. The item remains open

pending complete implementation of the above actions and inspector

review of their effectiveness.

(Closed) Open Item (440/85002-05(DRS)): Test personnel appear to

rely on General Electric or Gilbert Associates Incorporated test

specifications without being totally cognizant of design and testing

requirements contained in licensing documents. This item is being

addressed by the licensee's Special Project Plan 1102, " Test Procedure

Assurance Review," and thus will continue to be tracked by previous

inspection item 440/85013-01(DRS).

(Closed) Open Item (440/84-11-11(DRS); 441/84-11-11(DRS)): Complete

review of preventative maintenance controls during testing. The

inspector reviewed this area as described in Paragraph 8 of this report.

(0 pen) Unresolved Item (440/85002-02(DRS)): Consideration of instrument

inaccuracies in determination of preoperational test procedure acceptance

criteria. The licensee has develeped a Special Project Plan,

" Coordination of Setpoints and Interrelated Documents," which is to

address this item in addition to several related issues as described

in Paragraph 4.a of this report. Expected completion of this project

with a written final report is August 26, 1985.

(Closed) Open Item (441/84-11-15(DRS)): Review licensee's response to

how their program will minimize problems identified in preoperational

testing at other facilities. The licensee has provided a written

response which the inspector has reviewed and determined to be adequate.

(Closed) Unresolved Item (440/85013-06(DRS)): Resolve inspector

coments/ concerns for preoperational test procedure TP 1C41A-P001,

Revision 0, " Standby Liquid Control System." This item has been upgraded

to an example of a violation as described in Paragraph 4.h of this report

and will be included with the other examples of inadequate procedures

identified under violation 440/85013-01(DRS). Therefore, this item

'is considered closed.

(Closed) Open Item (440/84-22-02(DRS)): Licensee to submit and have

approved all required FSAR test abstracts. As noted in Paragraph 2.c of

Inspection Report 50-440/85017(DRS), the inspector had an open issue with

the Office of Nuclear Reactor Regulation (NRR) regarding which test

abstracts are required to be included in FSAR Section 14. A response

from NRR has been received and it appears no additional action by the

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licensee is required at this time. If additional or modified test

abstracts are later found to be necessary NRR will deal directly with

the licensee. This item is therefore considered closed.

(Closed) Open Item (440/85013-03(DRS)): Licensee to change the FSAR to

upgrade their commitment from ANSI N510-1975 to ANSI N510-1980. The

inspector reviewed FSAR Change. Request No. 493 and verified that the

licensee was taking appropriate action to resolve this concern and had

approved this change. The inspector has no further concerns in this

area.

3. Preoperational Test Procedure Verification

The inspector verified that the following preoperational test procedures

were prepared, reviewed, and approved in accordance with the requirements

of Regulatory Guide 1.68, the Test Program Manual (TPM),.the FSAR, the

Safety Evaluation Report (SER) and the Quality Assurance (QA) Program

and found them satisfactory except as noted below:

TP OG41-P001, " Fuel Pool Cooling and Cleanup System," Revision 2

.TP OM23/24-P001, "MCC Switchgear and Miscellaneous Electrical Equipment

Areas HVAC System and Battery Room Exhaust System,"

Revision 2 _

TP OP41-P001, " Cooling Tower Makeup Isolation System," Revision 0

TP OP47-P001, " Control Complex Chilled Water System," Revision 0

TP OP49-P001, " Emergency Service Water Screen Wash System," Revision 2

TP 1C61-P001, " Remote Shutdown System," Revision l'

TP 1F42-P001, " Fuel Transfer Equipment," Revision.1

TP 1M32-P001, "Emergeacy Service Water Pumphouse Ventilation System,"

Revision 1

TP 1M36-P001, "Off Gas Building Exhaust System," Revision 1

TP 1M43-P001, " Diesel. Generator Building Ventilation System," Revision 2

TP 1P42-P001, " Emergency Closed Cooling System," Revision 2

TP 1R23-P001, "480 Volt Load Centers," Revision 0

TP 1R42-P001, " Class 1E Bus Independence and Division 1 and 2, DC

Power System," Revision 0-

TP 2R25-P001, "120 VAC Class 1E Instrument and Miscellaneous Distribution

Panels," Revision 0

-TP 2R42-P002, " Class 1E DC Power Systems Division 3," Revision 0

TP 0G60-A001, " Miscellaneous Sump System, Service Water Valve Pit,"

Revision 0

TP OP41-A001, " Service Water System," Revision 1

TP 1C85-A002, " Steam Bypass and Pressu"e Regulator HPU," Revision 0

TP 1N21-A001, " Condensate System," Revision 0

TP 1N33-A001, " Steam Seal System," Revision 0

TP.1N62-A001, " Condenser Air Removal," Revision 0

TP 1N71-A001, " Circulating Water System," Revision 0

TP IP44-A001, " Turbine Building Closed Cooling System," Revision 2

TP 1P52-A001, " Instrument Air System," Revision 1

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TP 1R52-A001, " Maintenance and Calibration Communications System,"

Revision 0

TP-1N23-A001, " Condensate Filtration System,". Revision 1

TP 2R42-A001, "Non-Class 1E. Power Systems," Revision 0

TP'2R11-A002,:"LH-2-B Interbus Transformer Energization," Revision 0

_TP 1P48-A001,." Service Water Chlorination System," Revision 2

TP 2R11-A001, "LH-2-A Interbus Transformer Energization," Revision 0

TP 1P33-A001, " Turbine Plant Sampling," Revision 0

TP 2S11-A001, "Startup Transformer Energization," Revision 1

TP 2R11-A003, "LH-2-C Interbus Transformer Energization," Revision 1

-TP 1P12-A001, " Condensate Seal Water System," Revision 0

TP 1P11-A001, " Condensate Transfer and Storage System," Revision 2

TP 1P51-A001, " Service Air System," Revision 1

TP 1N35-A001, " Hydrogen Supply System," Revision 0

TP 1N34-A001, " Lube Oil Purification," Revision 0

-TP 2P52-A001, " Instrument Air System," Revision 0

TP 1N24-A001, " Condensate Demineralizer System," Revision 1

TP 1M49-A001, "HVAC Smoke Venting," Revision 1

TP-1M47-A001, " Steam Tunnel Cooling," Revision 1

'TP 1R11-A002, "LH-1-B Interbus Transformer Energization," Revision 1

TP 1M45-A001, " Circulating Water Pump House Ventilation System,"

Revision 1

TP 1M42-A001, " Turbine Power Complex Ventilation," Revision 2

TP 1M41-A001, " Heater Bay Ventilation," Revision 1

TP 1M35-A001, " Turbine Building Ventilation," Revision 2

TP OP84-A002, "Hypochlorite Generation Cooling Tower Feed and Plant

Discharge Dechlorination System," Revision 0

'TP OP34-A001, " Nuclear Sampling System," Revision 0

TP 1P83-A001, " Cooling Tower Acid Addition System," Revision 0

TP OP55-A001, " Building Heating System," Revision 1

TP OP22-A001, " Mixed Bed Demineralizer and Distribution," Revision 0

TP 1R14-A001, "120 VAC Vital-Inverter and Distribution Equipment,"

-Revision 0 ,

TP OP20-A001, " Makeup Water Pretreatment," Revision 0

TP OM48-A001, "Radwaste Control Room HVAC System," Revision 1

TP 1P86-A001, " Nitrogen Supply System," Revision 0 .

TP OM46-A001, " Miscellaneous HVAC Systems," Revision 0

TP OM31-A001, "Radwaste Building Ventilation," Revision 2

TP 1M33-A001, " Intermediate Building Ventilation, " Revision 1

TP 1S11-A001, "Startup Transformer Energization," Revision 1

TP 1R55-A001, " Permanent Plant Telephone System DC Equipment,"

Revision 0

TP 1R42-A001, "Non-Class 1E DC Power Systems," Revision 0

TP OP64-A001, " Plant Industrial Wastes System," Revision 0 '

-TP IL51-A001, " Turbine Room and Circulating Water Pumphouse Overhead

Cranes," Revision 2

TP OP21-A001, "Two-Bed Demineralizer and Distribution System,"

Revision 1 l

TP 1R11-A003, "LH-1-C Interbus Transformer Energization," Revision 1

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TP 1R11-A001, "LH-1-A Interbus Transformer Energization," Revision 0

TP OP65-A001, " Auxiliary Boiler Chemical Treatment System," Revision 1

TP OP62-A001, " Auxiliary Boiler Fuel Oil System," Revision 0

TP OP40-A001, " Service Water Screen Wash," Revision 1

TP OM37-A001, " Water Treatment Building Ventilation," Revision 0

TP OL51-A003, " Service Water Pumphouse Overhead Crane," Revision 0

No violations or deviations were identified.

4. Preoperational Test Procedure Review

The inspector reviewed the following approved test procedures against .

the FSAR, the SER, Regulatory Guide 1.68, QA Manual, Test Program Manual,

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applicable Regulatory Guides and American National Standards Institute

(ANSI) Standards and docketed correspondence and found them satisfactory

except as noted below:

a. TP 1C71-P001, " Reactor Protection System," Revision 1. During this

review, the inspector noted that the test procedure was not

consistent pertaining to the acceptance criteria for Turbine Control

Valve Fast Closure Trip Setpoint. Acceptance criteria 7.6

prescribed a setpoint and tolerance of 530t15 psig while the test

step 6.7.1 indicated 530130 psig. The licensee indicated that

530t30 psig was the appropriate setpoint and tolerance and therefore

acceptance criteria 7.6 tolerance was incorrect. In addition, the

inspector noted that in step 6.7.1.1, the Turbine First Stage

Pressure Low Power Setpoint was prescribed as 178.2 psig while in

step 6.16.2.2 it was given as 232 psig. The licensee indicated that

178.2 psig was the appropriate setpoint and therefore step 6.16.2.2

was incorrect. Also, in step 6.15.1, data sheet 4 prescribed the

removal of various fuses to initiate annunciators. However, the

test procedure did not provide for restorational replacement of

these fuses as required by Test Program Instruction (TPI)-18,

" Temporary Alterations," and TPI-7, "Preoperational Acceptance

and Special Test Procedure Preparation Review and Approval." These

items are considered an example of a violation in conjucntion with

the examples described in Paragraph 4.b and 4.f in that this

procedure was inconsistent with administrative requirements and

applicable design values (440/85042-01a(DRS)).

In addition, the inspector noted that the procedure prescribes

reactor protection system response time testing to be accomplished

during the preoperational test in accordance with Initial Checkout

and Run-in (IC&R) test procedures. The licensee indicated that

these IC&R procedures had not yet been written and approved by the

Test Program Review Committee (TPRC) but would be provided for NRC

review upon TPRC approval. This is to remain an open item until the

licensee has provided these TPRC approved procedures and they have

been reviewed by the inspector (440/85042-02(DRS)).

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The inspector also noted that acceptance criteria 7.1 prescribes

a Reactor Vessel. Steam Dome Pressure High trip setpoint as

1064.7 15 psig while Perry " Proof and Review" Technical

Specification Table 2.2.1-1 gives a trip setpoint of _1064.7 psig

and allowable value of 1079.7 psig. Therefore, the test procedure

tolerance allows the trip setpoint to be as high as the technical

specification allowable value. This same problem was also

identified in respect to the Automatic Depressurization System

timer as described in Paragraph 4.e of this report.

These tolerances appear to be inconsistent with the proposed Perry

specific setpoint methodology which has not yet received approval

of NRR. This specific methodology involves establishment of a

" leave-as-is" zone based on setpoints that are determined from the

General Electric setpoint methodology. Under this plan, the

instrument would not have to be recalibrated until calibration

checks have revealed that it has drifted out of this " leave-as-is"

zone. The " leave-as-is" zone is to be established in such a manner

as to ensure compliance with Regulatory Guide 1.105, " Instrument

Setpoints," Revision 1, which states that "setpoints be established.

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a with sufficient margin between the technical specification limits

for the process variable and the nominal trip setpoints to allow for

-(a) the inaccuranc of the instrument, (b) uncertainties in the

calibration, and (y)c the instrument drift that could occur during

the' interval between calibrations." The examples of test procedure

setpoint tolerances given above signify the establishment of this

" leave-as-is" zone as up to and including the technical

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specification allowable value. This clearly conflicts with the

proposed Perry specific setpoint methodology. It appears that there

has been little consistency or direction provided for the establishment

of " leave-as-is" zones. Therefore, if this methodology does receive

NRR approval, the possibility exists that extensive effort may be

needed to ensure that " leave-as-is" zones have been established

correctly and that instruments are recalibrated when discrepancies

such as these are discovered. This is considered to be an

unresolved item (440/85042-03(DRS)). In order to address this and

other related concerns, the licensee has developed Special Project

Plan, " Coordination of Setpoints and Interrelated Documents." This

plan establishes a review team to investigate various problem areas

such as test acceptance criteria versus instrument inaccuracies, the

" leave-as-is" zone, consistent setpoint terminology and definitions,

and dynamic interfaces between setpoint design documents. The

special project plan is expected to be complete by August 26, 1985,

with the issuance of a final report to describe the various problems

identified in detail, prescribe an action plan for resolution of

any identified problems, and identify the responsible organizations

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b. TP 1C71-P002, " Reactor Protection System (RPS) Motor Generator

Sets," Revision 0. FSAR Section 8.3.1.1.5.4 indicates that

" provision is made to prevent connection of both RPS buses to the

alternate source at the same time." This design feature, consisting

of the K2A and K2B relays and corresponding contacts, is to ensure

that both RPS buses are not simultaneously supplied from the

alternate power source so that these buses are not vulnerable no

single failure. The inspector noted that this particular interlock

was not tested in the preoperational test procedure. This iten is

' considered an example of a violation in conjunction with the

examples described in Paragraphs 4.a and 4.f in that this procedure

did not adequately test system design features (440/85042-01b()RS)).

c. TP 1N278-P001, "Feedwater Leakage Control System," Revision 1.

d. TP 1G43-P001, " Suppression Pool Makeup System," Revision 2.

e. TP 18218-P001, " Automatic Depressurization System (ADS / Safety

Relief Valves (SRV)," Revision 1. The inspector noted that

acceptance criteria 7.1.1 and 7.1.3 prescribes the ADS Timer

setpoint as 10512 seconds while Perry " Proof and Review" Technical

Specification Table 3.3.3-2 gives a setpoint value of _105 seconds

and an allowable value of 117 seconds. Therefore, the test procedure

tolerance allows the setpoint to be as high as the technical

specification allowable value. This tolerance appears to be

inconsistent with the proposed Perry plant specific setpoint

methodology utilizing a " leave-as-is" zone as described previously

in Paragraph 4.a of this report and thus is considered part of

the same unresolved item (440/85042-03(DRS)).

f. TP 1M51-P001, " Combustible Gas Control System (CGCS)," Revision 0. ,

The inspector noted that permanent plant instrumentation used to

provide acceptance criteria data in the test procedure were not

designated with the symbol "(AC)" on the Instrument Suninary Sheet.

Examples of the numerous discrepancies identified include the sample

flow indicators, sample inlet pressure indicators, and sample

temperature indicators on hydrogen analyzer panels 1H51-P022A and

1H51-P022B, used to provide data for acceptance criteria 7.1.a and

7.1.b, and the air flow meter on panel 1H51-P174A, used to provide

data for acceptance criterion 7.3.a.1. TPI-7, "Preoperational,

Acceptance, and Special Test Procedure Review and Approval,"

Section 4.1.2.2 and Attachment 6.5 prescribe the use of the

Instrument Summary Sheet. Instructions on the Instrument Suninary

Sheet require that the symbol "(AC)" be inserted for all instruments

involved with verifying acceptance criteria. This symbol indicates

those instruments requiring signature /date verifications to ensure

that they have been calibrated within six months of the start of the

test and to ensure that they receive post-test calibration

verification. This is considered an example of a violation in

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conjunction with the examples described in Paragraphs 4.a and

4.b in that this procedure was inconsistent with administrative

requirements (440/85042-01c(DRS)).

In addition, the inspector expressed concern pertaining to CGCS

compressor flow rate acceptance criteria as it relates to system

design requirements. Present test procedure acceptance criteria

prescribes 500150 standard cubic feet per minute (scfm) CGCS

compressor capacity under an equalized atmospheric pressure

condition between the drywell containment areas and 600160 scfm

capacity under equalized but higher pressure conditions during the

Containment Integrated Leak Rate Test (ILRT). The licensee has

now indicated that they intend to change the acceptance criteria

at atmospheric pressure conditions to a minimum of 500 scfm and to

include calculations to normalize test data to the design

temperature of 60 F for comparison to the acceptance criteria.

In addition, the licensee intends to delete the testing done under

containment ILRT conditions and to instead perform testing as an

Initial Checkout end Run-in (IC&R) test at a containment pressure

of 22.1 psia during depressurization following completion of the

ILRT. This pressure is the postulated containment pressure at which

the compressors are started approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after a Loss of

Coolant Accident to ensure that hydrogen concentrations do not

exceed the 4.0 percent limits of Regulatory Guide 1.7. The

inspector advised the licensee that the plan to do the higher

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pressure test as an IC&R test instead of a preoperational test may

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not be consistent with the intent of Regulatory Guide-1.68s

Section C.3, which states in regard to preoperational testing,

"to the extent practical, the plant conditions during the tests

should simulate the actual operating and emergency conditions to

which the structure, system, on component may be subjected." This

is an unresolved item until the inspector has reviewed the planned

procedure revision and determined its compliance with regulatory

requirements (440/85042-04(DRS)).

The inspector also noted that preoperational testing of the hydrogen

recombiners was not as extensive as that required by the 18 month

surveillance prescribed by Perry " Proof and Review" Technical

Specification Section 4.6.7. The surveillance requires that the

recombiner sheath temperature must attain between 1225 F and 1450 F

within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and maintain temperature within that range for an

additional 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The preoperational test procedure, however,

just verifies that the sheath temperature will stabilize at

1225110 F with no specified time periods. The licensee has

indicated that the test procedure will be revised to make it

consistent with the technical specification surveillance

requirements. This is to remain an open item until the inspector

- has reviewed the procedure revision to ensure compatibility with

the technical specification surveillance (440/85042-05(DRS)).

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g. TP IC418-P001, "St'andby Liquid Control Transfer," Revision 0.

h. TP.1C41A-P001, " Standby Liquid Control System," Revision 0. As

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indicated in Inspection Report 50-440/85013(DRS) (unresolved item

,440/85013-06(DRS)) the inspector had a number of comments / concerns

y for this preoperational test procedure that required additional

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inspection effort in order to determine if they were violations.

.This inspection effort is now complete and unresolved item

440/85013-06 has been upgraded to an example of a violation and

is included with the other examples 'of inadequate test procedures

, identified under violation 440/85013-01(DRS). The following is

a list of the examples.of violation identified in TP 1C41A-P001.

The test methodology for verifying the systems restricting

orifice flow was inadequate because it did not take into

consideration the elevation difference between the location

where the static test measurements were performed and the

lower level where the orifice flow entered the system

primary flow path (pump suction). In addition, consideration

of the dynamic effects in place when the system is running

were not included. General Electric (GE) and onsite review

of this concern,resulted in a new acceptance criterion being

generated that took~the above items into consideration.

Further review indicated that sufficient data was taken

during the conduct of'the test (wnich occurred prior to

resolution.of this concern) to allow it to be used to

demonstrate this portion ~of system operation through

additional calculations and without any retesting being

required.

• The test methodology used initially to demonstrate that the

Standby Liquid Control-(SLC) system storage tank air sparger

would perform as' designed was inadequate in that it did not

demonstrate that it was capable of mixing the boron solution

after the^ maximum time allowed between Technical Specification

(TS) surveillances'(*38 days). In addition, it-did not

determine how much sparging time is required to ensure that

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the samples taken for the TS surveillances are representative

of the tank contents. The above must be demonstrated since

the boron solution will stratify-out over time with a higher -

concentration layer near the bottom and a lower concentration

layer near the top (where the TS samples will be taken).

• 10 CFR 50.62 requires that the SLC system be designed to have

,

a minimum flow capacity and boron content equivalent in control

capacity to 86 gpm of 13 weight percent sodium pentaborate

solution. This equivalent control capacity is for a

251 inch-diameter reactor vessel. Since Perry has a smaller

size reactor vessel, a different (lower) flow would provide

11

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equivalent control. A GE analysis in response to this concern

resulted in GE.providing the site with an equation whereby

compliance with the equivalency requirement can be shown by

substituting plant-specific parameters. The original test

procedure failed to include consideration of this design

requirement. Subsequent review by the licensee has determined

that sufficient data had been collected during the original

testing.to allow demonstration of the required control

equivalency through the use of the above noted GE equation.

No additional violations or deviations .were identified. However,

2 open and 2 unresolved items requiring further evaluation as

described in the preceding paragraphs were identified in the review

of this program area.

5. Preoperational Test Witnessing

-The inspector witnessed the following preoperational test to ascertain

through. observation and review of documentation that testing was conducted

.in accordance with approved procedures and that test results appeared to

be acceptable or proper corrective actions were taken. Additionally, the

performance of licensee personnel was evaluated during the test. These

were_found to be satisfactory.

_

SP_1E61-001, " Local Leak Rate Test," Revision 0.

The inspector witnessed step 6.5 which consisted of testing per

Surveillance Instruction SVI-821-T9122, " Type C Local Leak Rate

Test of B21 Penetration P122," Revision 0, to determine the local

leakage rate from Main Steam Line C. This testing determined that

'the combined leakage from Inboard Main Steam Isolation Valve (MSIV)

1B21-F022C, Outboard MSIV 1821-F028C, Outboard Before Seat Drain

Valve 1821-F067C, MSIV Leakage Control System (LCS)-Inlet Valve

1E32-F001J, and MSIV LCS Drain Valves 1E32-F02J and IE32-F026J

was' within acceptance limits.

No violations or deviations were identified.

j -6. Preoperational Test Results Verification

The inspector verified that the following preoperational test results

were documented, reviewed and approved by the licensee in accordance

with the requirements of Regulatory Guide 1.68, the TPM, the FSAR, the

'

.SER, and the QA Program and found them satisfactory.

TP OG41-P001, " Fuel Pool Cooling and Cleanup System," Revision 2

TP OM23/24-P001, "MCC Switchgear and Miscellaneous Electrical Equipment

Areas HVAC System and Battery Room' Exhaust System,"

Revision 2

TP OP41-P001, " Cooling Tower Makeup -Isolation System," Revision 0

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.

TP OP47-P001, " Control Complex Chilled Water System," Revision 0 )

TP OP49-P001, " Emergency Service Water Screen Wash System," Revision 2

TP 1C61-P001, " Remote Shutdown System," Revision 1

TP 1F42-P001, " Fuel Transfer Equipment," Revision 1

-TP 1M32-P001, " Emergency Service Water Pumphouse Ventilation System,"

Revision 1

TP 1M36-P001, "Off Gas Building Exhaust System," Revision 1

TP 1M43-P001, " Diesel Generator Building Ventilation System," Revision 2

TP IP42-P001, " Emergency Closed Cooling System," Revision 2

TP 1R23-P001, "480 Volt Load Centers," Revision 0

TP 1R42-P001, " Class 1E Bus Independence and Division 1 and 2, DC

Power Tystem," Revision 0

TP 2R25-P001, "120 VAC Class lf Instrument and Miscellaneous Distribution

Panels," Pe :sion 0

TP 2R42-P002, " Class IE DC Pc,ier Systems Division 3," Revision 0

TP OG60-A001, " Miscellaneous Sump System, Service Water Valve Pit,"

Revision 0

TP OP41-A001, " Service Water System," Revision 1

TP 1C85-A002, " Steam Bypass and Pressure Regulator HPU," Revision 0 -

TP 1N21-A001, " Condensate System," Revision 0

TP 1N33-A001, " Steam Seal System," Revision 0

TP 1N62-A001, " Condenser Air Removal," Revision 0

TP 1N71-A001, " Circulating Water System," Revision 0

TP IP44-A001, " Turbine Building Closed Cooling System," Revision 2

TP IP52-A001, " Instrument Air System," Revision 1

TP 1R52-A001, " Maintenance and Calibration Communications System,"

Revision 0

TP 1N23-A001, " Condensate Filtration System," Rcvision 1

TP 2R42-A001, "Non-Class 1E Power Systems," Revision 0

TP 2R11-A002, "LH-2-B Interbus Transformer Energization," Revision 0

TP 1P48-A001, " Service Water Chlorination System," Revision 2

TP 2R11-A001, "LH-2-A Interbus Transformer Energization," Revision 0

TP 1P33-A001, " Turbine Plant Sampling," Revision 0

TP 2S11-A001, "Startup Transformer Energization," Revision 1

TP 2R11-A003, "LH-2-C Interbus Transformer Energization," Revision 1

TP 1P12-A001, " Condensate Seal Water System," Revision 0

TP 1P11-A001, " Condensate Transfer and Storage System," Revision 2

TP 1P51-A001, " Service Air System," Revision 1

TP 1N35-A001, " Hydrogen Supply System," Revision 0 1

TP 1N34-A001, " Lube Oil Purification," Revision 0

TP 2P52-A001, " Instrument Air System," Revision 0 >

TP 1N24-A001, " Condensate Demineralizer System," Revision 1

TP 1M49-A001, "HVAC Smoke Venting," Revision 1

TP 1M47-A001, " Steam Tunnel Cooling," Revision 1

TP 1R11-A002, "LH-1-B Interbus Transformer Energization," Revision 1

TP 1M45-A001, " Circulating Water Pump House Ventilation System,"

Revision 1

TP 1M42-A001, " Turbine Power Complex Ventilation," Revision 2

TP 1M41-A001, " Heater Bay Ventilation," Revision 1

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TP 1M35-A001, " Turbine Building Ventilation," Revision 2

. TP OP84-A002, "Hypochlorite Generation Cooling Tower Feed and Plant

Discharge Dechlorination System," Revision 0

TP OP34-A001, " Nuclear. Sampling System," Revision 0

TP 1P83-A001, " Cooling Tower Acid Addition System," Revision 0

-TP OP55-A001, " Building Heating System," Revision 1

TP OP22-A001, " Mixed Bed Demineralizer and Distribution," Revision 0

-TP 1R14-A001, "120 VAC Vital-Inverter and Distribution Equipment,"

Revision 0

,

TP OP20-A001, " Makeup Water Pretreatment," Revision 0

TP OM48-A001, "Radwaste Control Room HVAC System," Revision 1

TP 1P86-A001, "Nitroge'n Supply System," Revision 0

TP OM46-A001, " Miscellaneous HVAC Systems," Revision 0

TP OM31-A001, "Radwaste Building Ventilation," Revision 2

TP 1M33-A001, " Intermediate Building Ventilation, " Revision 1

TP'1S11-A001, "Startup Transformer Energization," Revision 1

TP 1R55-A001, " Permanent Plant Telephone System DC Equipment,"

'

Revision 0

TP 1R42-A001, "Non-Class 1E DC Power Systems," Revision 0

,

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TP 0P64-A001, " Plant Industrial Wastes System," Revision 0

-TP IL51-A001, " Turbine Room and Circulating Water Pumphouse Overhead

Cranes," Revision 2

t

TP OP21-A001, "Two-Bed Demineralizer and Distribution System,"

, Revision 1.

TP 1R11-A003, "LH-1-C Interbus Transformer Energization," Revision 1

- TP 1R11-A001, "LH-1-A Interbus Transformer Energization," Revision 0

1

~ TP OP65-A001, " Auxiliary Boiler Chemical Treatment System," Revision 1

~

TP OP62-A001, " Auxiliary Boiler Fuel Oil System," Revision 0

'

TP OP40-A001, " Service Water Screen Wash," Revision 1

TP OM37-A001, " Water Treatment Building Ventilation," Revision 0 .

TP.OL51-A003, " Service Water Pumphouse Overhead Crane," Revision 0

v

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No violations or deviations were identified.

7. Preoperational Test Results Review

l

The inspector reviewed the results of the following tests against the

i FSAR, the SER, Regulatory Guide 1.68, the QA Manual, and the Test Program

Manual, and determined that-test changes and test exceptions were

processed in accordance with administrative controls, test deficiencies

were identified, processed, and corrected as required, results were

'

evaluated and met the acceptance criteria, and the results were reviewed

and approved as required.

4

TP 1C41B-P001, " Standby Liquid Control Transfer," Revision 0.

-No violations or deviations were identified.

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.

8. Overall Test Program Review

The inspector verified that controls for preventative maintenance and

equipment protection during and following preoperational testing have

been established including:

periodic surveillance as required

protection from environmental extremes

implementation of periodic maintenance and calibration programs

maintenance of cleanliness

The inspector also verified that administrative controls have been

established which require preparation and retention of maintenance

records. During this review, the inspector noted that administrative

controls for preventative maintenance were spread throughout several

governing documents contributing to confusion as to the applicable

controls and could be conducive to program implementation errors.

The inspector also noted that Perry Plant Department Interface 7-1301,

" Maintenance Program Coordination," had not been revised since August 8,

1983, and thus contained references to procedures which no longer exist.

As a result of these concerns and also since Perry Plant Department

Interface 7-1301 was almost redundant with Perry Plant Department

Interface 7-1304, " Preventative Maintenance Program," the licensee

deleted the former after assuring that any remaining administrative

controls had been transferred to the other procedure. Furthermore,

the licensee revised Perry Plant Department Interface 7-1304 to reference

Test Program-12, " Work Authorizations," instead of the incorrect reference

to Project Administration 1107, " Work Authorization Process."

No violations or deviations were identified.

9. Preoperational Test Program Implementation

a. The licensee's implementation of jurisdictional tagging was reviewed

during this inspection period. Test Program Instruction (TPI)-9,

Revision 1, Section 4.1.7, provides instruction on how the licensee's

jurisdictional tagging program is to be implemented for systems

undergoing preoperational testing. This section requires that: for

i

electrical equipment, blue jurisdictional tags or stickers be placed

on all electrical components and the associated control switches and

breakers; for mechanical equipment, the tags or stickers be placed on

all mechanical components such as valves, tanks, pumps, etc.; and

for instrument and control equipment, the tags will be placed on all

gauges, panels, readily accessible sensing devices, tubing racks,

etc. Because of the large amount of instrument and control

equipment in the Control Room, the licensee decided to designate

everything therein as under Nuclear Test Section (NTS) control and

to not individually mark each item. As each instrument or control

completed preoperational testing and was turned over to Operations,

15 l

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.

it was required to be tagged / marked by a green tag / sticker to

indicate this status in accordance with Perry Administrative

Procedure (PAP) 1401, " Equipment Tagging."

During the review of this area, the inspector found that the

Operations personnel had processed a change (Test Change Notice

No. 5) to PAP 1401, effective June <1, 1985, which deleted the

requirement for green tagging /stickering any systems / components

for Unit 1 or Unit 1/2 common required for Unit 1 operation. The

justification for this change was that all these systems / components

had been turned over from construction to NTS and therefore the

previous method of indicating that the system / component was under

construction jurisdiction (i.e., no tags / stickers) could now be

used by Operations and thereby minimize the amount of paper being

processed. The inspector noted that this was a reasonable course

of action on the part of the licensee except that NTS's method of

identifying jurisdiction in the Control Room had not changed.

Therefore, it was not possible to identify what instrument,

controls, electrical equipment, etc., were under NTS jurisdiction

and which were under Operations jurisdiction. This is considered

to be a violation of 10 CFR 50, Appendix B, Criterion XIV, in that

adequate measures to indicate the status of equipment within the

Control Room were not established and implemented (440/85042-06(DRS)).

b. The licensee's implementation of control of temporary electrical

alterations was also reviewed during this inspection period.

TPI-18, Revision 3, provided instructions of how their temporary

alteration program was to be implemented. Section 4.1.1 of TPI-18

stated that prior to release for preoperational or acceptance test,

it is not necessary that the System Test Engineer (STE) review and

approve the implementation and removal of temporary alterations.

Section 4.1.2 stated that at anytime after system turnover to NTS,

the STE may control the implementation and removal of temporary

alterations on a system under his jurisdiction by submitting a

memorandum to the Test Coordinator which informs him of the

effective date of that control. Section 4.1.4 stated that the

Test Coordinator shall approve implementation or removal of

temporary alterations without the review signature of the STE

after the effective date on the memorandum or after connencing

preoperational or acceptance testing, whichever occurs first.

The ' inspector's review of this revision of the program revealed the

following problem. The period of time between a system's release

for test authorization and the time that the test commences was not

addressed. The release for test package includes, among other

things, a walkdown of the system by the STE to verify that the system

is per design and a review for any temporary alterations. At this

point, baseline data as to the status of the system with respect to

temporary alterations is established by the STE. By not requiring

the STE to control temporary alterations from this point on renders

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the baseline data suspect since the commencing of actual testing may

be months after the release for test authorization. If a temporary

alteration is made during this time frame and is still in place when

testing is being performed, the results of that testing may not be

valid. Section 1.0 of TPI-18 allows temporary alterations to be

made and removed without following the requirements therein if it is

specifically required by an approved test procedure which contains

signature verifications for implementing and returning to normal.

The Test Coordinator is also required to be notified prior to the

alteration and upon its return to normal if the alteration affects

a system in operation. It is not clear that just contacting the

Test Coordinator instead of the affected STE will ensure that the

affected STE's testing is not invalidated by the alteration.

In either case, the potential for invalidating test results exists

and, depending on how the temporary alteration affects the system

operation, this may go undetected.

During the course of this inspection and prior to the inspector

identifying the above concerns, the licensee issued Revision 4 to

TPI-18. This change basically transferred control for

implementation of all new temporary alterations to PAP-1402,

" Control of Lifted Leads, Jumpers, Temporary Electrical Devices,

and Mechanical Foreign Items." Removal is still controlled by

TPI-18. TCN-005 to PAP-1402 was also issued to require the STE's

concurrence to any temporary alteration. This programmatic change

resolves the inspector's first concern with respect to any temporary

alterations processed under PAP-1402. However, the inspector still

has concerns with respect to the effect the old program may have had

on testing performed under it. In addition, with respect to the

second concern noted above, the new PAP-1402 procedure still has the

same exception to its requirements as existed in Section 1.0 of

TPI-18 except that it does not even require the Test Coordinator

be notified of the implementation or removal of any temporary

al terations.

The failure of the Perry test program to address the above noted

problem areas is considered to be a violation of 10 CFR 50,

Appendix B, Criterion XI, and Criterion XIV in that adequate

measures were not established to insure that the STE was aware of

the status of his system while it is undergoing testing and to

thoroughly ensure that the required testing demonstrated that the

structures, systems, and components will perform satisfactorily

-

inservice (440/85042-07(DRS)).

,

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10. . Unresolved Items

Unresolved items are matters about which information is required in order

to ascertain whether they are acceptable items, items of noncompliance,

or deviations. Unresolved items disclosed during the inspection are

discussed in Paragraphs 4.a, 4.e, and 4.f.

11. Open Items

Open items are matter which have been discussed with the licensee which

will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. Open items disclosed during

the inspection are discussed in Paragraphs 4.a and 4.f.

12. Exit Interview

The inspector met with licensee representatives denoted in Paragraph 1

on July 31, 1985. The inspector summarized the scope and findings of

the inspection and discussed the likely content of this inspection report.

The licensee did not indicate that any of the information disclosed

during the inspection could be considered proprietary in nature.

The licensee acknowledged the statements by the inspector with respect

to the violations in Paragraphs 4.a, 4.b, 4.f, 9.a, and 9.b.

18