B17354, Responds to NRC Re Violations Noted in Insp Rept 50-336/98-202.Corrective Actions:Test Plan for Pdcr 2-064-95 Was Revised to Incorporate Design Requirements.List of Commitments Included
| ML20236W901 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/03/1998 |
| From: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-336-98-202, B17354, NUDOCS 9808060288 | |
| Download: ML20236W901 (39) | |
Text
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Northeast ""P"'"Y"'("""'"*')**'"'""'"'*"
Nuclear Energy sulnone Nudear Pow sianon Northeast Nuclear Energy Company ]
P.O. Box 128 Wat< rfoni, Ur 0638.LO128 (860) 447-1791 l'as (860) 444-4277 The Northeast Utilitics System AUG -3 1998 i
Docket No. 50-336 l B17354 .j Re: 10 CFR 2.201 '
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station Unit No. 2 Reply to a Notice of Violation Safety System Functional Inspection Nuclear Reaulatorv Commission insoection Report 50-336/98-202 By letter dated June 11,1998 W, the Nuclear Regulatory Commission Special Projects Office transmitted the results of Inspection Report 50-336/98-202. The inspection was part of a broader Nuclear Regulatory Commission (NRC) activity directed at verifying
- the effectiveness of Northeast Nuclear Energy Company's (NNECO) Configuration Management Program. The letter included a Notice of Violation (NOV) citing eight areas where NNECO's activities were not in compliance with NRC regulations.
In a letter dated July 15,1998,* NNECO requested additional time (until August 3, 1998) to provide a reply to the Notice of Violation.
NNECO's activities to improve the quality of safety evaluations and configuration management are ongoing. NNECO's commitments associated with this submittal are contained in Attachment 1. Attachment 2 provides NNECO's response to the NOV items pursuant to the provisions of 10 CFR 2.201.
Il 98o806o288 9808o3 * //
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(" E. V. Imbro letter to M. L. Bowling, " NOTICE OF VIOLATION AND SAFETY SYSTEM FUNCTIONAL INSPECTION OF MILLSTONE UNIT 2 (NRC INSPECTION REPORT NO.
50-336/98-202)," dated June 11,1998. -
A M. L. bowling letter to the NRC, " REQUEST FOR ADDITIONAL TIME TO RESPOND TO A #
,, NOTICE OF VIOt.ATION," dated July 15,1998.
(E3422-3 REY.124
U.S. Nucirr R:gulatory Commission v M317354\P:g3 2 Should you have any. questions regarding the information contained herein, please contact Mr. Ravindra G. Joshi at (860) 440-2080.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Martin L. Bowling, Jr. if Recovery Officer - Technical Services Attachments (2) cc: H. J. Miller, Region i Administrator W. D. Lanning, Deputy Director, inspections, Special Projects Office D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 E. V. Imbro, Acting Director, Special Projects Office P. S. Koliay, Branch Chief, ICAVP Oversight, Special Projects Office J. P. Durr, Branch Chief, inspections, Special Projects Office
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1 Attachment 1 !
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Millstone Nuclear Power Station, Unit No. 2
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NNECO Commitments l
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I August 1998
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U.S. Nuclser R:gulatory Commission
- B17354\Attachm:nt 1\Page 1 List of Regulatory Commitments The following table identifies those actions committed to by NNECO in this document.
Please notify the Manager - Millstone Unit No. 2 Regulatory Compliance of any questions regarding this document or any associated regulatory commitments.
l Commitment Description Committed Date l Number or Outage B17354.01 The test plan for PDCR 2-064-95 was revised to Complete l incorporate the design requirements.
B17354.02 As of June 25,1998, 2-RB-13.1 A/B had both Complete been successfully retested in accordance with the
, test plan which demonstrated they met all design basis requirements.
B17354.03 A review of design change engineering release Complete transmittals in the MP2 control room was completed, and found no other cases where changes were made to test plans that left previously released portions not tested to new requirements.
B17354.04 A procedure will be developed requiring the Prior to Restart RBCCW system flow balance to be verified prior From RFO13 to startup after each refueling.
B17354.05 NNECO revised Maintenance Form MF 2701J-96 Complete specifically identifying the acceptance criterion for service water cooled heat exchanger fouling.
B17354.06 During this outage, NNECO will or has performed Prior to Entry into i testing on the diesel heat exchangers, and vital Mode 4 AC switchgear room cooler and vital DC l
switchgear room chiller heat exchangers.
B17354.07 NNECO currently plans to test the RBCCW heat RFO13 exchangers during the shutdown for RFO13.
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6817354\Attachm:nt 1\Pcge 2 Commitment Description Committed Date Number or Outage B17354.08 A test procedure (SPROC EN 98-2-04) will be Prior to Entry into developed to evaluate the planned pump Mode 4 swapping methodology, the system peak pressure response during swapping / check valve slamming, the ability of the new " soft-seat" relief valves to re-seat if they lift and to determine if an optimal flow range exists for performing pump swaps.
B17354.09 RBCCW 6fstem procedure references to system Prior to Entry into flowrates will be reviewed to ensure that they are Mode 4 consistent and compatible after performance testing utilizing SPROC EN 98-2-04.
l B17354.10 An FSAR Change Request (FSARCR) will be Prior to Entry into PORC approved to more accurately reflect the Mode 4 system operation and pump swapping will be PORC approved.
B17354.11 A license amendment request to revise Technical Complete Specification 3.8.1.1 to be consistent with General Design Criterion 17 was submitted to the NRC on July 17,1998.
B17354.12 The valve identification on Operations Critical Complete Drawing 25203-26017 sh. 2 was corrected by Design Change No4ce (DM2-00-0730-97).
B17354.13 FSAR Change Request (FSARCR) to update Prior to Entry into Table 9.4-2 (to change the valve identification Mode 4 number to 2-RB-402 will be PORC approved).
B17354.14 Electrical and l&C drawings associated with Valve Prior to Entry into 2-RB-402 will be identified and updated, as Mode 4 required.
B17354.15 Procedures associated with Valve 2-RB-402 will Prior to Entry into be identified and updated, as required. Mode 4 B17354.16 The tray covers will be installed to eliminate the Prior to Entry into separation deficiencies. Mode 4 i
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U.S. Nuclarr Regulatory Commission t317354\Att: chm:nt 1\Pcg3 3 Commitment Description Committed Date Number or Outage B17354.17 The applicable drawing to document the Prior to Entry into installation of the tray covers will be revised. Mode 4 B17354.18 MEPL MP2-CD-3675 was issued reclassifying PI- Complete 6324, PI-6325 and the associated tubing as Category 1.
B17354.19 Nonconformance Report (NCR) 2-98-0169 was Complete issued to review past work order history and purchasing history for PI-6324, PI-6325 and the associated tubing. The NCR was dispositioned as "use-as-is" for PI-6324 and PI-6325 as a result of these reviews. The NCR was closed on July 7, 1998.
l B17354.20 The Production Maintenance Management Complete l System (PMMS) database was updated to reflect i
the Category I classification.
l B17354.21 DCN DM2-00-0640-97 was supplemented to Prior to Entry into correct the errors and the piping drawing of Mode 4 concern will be updated.
B17354.22 Support drawing 25203-22200 SH. 491315E will Prior to Entry into be revised to reflect the as-built condition, and the Mode 4 loading calculation will be verified as acceptable for the as-built configuration.
l B17354.23 Design Change Notice DM2-00-0919-97 was Prior to Entry into updated to correct the piping support drawings, Mode 4 which will be updated prior to entry into Mode 4.
B17354.24 The orientation of the supports will be clarified in Prior to Entry into i
DCN DM2-08-0919-97. Mode 4 i B17354.25 Specification SP-ME-730 was clarified. Complete l Clarifications provided to SP-ME-730 require that l installations comply with all the requirements of l the specification (e. g., orientation, load capacity and attachment details).
U.S. Nuciscr Reguintory Commission
- B17354\Attrchment 1\Pcg3 4 l Commitment Description Committed Date Number or Outage B17354.26 Table 9.3-1 of the FSAR will be PORC approved. Prior to Entry into Mode 4 B17354.27 NNECO will identify RBCCW system design Prior to Entry into
! impacts on setpoint calculations. Mode 4 B17354.28 The setpoint calculation will be revised with Prior to Entry into j assurr%ons based on actual system design. Mode 4 B17354.29 A system design review has revealed other Prior to Entry into considerations impacting the setpoint calculation Mode 4 as discussed above. Procedures will be revised to l limit radiation monitor background and to provide adequate control of setpoint changes. An interim change has already been made to form SP2654K-1 for limiting background. Final procedure changes will be completed after the completion of a rs'tised calculation.
B17354.30 Other ehluent radiation monitor setpoints will be Prior to Entry into reviewed m ensure that there are no similar Mode 4 failures to implement design bases.
B17354.31 All affected departments will be required to review Prior to Entry into proposed revisions to requirements for effluent Mode 4 radiation monitor setpoints in the ODCM.
B17354.32 A procedure to effectively implement effluent Prior to Entry into radiation monitor setpoints in the ODCM will be Mode 4 established.
B17354.33 AOP 2564 (Loss Of RBCCW) and relevant Prior to Entry into RBCCW ARP window instructions will be Mode 4 modified, as necessary, to clarify actions and l ensure consistency between the documents.
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'B17354\ Attachment 1\Page 5 Commitment Description Committed Date Number or Outage B17354.34 Unit 2 AOPs and their applicable ARP window August 31,2000 steps and instructions will be reviewed prior to, or as part of each procedure's Biennial Review to correct actions and wording which are inconsistent. This corrective action will be completed as part of the Biennial Review l Process.
B17354.35 Millstone Unit No. 2 will review feedback from December 31, Operator training sessions with regard to 1998 consistency between ARPs and AOPs, and determine necessary procedure modifications B17354.36 The CDL group reestablished the P&lDs as Complete controlled documents (through the NDS Control Document Section) and verified / updated the P&lD stick file.
I B17354.37 The CDL was added to the controlled distribution Complete for these P&lDs.
B17354.38 The P&lD files in the other CDLs were audited to Complete verify current revision. No similar P&lD problems were identified in the other CDLs. However, several P&lDs were missing from a stick file in one CDL. This was corrected in accordance with CDL program.
B17354.39 The CDL group will review its program and September 30, procedures and provide more specific guidance 1998 regarding the storage of uncontrolled (or reference) documents in CDLs.
B17354.40 DCR M2-96068 SE Number S2-EV-97-0018, Rev. Prior to Entry into 1 will be revised to consider the effect of the Mode 4 ,
change relative to the acceptance limit in NRC l SER issued on May 10,1974. l I
l B17354.41 A license amendnent request will be processed in Prior to Entry into j l accordance v,ith 10 C! n. 50.90 for the change to Mode 4 the SER acceptance limit for electrical separation criteria in control boards and panels. ,
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- B17354\Attrchm:nt 1\Pcg3 6 Commitment Description Committed Date Number or Outage B17354.42 The procedure for performing safety evaluations Prior to Entry into l
i will be reviewed and revised, as required, to Mode 4 strengthen the guidance concerning plant l changes which affect NRC SERs.
B17354.43 A review of other DCRs which impact electrical Prior to Entry into separation will be performed for similar discrepant Mode 4 conditions.
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! Attachment 2 Millstone Nuclear Power Station, Unit No. 2 i l
l Response to Notice of Violation l l
Nuclear Regulatory Commission inspection Report 50-336/98-202 i
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U.S. Nucisar Regulatory Commission -
'B17354\Attachm:nt 2\Paga 1 1
J Nuclear Reaulatory Commission Violation "A" (50-336/98-202-01)
Restatement of the Violation 202-01. A.1 A. 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires that all testing required to demonstrate that structures, systems, and components will perform .
l satisfactorily in service is identified and performed in accordance with written test I
procedures which incorporate the requirements and acceptance limits contained in j applicable design documents.
l l Contrary to the above:
- 1. A post-modification test procedure did not incorporate the requirements contained in design documents. Test procedure SP 21206A, " Instrument Air Accumulator Chack Valve Test," Rev. 3, dated November 5,1997, tested the backup air accumulators l' for valves 2-RB-13.1A/B but did not incorporate the requirements and acceptance limits contained in calculation 97-ENG-01823-M2, " Verification of Accumulator Size for Valves 2-RB-13.1 A and 13.18," Rev. O, dated August 13,1997, and modification PDCR 2-064-95, " Air Accumulator for 2-RB-13.1A & B," Rev.1, dated August 20, 1997. The test did not verify that the air accumulator leak-tightness was sufficient to hold the valve in the closed position for 90 minutes with a starting pressure of 90 pounds per square inch gauge (psig) and a final pressure of 60 psig.
i NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The test deficiencies identified were the result of inadequate transmittal of the design inputs necessary to complete a comprehensive test plan by the assigned test Engineer. l l Upon review of several other partial design change turnover packages, no other test deficiencies were identified. Therefore, this event was considered an isolated event.
A modification to install backup air accumulators for valves 2-RB-13.1 A/B was instituted via PDCR 2-064-95. The intent of the modification was to keep these valves closed during a Safety injection Actuation Signal (SIAS) coincident with a loss of instrument Air until these valves received a Sump Recirculation Actuation Signal (SRAS) to open.
Valves 2-RB-13.1A/B . fail open on a loss of Instrument air. The retest for the modification to these valves verified there was no leakage, via a bubble test, that the valves stayed closed for the specified time (which was one hour at the time) and that the valves stroked acceptably after instrument air was restored. Normal instrument air
U.S. Nuclocr Regulatory Commission ,
'B17354\Attachm:nt 2\ Pag 3 2 system pressure is >100 psig. This testing was deemed acceptable at the time. Since this was a new design, testing should have occurred at the values assumed in the calculation, namely, specific starting pressure and a minimum pressure, to verify the leakage rate (and bottle size) was acceptable. These pressures were not verified.
Corrective Actions and Results Achieved The test plan for PDCR 2-064-95 was revised to incorporate the design requirements.
As of June 25,1998,2-RB-13.1 A/B had both been successfully retested in accordance with the test plan which demonstrated they met all design basis requirements.
A review of design change engineering release transmittals in the MP2 control room was completed, and found no other cases where changes were made to test plans that left previously released portions not tested to new requirements.
J Corrective Actions to Avoid Future Violations No additional actions are planned.
Date When Full Compliance Will Be Achieved On the basis of the above completed actions, NNECO is in full compliance with respect
.. to the cited violation.
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U.S. Nuclarr Regul: tory Commission 917354\Att: chm:nt 2\Pcg3 3 Nuclear Reaulatory Commission Violation "A" (50-336/98-202-01)
Restatement of the Violation 202-01. A.2 A. 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires that all testing
. required to demonstrate that structures, systems, rnd components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
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- 2. All testing required to demonstrate that the reactor building closed cooling water system (RBCCW) will perform satisfactorily in service was not identified. A periodic test to verify adequate flow to each component serviced by RBCCW had not been established. Procedure SPROC 97-2-19, "RBCCW Building Closed Cooling Water l
System Flow Balance," Rev. 2, dated March 2,1998, only required a one-time flow balance be performed.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation l This violation resulted from the failure to (formally) identify the need for periodic testing in a timely fashion.
No formal tracking document for creation of a follow-up test procedure existed at the time of the NRC inspection. However, during and after performance of the SPROC, both Design and Tech Support Engineering, as well as NNECO management, were informally discussing and were aware of the need to perform follow-up testing should any changes take place in the system.
s Corrective Actions and Results Ach?eved A procedure will be developed requiring the RBCCW system flow balance to be verified prior to startup after each refueling.
l Corrective Actions to Avoid Future Violations No additional actions are planned.
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917354%ttachment 2\Page 4 l l
l Date When Full Compilance Will Be Achieved j The creation and approval of a permanent test procedure for validation and retest of the RBCCW flow balance will be completed prior to restart from Refueling Outage 13.
NNECO will be in full compliance with respect to the cited violation prior to restart from
, Refueling Outage 13.
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U.S. Nucir r R:gulatory Commission S17354%ttechm:nt 2\Pcg3 5 Nuclear Reaulatory Commission Violation "A" (50-336/98-202-01)
Restatement of Violation 202-01. A.3 A. 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above:
- 3. A writte test procedure did not incorporate acceptance toits. Preventive maintenance procedure MF 2701J-96, " Service Water Cooled Heat Exchangers Subject to GL 89-13," Rev. 3, dated April 21,1997, provided instruction.s for periodic maintenance and inspection of the service water cooled heat exchangers. The procedure did not provide acceptance limits for the as-found cleanliness of the RBCCW heat exchangers.
NNECO's Response NNECO does not dispute the cited violation.
Reason forthe Violation NNECO has depended on frequent inspection and cleaning of heat exchangers for maintenance of heat transfer surfaces since 1990. Maintenance Form MF 2701J-96 was developed to schedule and clean systern safety related heat exchangers and provide a means of documenting as four.d heat exchanger condition. Inspection and hydrolysing activities on the RBCCW and diesel generator heat exchangers have been performed quarterly since 1990 and have shown little evidence of fouling on the heat exchanger surfaces. Historically, if debris were found that could influence heat exchanger margin, a Condition Report would be written which would initiete an operability / deportability determination. The corrective action from the condition report would take steps to correct for future fouling (e.g., increase inspection frequency).
These steps were not directed by the maintenance form but are the current plant practice.
Corrective Actions and Results Achieved As part of the corrective action, Maintenance Form MF 2701J-96 was revised to include acceptance criteria for heat exchanger inspections.
The acceptable heat exchanger fouling changes with the temperature of the service t
U.S. Nuclear Rrguistory Commissicn B17354\Attachm:nt 2\Pagn 6 water and tube plugginc! design margin of the heat exchanger. It is not meaningful to list quantities of debris as acceptance criteria since this will change with season and with unit evaluated. Therefore, NNECO revised Maintenance Form MF 2701J-96 specifically identifying the acceptance criterion for service water cooled heat exchanger
- fouling. If this s:ceptance criterion is met or exceeded, the form requires that a CR be initiated and component operability be addressed.
NNECO recognizes the importance of performing base line thermal performance tests to further define heat exchanger design and fouling margin as recommended by Generic Letter 89-13. This testing will also determine if the existing cleaning frequency is adequate. MF 2701J-96 was written to identify macrofouling but was net written to identify microfouling since it cannot be quantified visually. During this outsge, NNECO will or has performed testing on the diesel heat exchangers, and vital AC switchgear room cooler and vital DC s.vitchgear room chiller heat exchangers. NNECO currently plans to test the RiiCCW heat exchangers during the shutdown for RFO13.
Completion of this testing will assist in establishing the proper frequency for cleaning and will also further define heat exchanger design margin.
Corrective Actions to Avoid Future Violation No additional actions are planned.
Date When Full Compliance Will Be Achieved i On the basis of the completed revision to Maintenance Form MF 2701J-96, NNECO is in full compliance with respect to the cited violation. l 1
U.S. Nucle r R:gulatory Commission B17354\Att chm:nt 2\Pcg3 7 Nuclear Reaulatory Commission Violation "B" (50-336/98-202-02)
Restatement of the Violation 202-02. B.1 B. 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires that conditions adverse to quality be promptly identified and corrected. Procedure RP-4,
" Corrective Action Program," Rev. 6, Change 1, dated April 1,1998, requires that conditions adverse to quality be ider6fied and promptly corrected.
Contrary to the above:
- 1. A condition adverse to quality had not been adequately corrected. Condition report M2-97-0489, "RBCCW System Design Pressure Can Be Exceeded at Low Flows," dated March 27,1997, stated that RBCCW system pressure could exceed desiga pressure during pump swapping. Operating Procedure OP 2330A, "RBCCW System," Rev.19, dated March 9,1998, was changed to alleviate the pressure spiking. The procedure was not tested for effectiveness at low flows and was inconsistent with Final Safety Analysis Report (FSAR) Section 9.4.4.2 requirements and with surveillance test requirements.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation This violation resulted from the lack of forma' testing to address potentially low system flow conditions et which pump swaps could occur. In addition, a procedure change was implemented wrsi allowed the system to be operated in a manner whid, was inconsistent with the FSAR.
The RBCCW system experiences pressure spikes during normal pump swaps. To minimize the pressure spikes during pump swaps, a change to Operating Procedure OP 2330A was initiated which included a maximum flow value for swapping RBCCW pumps. A minimum flow value was not specified, evaluated or tested because the system is not operated at low flows, even though the procedure does not specifically prohibit it. When the system Operating Procedure OP 2330A was revised as recommended by Engineering Technical Evaluation M2-EV-97-0021, the changes to the procedure did not take into account the wording in the FSAR. The SE screening
- sheet asscciated with the procedure revision did not identify that any changes to the
! FSAR were necessary.
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Corrective Actions and Results Achi?ved A test procedure (SPROC EN 98-2-04) will be developed to evaluate the planned pump swapping methodology, the system peak pressure response during swapping / check valve slamming, th9 ability of the new " soft-seat" relief valves to re-seat if they lift and ]
to determine if an opimal flow range exists for performing pump swaps.
RBCCW system procedure references to system flowrates will be reviewed to ensure !
that they are consistent and compatible after performance testing utilizing SPROC EN 98-2-04.
An FSAR Change Request (FSARCR) will be PORC approved to more accurate!/
reflect the system operation and pump swapping will be PORC approved.
Corrective Actions to Avoid Future Violations )
No additional actions are planned.
1 Date When Full Compliance Will Be Achieved
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i NNECO will be in full compliance with respect to the cited violation prior to entering Mode 4.
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U.S. Nuclear Regulatory Commission B'i7354\Attachm nt 2\Pags 9 Nuclear Reaulatory Commission Notice of Violation B (50-336/202-02)
Restatement of the Violation 202-02. B.2 B.10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires that conditions adverse to quality be promptly identified and corrected. Procedure RP-4,
" Corrective Action Program," Rev. 6, Change 1, dated April 1,1998, requires that conditions adverse to quality be identified and promptly corrected.
Contrary to the above:
- 2. A condition adverse to quality had not been identified nor corrected. Technical l
Specification (TS) 3.8.1.1 requires two sources of offsite power be supplied to the switchyard, whereas 10 CFR Part 50," General Design Criterion 17," Appendix A, requires that two sources be supplied to the safety buses. LER 95-035, dated October 5,1995, reported that the licensee procedures had not required them to enter a TS limiting condition for operation with less then two power paths from the switchyard to the onsite safety busses. The licensee procedures were changed at that time but tne need for a TS change was not identified nor corrected.
NNECO's Response NNECO does not dispute the cited violation.
i Reason for the Violation The reason for this violation was an insensitivity by NNECO to identify the need for an immediate Technical Specification change.
The Millstone Unit No. 2 Operating License and Technical Specifications were issued by the NRC Staff in a Letter dated August 1,1975. The wording contained in LCO 3.8.1.1 at that time is identical to the wording that appears in the current version of the LCO. The original Combustion Engineering Technical Specifications (NUREG-0212) were still in draft form at this time, with Revision 0 being issued on August 20,1975.
The wording contained in LCO 3.8.1.1 was not questioned until September 6,1995 when it was discovered that the wording of the LCO was not being interpreted in the context of General Design Criterion 17. As a result of this discovery, Licensee Event Report (LER) 50-336/95-035-00 was written and a Technical Specification Clarification was written to reflect that the two offsite power sources and their connection to the onsite Class 1E distribution system consisted of the Unit No. 2 RSST connecting to busses 24C and 24D and the Unit No.1 RSST connecting from bus 14H to 24E.
Surveillance procedures were changed to verify the required circuit breaker positions and power availability. No commitment was made in the LER to change LCO 3.8.1.1.
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l in a letter dated January 18,1996, NNECO informed the NRC Staff that the Millstone Unit No. 2 Technical Specifications would be converied to the improved Standard i Technical Specifications based on Revision 1 of NUREG-1432, " Standard Technical Specifications, Combustion Engineering Plants'. NNECO had intended for the { '
conversion to improved Standard Technical Specifications to resolve any wording ,
issues that existed currently in LCO 3.8.1.1. The converted Technical Specifications (
were expected, at that time, to be submitted in Juno of 1997. The conversion to j Improved Standard Technical Specifications was begun in the second quarter of 1996
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but work was halted in the last quarter of 1996 due to the reallocation of resources J
necessary to recover the Licensing and Design Basis of the unit. In a letter dated January 20,1997, NNECO informed the NRC Staff of the delay. In a letter dated March 27,1997, NNECO submitted the Millstone Unit No. 2 Operational Readiness Plan to :
the NRC. Within this submittal, NNECO stated that tne conversion to improved l
Standard Technical Specifications would be performed after return to operation and l completion of actions to restore compliance with the Licensing and Design Basis. '
Corrective Actions and Results Achieved A license amendment request to revise Technical Specification 3.8.1.1 to be consistent with General Design Criterion 17 was submitted to the NRC on July 17,1998.
Corrective Actions to Avoid Future Violations No additional corrective actions m planned.
i Date When Full Compliance Will Be Achieved Based upon the clarification to the Unit No. 2 Technical Specifications, as contained within the Technical Requirements Manual, and the Surveillance Procedures used to verify operability of the offsite power sources using circuit breaker positions and power availability, NNECO is currently in full compliance with General Design Criterion 17.
NNECO will be in compliance with resp;. to the cited violation when the license amendment request to revise Technical Specification 3.8.1.1 is approved by the NRC and implemented.
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f U.S. Nucisar R:gulatory Commission h17354\ Attachment 2\Page 11 Nuclear Reaulatory Commission Violation "C" (50-336/98-202-03)
Restatement of the Violation 202-03. C C. 10 CFR Part 50, Appendix B, Criterion Vill, " identification and Control of Materials, Parts, and Components," requires that measures be established for the identification and control of materials, parts, and components, and that the identification be maintained.
Contrary to the above, the iden$ification and control of a valve was not maintained.
In several databases, letdown heat exchanger RBCCW outlet temperature control valve,2-RB-402, had two different identification numbers. The valve was identified as 2-RB-402 and 2-CH-223. Valve 2-RB-402 was identified as safety-related, whereas 2-CH-223 was not.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation This violation resulted from the failure to perform a comprehensive review of all applicable documents.
The valve number was changed from 2-CH-223 to 2-RB-402 by Design Change Notice (DCN) DM2-S-0473-93. DCN DM2-S-0473-93 did not address all affected drawings and design documents.
1 Corrective Actions and Results Achieved i The valve identification on Operations Critical Drawing 25203-26017 sh. 2 was I corrected by Design Change Notice (DM2-00-0730-97).
FSAR Change Request (FSARCR) to update Table 9.4-2 (to change the valve identification number to 2-RB-402 will be PORC approved). ,
l Electrical and I&C drawings associated with Valve 2-RB-402 will be identified and updated, as required.
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Procedures associated with Valve 2-RB-402 will be identified and updated, as required.
Corrective Actions to Avoid Future Violations No additional actions are planned.
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l Date When Full Compliance Will Be Achieved NNECO will be in full compliance with respect to the cited violation prior to entry into Mode 4.
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N,lugjear Reaulatory Commission Violation "D" (50-336/98-202-04) l Restatement of the Violation 202-04. D.1 j l
D. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," states in part that activ'ities affecting quality be prescribed by documented instructions and be accomplished in accordance with those instructions.
Contrary to the above:
- 1. An instance was noted where the two RBCCW pump trains (Facilities 1 and 2) did not meet the electrical separation criteria specified in FSAR Section 8.7 and the licensee specification SP-M2-EE-0016, " Electrical Separation Specification-Millstone Unit 2," Rev.1, dated September 9,1997. The separation criteria required 18 inches of free air space horizontally between redundant cable trays.
For cables Z12AA20, Z21_AA20, Z24LA60, and Z16HT35 on Standards drawing 25203-34031, Rev. 7, there was approximately 9 inches of free air space horizontally.
NNECO's ResDonse NNECO does not dispute the cited violation. j Reason for the Violation This violation resulted from lack of cable tray covers being installed. Tray covers are ;
required for trays which do not meet the required separation distance. The installation of these tray covers was not documented on design drawings. The lack of design drawings to control and maintain cable tray cover installations resulted in either these l'
tray covers not being installed as required or these tray covers being removed and not replaced during plant modification or maintenance activities.
Corrective Actions and Results Achieved The applicable drawing to document the installation of the tray covers will be invised.
The tray covers will be installed to eliminate the separation deficiencies.
Corrective Actions to Aveld Future Violations No additional actions are planned.
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U.S. Nucl:er R:gulctory Commission D17354%ttachm:nt 2\Pago 14 Date When Full Compliance Will Be Achieved NNECO will be in full compliance with respect to the cited violation prior to entering Mode 4.
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i U.S. Nucl:tr R:guintory Commission
'817354\Attrchm: nt 2\Pcg315
.N_pclear Reaulatory Commission Violation "D" (50-336/98-202-04)
Restatement of the Violation 202-04. D.2 ;
D. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and '
Drawings," s'.ates in part that activities affecting quality be prescribed by documented instructions and be accomplished in accordance with those instructions.
Contrary to the above:
- 2. Two pressure indicators, Pl-6324 and PI-6325, and their respective tubing, were incorrectly classified as nonsafety-related and nonseismic. FSAR section 5.2.8.2.1 and specification SP-ME-668, Rev. 4, dated May 23, 1997, required these instruments and tubing to be seismic and safety-related.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation This violation resulted from the failure to recognize that the instruments are within the containment isolation boundary.
FSAR Section 5.2.8.2.1 states that containment boundary instrument lines, up to and including the pressure retaining parts of the instrument, are Seismic Class 1. PI-6324 and PI-6325 appear on FSAR Figure 5.2-33 as forming part of the containment pressure boundary. MEPL MP2-CD-3486 was issued on December 19,1997 and incorrectly classified PI-6324, PI-6325 and the associated tubing as non-QA.
Corrective Actions and Results Achieved MEPL MP2-CD-3675 was issued reclassifying Pl4324, PI-6325 and the associated tubing as Category 1.
Nonconformance Report (NCR) 2-98-0169 was issued to review past work order history and purchasing history for PI-6324, PI-63:!5 and the associated tubing., The l NCR was dispositioned as "use-as-is" for PI-6324 and PI-6325 as a result of these l reviews. The NCR was closed on July 7,1998.
The Production Maintenance Management System (PMMS) database was updated to i reflect the Category I classification. .
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U.S. Nucl:nr Regulatory Commission
'B17354%ttar,hment 2\Page 16 Corrective Actions to Avoid Future Violations No additional actions are planned Date When Full Compliance Will Be Achieved On the basis of the above completed actions, NNECO is in full compliance with respect to the cited violation.
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U.S. Nuclur Regulatory Commission
'817354\ Attachment 2\Page 17 Nuclear Reaulatory Commission Violation "D" (50-336/98-202-04) l Restatement of the Violation 202-04. D,3 L
D. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," states in part that activities affecting quality be prescribed by i documented instructicas and be accomplished in accordance with those L instructions.
Contrary to the above:
- 3. An example of originally-installed small bore piping which was not installed in accordance with the applicable piping isometric drawing was identified. A 3/4-inch l by 1/2-inch reducing elbow was installed instead of a 3/4-inch elbow and 3/4-inch by 1/2-inch reducer as specified by DCN No. DM2-00-0640-97, "HPSI 41A Seal / Bearing Coolers Cooling Water supply ar,a Meturn Pipe Replacement," dated August 12,1997.
- l. Additionally, a pipe support was instased differently than required. The support, l Hanger No. 6, was shown on drawing 25203-22200 SH. 491315E, Rev. O, dated '
March 3,1982. The drawing showed a frame type restraint, but the installed l restraint was a cantilever arrangement. Additionally, the drawing showed a 4-inch and a 2-inch angle members, but the installation was made of a 6-inch square l tube and 6-inch wide flange members. Likewise, anchor base plate locations, sizes, and concrete fastener sizes were different than shown on the drawing.
NNECC's Response NNECO does not dispute the cited violation.
Reason for the Violation There was inattention to detail in the development of the piping drawings associated with Design Change Notice (DCN) DM2-00-0640-97.
There was inadequate documentation of design details and $pages which occurred during the installation of support Hanger No. 6 shown on Drawing 25203-22200 SH.
491315E, Rev. O.
t- Corrective Actions and Results Achieved DCN DM2-00-0640-97 was supplemented to correct the errors and the piping drawing of concarn will be updated.
I U.S. Nucinar Regulatory Commission
'B17354\Attachm:nt 2\Pago 18 Support drawing 25203-22200 SH. 491315E will be revised to reflect the as-built condition, and the loading calculation will be verified as acceptable for the as-built configuration.
Corrective Actions to Avoid Future Violations No additional actions are planned.
Date When Full Compliance 'Will Be Achieved NNECO will be in full compliance with respect to the cited violation prior to entry into Mode 4.
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U.S. Nucle r Regulatory Commission
'817354\Attachm:nt 2\Pego 19 l
Nuclear Reaulatory Commission Violation "D" (50-336/98-202-04)
Restatement of the Violation 202-04. D.4 D. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," states in part that activities affecting quality be prescribed by documented instructions and be accomplished in accordance with those instructions. )
l Contrary to the above:
- 4. There were two examples of recent modification work where piping supports were !
not installed in accordance with their drawings. The supports, 25203-22200- l 611087 and 25203-22200-611100, were shown on DCN No. DM2-00-0919-97, l "HPSI Pump P-41A Seal / Bearing Cooling Water Supply and Return Piping j Supports," Rev. O, dated October 10,1997. The actual installations differed from the drawing in that the assemblies were rotated 90 degrees from that shown.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation
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I There was inadequate documentation of design details and r,ngineering decisions made during the installation of these supports on small bore pir ng. J j
Corrective Actions and Results Achieved Design Change Notice DM2-00-0919-97 was updated to correct the piping support drawings, which will be updated prior to entry into Mode 4.
In addition, the orientation of the supports will be clarified in DCN DM2-08-0919-97.
Corrective Actions to Avoid Future Violations Specification SP-ME-730 was clarified. Clarifications provided to SP-ME-730 require that installations comply with all the requirements of the specification (e.g., orientation, load capacity, and attachment details).
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U.S. Nucl:rr Rrgulatory Commission
,B17354\Attachm:nt 2\Pcge 20 j
Date When Full Compliance Will Be Achieved NNECO will 1:e in full compliance with respect to the cited violation prior to entry into l
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U.S. Nuclear R3gulctory Commission
'B17354\Attachm:nt 2\Prgo 21 Nuclear Reaulatory Commission Violation "D" (50-336/98-202-04)
Restatement of the Violation 202-04. D.5 D. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," states in part that activities affecting quality be prescribed by documented instructions and be accomplished in accordance with those instructions.
Contrary to the above:
- 5. An FSAR change request had not been initiated as required by Procedure RAC 03, " Changes and Revisions to Final Safety Analysis Reports," Rev. O, dated December 18,1997. The flow for the. shutdown coolers described in FSAR Table
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9.3-1 were not revised to reflect the reduction of the design basis minimum desi0 n I flow from 4820 gallons per minute (gpm) (2.41 x 10' pounds per hour) to 3500 gpm (approximately 1.75 x 10' pounds per hour). A request to change FSAR Table 9.3-1 had not been made.
NNdCO's Response NNECO does not dispute the cited vio'ation.
i Reason for the Violation This violation resulted from misinterpretation of the FSAR Table 9.3-1. The FSAR table was incorrectly used as design parameters rather than operating parameters. I I
The RBCCW system design basis functional capabilities including FSAR Table 9.3-1 1 need to reflect the current system design basis. The functional capabilities were revised based on the containment peak temperature reanalysis. 4 Corrective Actions and Results Achieved Table 9.3-1 of the FSAR will be PORC approved.
Corrective Actions to Avoid Future Violations No additional actions are plcnned.
1 Date When Full Compliance Will Be Achieved NNECO will be in fu!! compliance with respect to the cited violation prior to entering Mode 4.
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U.S. Nucl::ar R::gul:: tory Commission
'B17354\Attachm::nt 2\Pcge 22
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Nuclear Reaulatory Commission Violation "E" (50-336/98-202-05) l l
i Restatement of the Violation 202-05. E E. 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," requires in part that measures be established to assure that the design basis is correctly translated '
into specifications, drawings, procedures, and instructions.
Contrary to the above, for RBCCW radiation monitor, RM 6038, the design basis alarm setpoint calculation assumptions for flow were not translated into operating procedures. OPS Form 2669A-2, " Unit 2 Aux Building Rounds," Rev. 25, did not specify the flows assumed in the setpoint calculation. Similarly, the " Millstone Two Radiation Monitor Manual," dated June 27,1997, provided an inadequate setpoint calculation bases for the RM-6038 alarm setpoint in that it did not assume flow dilution. Additionally, Operations Form 2654K, " Radiation Monitor Setpoint Verification," Rev. 3, did not provide guidance for dealing with postulated Conditions of high background radiation levels which could result in a nonconservative setpoint.
NNECO's Response NNECO does not dispute the cited violation.
Reason for ths Violation There was a failure to verify the basis of the setpoint against system design. The ]
Radiological Assessment Branch (RAB) ca?culated a maximum allowable setnoint i value. This value and the calculation were placed in the Radioic3 i cal Uuusnt l Monitoring /Off-Site Dose Calculation Manual (REMODCM) and in the Rahion l Monitor Manual (Manual). The Manual also recommended a setpoint value based on )
two or three times the normal monitor reading to allow for a sensitive indication of increased RBCCW radioactivity. RAB did not verify calculational parameters against system design, nor did RAB ensure that the setpoint was adequately implemented in ,
procedures. Additionally, the failure to adequately implement the alarm setpoint design basis was due to inadequate communications of the basis for the setpoint by i implementing departments, and a failure to verify proper setpoint controls within !
applicable implementing procedures. Operations set the setpoint at two times the ;'
normal monitor reading with procedural steps to increase the setpoint as the reading increased. However, there were no provisions to limit the setpoint to the maximum allowable value as described in the REMODCM. Chemistry, wiiich has the lead for i REMODCM implementation, did not ensure that the setpoint was adequately implemented in procedures.
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U.S. Nuclear R:gulatory Commission 1
'B17354\ Attachment 2\Page 23 I l
l Corrective Actions and Results Achieved NNECO will identify RBCCW system design impacts on setpoint calculations.
The setpoint calculation will be revised with assumptions based on actual system design.
A system design review has revealed other considerations impacting the setpoint calculation as discussed above. Procedures will be revised to limit radiation monitor l background and to provide adequate control of setpoint changes. An interim change has already been made to form SP2654K-1 for limiting background. Final procedure changes will be completed after the completion of a revised calculation.
Other effluent radiation monitor setpoints will be reviewed to ensure that there are no similar failures to implement design bases.
l l Corrective Actions to Avoid Future Violations Affected departments will be required to review proposed revisions to requirements for effluent radiation monitor setpoints in the ODCM. i
! A procedure to effectively implement effluent radiation monitor setpoints in the ODCM will be established.
Date When Full Compliance Will Be Achieved
, NNECO will be in full compliarce with respect to the citeci violation prior to entry into i Mode 4.
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U C. Nuclear Regulatory Commission
, 'B17354\ Attachment 2\Page 24 Nuclear Reaulatory Commission Violation "F" (50-336/98-202+6)
Restatement of the Violation 202-06. F F. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, And Drawings," requires that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances.
I Contrary to the above, the annunciator response procedures i4/ the RBCCW system contained numerous inconsistencies, had widely differing levels of detail, j and exhibited poor integration with existing operating and abnormal operating l procedure instrenion (AOP) 2564, " Loss Of RBCCW," Rev. 3. )
l NNECO's Response
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NNECO does not dispute the cited violation. -
Reason for the Violation The Millstone Unit 2 Alarm Response Procedures (ARPs) and Abnormal Operating Procedures (AOPs) were developed and modified over several years by many different individuals. There was no requirement to ensure that the guidance within the two procedure types was consistent. In addition, there was no evaluation performed to determine whether or not the guidance was consistent. Therefore, as the procedures were modified over time, the guidance from procedure to procedure began to vary.
Corrective Actions and Results Achieved AOP 2564 (Loss Of RBCCW) and relevant RBCCW ARP window instructions will be modified, as necessary, to clarify actions and ensure consistency between the documents. This will be completed prior to entry into Mode 4 from the current outage.
Millstone Unit No. 2 will review feedback from Operator training sessions with regard to consistency between ARPs and AOPs, and determine necessary procedure modifications. This review will be completed by December 31,1998.
l Corrective Actions to Avoid Future Violations
, Unit 2 AOPs and their applicable ARP window steps and instructions will be reviewed l prior to, or as part of ert procedure's Biennial Review to correct actions and wording i which are inconsistent. This corrective action will be completed as part of the Biennial Review process.
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U.S. Nuclecr Regulatory Commission
'B17354\ Attachment 2\Paga 25 Date When Full Compliance Will Be Achieved NNECO will be in full compliance with respect to the cited violation prior to entry into Mode 4.
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U.S. Nuclerr R::gulatory Commission
' , 'B17354\Attachmtnt 2\Pega 26 Nuclear Reaulatory Commission Violation "G" (50-336/98-202-07)
Restatement of the Violation 202-07. G G. 10 CFR Part 50, Appendix B, Criterion VI, " Document Control," requires that measures be established to control issuance of documents, such as instructions, procedures and drawings, including changes thereto, which prescribe activities affecting quality. These measures shall assure that documents, including changes, are distributed to and used at the prescribed location.
VI. Document Control Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization.
Contrary to the above, the full-size Unit 2 piping and instrumentation diagrams maintained in the Controlled Document Library on the third floor of building 475 had not ,
been updated since May 1997. I NNECO's Response NNECO does not dispute the cited violation. ,
i Reason for the Violation The out of date drawings found in the Controlled Document Library (CDL) had been removed from controlled distribution, but were inadvertently kept in CDL 475-3.
Inefficient transfer of responsibility for controlled documents was the cause of this '
condition.
l As part of the establishment of CDLs in May 1997, controlled copy holders (in the vicinity of the new CDLs) were instructed to transfer their controlled documents to the new CDL. Concurrent with this action Nuclear Document Services (Document Control Section) terminated the controlled document status for these holders including the holder of these P&lDs (i.e. there would be no further controlled updates for this set of f documents). This specific set of P&lDs was not transferred to the CDL, and remained 4
l U.S. Nucl2cr Regulatory Commission
' " 'B17354\Attachmtnt 2\Page 27 uncontrolled. As a good business practice, these documents should have been removed from the CDL.
Corrective Actions and Results Achieved The CDL group reestablished the P&lDs as controlled documents (through the NDS Control Document Section) and verified / updated the P&lD stick file. The CDL was added to the controlled distribution for these P&lDs.
l The P&lD files in the other CDLs were audited to verify current revision. No similar P&lD problems were identified in the other CDLs. However, several P&lDs were missing from a stick file in one CDL. This was corrected in accordance with CDL
! program.
Corrective Actions to Avoid Future Violations The CDL group will review its program and procedures and provide more specific guidance regarding the storage of uncontrolled (or reference) documents in CDLs.
! This action will be completed by September 30,1998.
l Date When Full Compliance Will Be Achieved NNECO is currently in full compliance with respect to the cited violation.
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- U.S. Nucistr Regulatory Commission
- B17354\Att:chment 2\Page 28 Nuclear Reaulatory Commission Citation "H" (50-336/98-202-08)
Restatement of the Violation 202-08. H 1
H. 10 CFR 50.59, " Changes, Tests, and Experiments," permits changes to be made -
in the facility as described in the FSAR, and requires that records of the changes be maintained, and that the records include a written safety evaluation which provides the bases for the determination that the change did not involve an unreviewed safety question. A proposed change involves an unreviewed safety question if the probability of occurrence or the consequences of a malfunction of equipment evaluated in the safety analysis report may be increased.
NRC " Safety Evaluation of the Millstone Point Nuclear Power Station," dated May 10,1974, Section 7.10, approved 12 inches as the electrical cable separation criteria in panels.
FSAR Section 8.7.3.1 described the same separation criteria.
Contrary to the above, a safety evaluation erroneously concluded that a reduction in the plant-wide electrical separation criteria was not an unreviewed safety question. Design Change Record (DCR) M2-96-068, " Electrical Separation Specification-Millstone Unit 2," Rev 0, dated September 8,1997, revised SP-M2-EE-0016, Rev. O, dated September 9,1996. The change reduced the electrical cable separation criteria from 12 to 6 inches in cabinets. The DCR included a Safety Evaluation No. S2-EV-97-0018, Rev.1, dated September 8,1997, which concluded that there was not an unreviewed safety question. The reduction in separation could increase the probability of a previously evaluated malfunction of equipment.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The discrepant condition identified by this violation was a safety evaluation (SE) that erroneously concluded that a reduction in the electrical separation criteria for wires and devices inside control panels was not an unreviewed safety question (USO).
The cause of the violation was the failure of the Design Change Record (DCR) SE to fully consider the effect of the change relative to the acceptance limit stated in the NRC Safety Evaluation Report (SER) issued on May 10,1974.
U.S. Nucirr Regulatory Commission
- * 'B17354\Attachm:nt 2\Pags 29 Section 7.10 of the SER states in part that, I "The applicant has also stated that at least 12 inches of air separation has been l maintained in the control boards and panels, or noncombustible barriers or conduit l were provided." and, "We conclude that the applicants' cable separation criteria ....
are' acceptable."
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i The DCR revised the separation criteria from 12 inches to 6 inches. The DCR SE concluded that the change was safe and did not involve an unreviewed safety question.
An adequate basis was documented in the SE that the change was safe. However, the SE did not specifically address the SER acceptance limit for separation criteria. Since i the SER acceptance limit was being revised by the DCR, this should have resulted in l
the SE conclusion that the change involved a USQ and required NRC approval prior to implementation.
l Corrective Actions and Results Achieved l l DCR M2-96068 SE Number S2-EV-97-0018, Rev.1 will be revised to consider the effect of the change relative to the acceptance limit in NRC SER issued on May 10, 1974.
j A license amendment request will be processed in accordance with 10 CFR 50.90 for l the change to the SER acceptance limit for electrical separation criteria in control l boards and panels.
l Corrective Actions to Avoid Future Violations i
The procedure for performing safety evaluations will be reviewed and revised, as required, to strengthen the guidance conceming plant changes which affect NRC SERs. '
l A review of other DCRs which impact electrical separation will be performed for similar discrepant conditions.
Date When Full Compliance Will Be Achieved NNECO will be in full compliance with respect to the cited violation prior to entry into ;
Mode 4. l l
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