IR 05000213/1987006

Insp Rept 50-213/87-06 on 870210-0318.No Violations Noted. Major Areas Inspected:Plant Operations,Radiation Protection, Fire Protection,Physical Security,Maint,Surveillance Testing,Ie Info Notices & Open Insp Findings

ML20205M898
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/25/1987
From:	Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205M866	List: IR 05000213/1987006 ML20205M863
References
50-213-87-06, 50-213-87-6, IEIN-86-007, IEIN-86-7, NUDOCS 8704020525
Download: ML20205M898 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-06 Docket N License N DPR-61 Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 l

Hartford, CT 06101 Facility: Haddam Neck Plant, Haddam, Connecticut

! Inspection at: Haddam Neck Plant Inspection conducted: February 14 through March '18, 1987

' Inspectors: Stephen M. Pindale, Resident Inspector Paul D. Swetland, Senior Resident Inspector Approved by: E4e Me c 2 A e J, f 2 d- 3/ar/e7 E. C. McCabe, Chief, Reactor Pp6jects Section 3B Date Summary:

Areas Inspected: This was a routine resident inspection (225 hours0.0026 days <br />0.0625 hours <br />3.720238e-4 weeks <br />8.56125e-5 months <br />) of plant operations, radiation protection, fire protection, physical security, maintenance, 1 l surveillance testing, IE Information Notices, open inspection findings and licensee I

events. The licensee's fitness for duty program and low temperature overpressure '

protection system were also reviewe Results: Five NRC open inspection findings were closed. Two unresolved items were opened regarding reactor vessel low temperature overpressure protection (Report Detail 8). No violations were identified.

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TABLE OF CONTENTS PAGE Summary of Facility Activities....................................... 1 Review of Plant Operations........................................... 1 l Observation of Maintenance and Surveillance Testing.................. 1 Followup on Previous Inspection Findings............................. 2 4.1 Solenoid Operated Valve Failures................................ 2 4.2 HPSI Valve SI-HV-1881 Positioning............................... 2 4.3 Control of Heavy Equipment...................................... 3 4.4 Portable Fire Extinguisher Inspection........................... 4 4.5 Control / Computer Room Fire Wall................................. 4 4.6 Safety Injection Valve Not Locked............................... 5 4.7 Three-Loop 0peration............................................ 5 i

1 Followup on IE Information Notice 86-07.............................. 6 Followup on Events Occurring During the Inspection................... 6 1 Review of Periodic and Special Reports............................... 7 Low Temperature Overpressure Protection.............................. 7 l Fitness for Duty Program............................................. 9 1 Unresolved Items..................................................... 10 1

1 Exit Interviews...................................................... 10 l

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DETAILS Summary of Facility Activities At the beginning of the inspection period, the plant was operating at full power. A turbine load runback occurred on March 2 due to a spurious negative rate spike on one power range nuclear instrument. Full power operation was resumed. On March 4 and 14, load was reduced to 50% power to locate and re-pair condenser tube leakage and to add oil to the No. 2 reactor coolant pump motor, respectivel . Review of Plant Operations The inspector observed plant operation during regular tours of the following plant areas:

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Control Room --

Security Building

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Primary Auxiliary Building --

Fence Line (Protected Area)

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Vital Switchgear Room --

Yard Areas ,

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Diesel Generator Rooms --

Turbine Building 4

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Control Point --

Intake Structure and Pump Building Control room instruments were observed for correlation between channels and for conformance with Technical Specification (TS) requirements. The inspector observed various alarm conditions which had been received and acknowledge Operator awareness and response to these conditions were reviewed. Control room and shift manning were compared to regulatory requirements. Posting and control of radiation and high radiation areas was inspected. Compliance with Radiation Work Permits and use of appropriate personnel monitoring devices were checke Plant housekeeping controls were observed, including control and storage of flammable material and other potential safety hazards. The inspector also examined the condition of various fire protection system During plant tours, logs and records were reviewed to determine if entries were properly made and communicated equipment status / deficiencies. These records included operating logs, turnover sheets, tagout and jumper logs, process computer printouts, and Plant Information Reports. The inspector observed selected aspects of plant security including access control, physical barriers, and personnel monitoring. No abnormal conditions were identifie . Observation of Maintenance and Surveillance Testing The inspector observed various maintenance and problem investigation activi-ties for compliance with requirements and applicable codes and standards, QA/QC involvement, safety tags, equipment alignment and use of jumpers, per-sonnel qualifications, radiological controls, fire protection, retest, and reportability. Also, the inspector witnessed selected surveillance tests to determine whether properly approved procedures were in use, test instrumenta-tion was properly calibrated and used, technical specifications were satisfied,

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testing was performed by qualified personnel, procedure details were adequate, and test results satisfied acceptance criteria or were properly dispositione The following activities were reviewed:

PMP 9.1-1 Turbo-Generator Control Valve Test SNM 1.4-2 Removing New Fuel From Shipping Containers SNM 1.4-3 Detail Inspection of New Fuel Assemblies and RCCAs SUR 5.1-8 Monthly Containment Recirculation Fan Damper Test and Filter Inspection SUR 5.1-13 Auxiliary Feed Pump Monthly Functional Test SUR 5.1-24 Inspection of Main Steam Header and Feedwater Lines SPL 10.7-270 Preoperational Test of the Computer Room Halon System The inspector had no further questions on these matter . Followup on Previous Inspection Findings During the course of the inspection, seven NRC open items were reviewe The inspector found licensee actions with regard to five of these areas to be sufficient to close these items. Details follow:

4.1 (Closed) Unresolved Item (213/85-20-01): Multiple failures (sticking)

of solenoid-operated valves (S0Vs) in the automatic auxiliary feedwater (AFW) actuation system. The failures were not repeatable after cycling of the S0Vs, and no definitive cause of the sticking was evident upon valve disassembly. The licensee confirmed with the valve manufacturer that extended periods with the solenoid energized most probably caused these failures. Therefore, the licensee committed in Licensee Event Report 85-24 to perform more frequent exercise / testing of the AFW SOV The inspector ascertained that other continuously energized S0Vs are installed in the main steam isolation valve closure system. These S0Vs are cycled quarterly and have not exhibited similar failures. The test )

frequency for AFW S0Vs was reduced from a refueling to a weekly interva l No AFW SOV sticking has been experienced at the weekly interval. On i February 17, 1987, the licensee initiated an administrative technical specification (ATS) to formalize the test frequency reduction. This ATS is to be incorporated in the plant TS's during the conversion to Standard TSs in 1987-88. This item is close I l

4.2 (Closed) Unresolved Item (213/86-16-02): The licensee was to evaluate i the consequences of operating the high pressure safety injection (HPSI) '

pump recirculation line isolation valve (SI-HCV-1881) during normal plant operations. On July 3, 1986, the failure of that 2-inch valve in the l

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open position potentially rendered both HPSI system trains inoperable for approximately 45 minutes. Since that failure of SI-HCV-1881, the licensee has maintained the valve in the closed positio No specific calculations have been performed to quantify the consequences of SI-HCV-1881 failing open. However, qualitative engineering assess-ments indicate that, with this 2-inch valve open, both HPSI trains should be considered inoperable and consequently outside the design basis of the plant Technical Specification The licensee performed a review to determine the necessity for opening SI-HCV-1881 during normal operation. The primary reason for opening SI-HCV-1881 on a monthly basis was to verify the operability of the HPSI pump discharge check valves. This partial stroke test is required quar-terly as specified in Amendment 37 to the Operating License (ASME Section XI Program). Because SI-HCV-1881 has been maintained shut since its failure, the HPSI pump check valve test has been performed by opening the individual 1/2-inch loop recirculation valves (one at a time). Lic-ensee qualitative assessments indicate that the failure of a 1/2-inch loop recirculation valve would not impact the HPSI system design base The licensee has concluded that SI-HCV-1881 need not be opened for

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monthly or quarterly surveillance purposes, and will be maintained closed during plant operation. The monthly surveillance procedure, SUR 5.1-4, Hot Operational Test was revised to specify that SI-HCV-1881 be main-tained closed during this test. This item is closed.

I 4.3 (0 pen) Unresolved Item (213/86-20-01): The licensee was to develop and implement a program to control the storage of heavy, transient equipment in safety related areas. During this inspection period, the inspector found a compressed gas storage bottle lashed to a conduit in the Primary Auxiliary Building, near containment isolation valve operating line The bottle had been located there for operator use during a shutdown from outside the control room. Also, a cart in the control room holding several breathing air storage bottles (previously identified by NRC as a potential safety hazard) recently was moved closer to the main control board. Neither of these two occurrences were reviewed by the licensee for their impact on safety-related equipment. Upon inspector identifi-cation of these problems, the equipment was removed to a safer locatio Subsequent licensee evaluation of the PAB gas bottle concluded that  !

adverse affects of the installation would have been minimal. The in-spector determined that the licensee's expected implementation date for a storage control program to address this issue had slipped to May 198 !

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During a meeting with licensee management on February 26, 1987, the.in-spector noted that further interim measures were needed to assure the

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integrity of safety-related equipment pending final implementation of ,

the equipment storage control program. Department heads were instructed by the licensee to inspect their assigned spaces to identify and correct any further discrepancies. This action was subsequently formalized in a revision to administrative control procedure ADM 1.1-125, Station Housekeeping and Inspection Program. The licensee plans to implement

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work control procedure changes and indoctrinate personnel to prevent re-currence of such events within the previously established schedule. This item remains open pending licensee completion of the above action .4 (Closed) Violation (213/86-20-02): Portable fire extinguishers (PFEs)

in the switchgear room were not inspected in accordance_with preventive maintenance procedure PMP 9.5-120, Portable Fire Extinguisher Inspectio The licensee response stated that the failure to inspect the switchgear room PFEs was the result of poor communications between the contractor personnel assigned that duty and the station personnel responsible for its completion. The contractor did not perform the switchgear room PFE inspections and failed to notify responsible station personne The licensee's immediate corrective action was to perform PMP 9.5-120 to ensure that all PFEs had been inspected. The licensee took additional actions to prevent recurrenc Previously, a single sign-off was re-quired when all PFE inspections were completed. PMP 9.5-120 was revised to include a checkoff for individual PFEs. Also, the maintenance depart-ment supervisor issued a memorandum restating the responsibility of sta-tion personnel to oversee / verify the actions of contractor personnel performing quality-related work under their cognizanc A subsequent NRC Team Inspection (NRC Inspection Report No. 50-213/86-29)

noted additional PFEs that were not inspected. The licensee review of these problems revealed that the work order to perform these checks had not been closed and that inspections were planned prior to expiration of the test interval grace period. The inspector verified completion of the preventive maintenance checks on these and other PFEs. No further discrepancies were identified. The continued effectiveness of the lic-ensee's actions will be reviewed under the routine inspection progra This item is close l 4.5 (0 pen) Unresolved Item (213/86-24-01): Construction and design deficien-cies identified in the control room / computer room wall adversely affected the 1-hour fire rating of this wall. A roving fire patrol was imple-mented to compensate for the degraded fire barrier. The licensee was to evaluate and implement necessary corrective actions to reestablish compliance with Technical Specification 3.22 and the bases of License Amendments 28 and 81. The inspector reviewed the status of the existing computer room wal The licensee stated that all fire wall deficiencies had not yet been corrected due to the proximity of the work area to safety-related electrical cabinets. The licensee intends to maintain the roving fire patrol to monitor the discrepant fire wall until all the deficiencies are corrected during the July 1987 refueling outag The inspector reviewed the preparation for and results of the computer room Halon system functional acceptance test conducted on March 3, 198 The Halon system test results indicated that a peak Halon concentration above 7% was reached and a concentration above 6% was sustained for 10 minutes. In order to maintain the validity of the Halon test results, the inspector noted that extraordinary work controls would be necessary

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to maintain the present Halon leakage integrity of the computer room wall during fire barrier repair This item remains open pending final com-pletion of the fire barrier repairs and NRC review of the Halon test result .6 (Closed) Violation (213/86-27-06): The licensee discovered that safety injection system valve MOV-24 was not locked in its specified position, as required by plant Technical Specifications. The violation was con-sidered to be of minor safety significance since no equipment was mis-positioned. In response to the violation, the licensee committed to 1) issue instructions to operators to emphasize the importance of insur-ing that locks and chains are intact on locked components; 2) file a training request to add locked valve training to operator training pro-grams, and; 3) change surveillance procedure SUR 5.1-126, Locked Valve Checklist, to address the proper method for verifying locked component statu On November 4,1986, the licensee issued a memorandum to all Operations Shift supervisors, senior control operators, control operators, and auxiliary operators. The memorandum stressed the importance of proper maintenance of locks and chains, and provided brief instructions on how proper checks of the valves and breakers are to be performed. The lic-ensee also revised Operations Department Instruction (0DI) No. 1, Conduct of Operations, to include instructions on practices to be followed when

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verifying the status of locked components during surveillance checks and system line-ups. Additionally, in response to a training request, the Non-Licensed Continuing Training Program has been upgraded to provide instructions on proper verification of the status of locked component The inspector verified that the instructor lesson plans reflect the training program changes. A controlled routing (CR) to the Operations Department tracks the revision of procedure SUR 5.1-126. The inspector had no further question .7 (Closed) Unresolved Item (215/86-30-01): On July 11, 1986, the licensee l identified a 3-loop reactor coolant system (RCS) flow inadequacy such that the measured flow was about 2.4% less than the safety analysis valu Three-loop operation was then administratively prohibited by the license Contrary to this, on December 8, 1986, the licensee discovered that the reactor was being operated in mode 2 (reactor critical, less than 5 per-cent power) with 3 loops operating. Such operation had lasted for ap-proximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. When identified, the licensee promptly started the fourth reactor coolant pump. The operation outside the plant design basis was reported to the NRC on December 8. Licensee review of the event identified incomplete implementation of corrective actions noted in licensee event report LER 86-34, which described the July 11, 1986 event. Additional procedural revisions were initiated via temporary procedure changes (TPCs) to assure continued conformance with the plant safety analyses. On December 31, 1986, the licensee submitted to NRC Licensing a proposed Technical Specification (TS) revision which included the 3-loop flow reanalysis and associated proposed TS changes. NRC re-

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i view noted that the failure to maintain the plant in accordance with the commitment of LER 86-34 constitutes a licensee-identified deviation from a commitmen In December 1986, procedure ADM 1.1-150, Preparation, Re-view and Tracking of LERs was implemented. This procedure provides a i

formal r ocess for tracking the implementation of.LER commitments. Since-this deviation was licensee-identified'and appropriate corrective actions have been implemented, no further action is considered necessary at this-

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time. The inspector had no further questions on this ite . Followup on IE Information Notices (IENs)

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-IEN 86-07: Inadequate Maintenance and Testing of Diesel Generator Governors 1,

This notice informed licensees of potential diesel generator speed control problems caused by inadequate oil filling and venting procedures / techniques

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for the diesel speed governor. The licensee reviewed this concern and deter-mined that no such problems had occurred to date. However, the recommended

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governor fill and. vent procedures were incorporated in Revision 10 to Proce-dure PMP 9.5-36, Preventive Maintenance of.the Emergency Diesels. The in-

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spector verified these actions as documented in site controlled routing 86-457.~

l No inadequacies were identifie . Followup on Events Occurring During the Inspection

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6.1 Licensee Event Reports (LERs)

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The following LERs were reviewed for clarity, accuracy of the description.

j of cause, and adequacy of corrective action.- The inspector. determined j whether further information was required and whether there were generic-implications. The inspector also verified that the reporting require-

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ments of 10 CFR 50.73 and Station Administrative and Operating Procedures had been met, that appropriate corrective action had been taken, and that j- the continued operation of the facility was conducted within Technical

Specification Limits.

I 86-04 Low Temperature Overpressure Protection (LTOP) System Malfunction

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86-18 RCS Wide Range Pressure Uncertainty, Revision 1-

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{ 86-33 LTOP Isolation Valve Interlock Failure 86-40 LTOP System Inoperable for Testing

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j (These events are reviewed in Report Detail 8, following.)

-I 6.2 During full power operation.on March 2,1987, Dropped Rod / Rod' Stop, i Overpower Rod Stop and Overpower Trip alarms were received from one of j the four Nuclear Instrumentation System (NIS) channels (No. 32). The negative rate Dropped Rod / Rod Stop signal initiated a turbine load run-

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back, which was overridden after plant operators determined that the actuations were spurious. The licensee installed a jumper on the turbine load runback signal on NIS Channel 32 because of continuing spikes on that channel. Notifications were made to local, state and NRC official Licensee investigation revealed the source of the NIS channel 32 spikes to be the high voltage power supply. The licensee repaired the faulty power supply and restored it to servic The jumper was removed on March 4. Anomalies in the NIS drawers have been a continuing problem at the-plant. A long term corrective action plan exists to replace the NIS because of aging, replacement part procurement considerations, and pre-vious similar events on other NIS channels. For the interim, the licen-see closely monitors NIS performance through weekly verification of system operability. The inspector had no further questions at this tim . Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted pursuant to Technical Specification 6.9 were reviewed. This review verified that the reported in-formation was valid and included the NRC required data; that test results and supporting information were consistent with design predictions and performance specifications; and that planned corrective actions were adequate for resolu-tion of the problem. The inspector also ascertained whether any reported in-formation should be classified as an abnormal occurrence. The following periodic reports were reviewed:

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Monthly Operating Report 87-01, plant operations from January 1-31, 1987

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Monthly Operating Report 87-02, plant operations from February 1-28, 1987 No inadequacies were identifie . Evaluation of Low Temperature Overpressure Protection (LTOP)

Reactor vessel integrity can be threatened by sudden pressure increases com-bined with low reactor coolant system (RCS) temperature. This concern was addressed by the installation of an LT0P relief system which is placed in service whenever the RCS temperature is below 340 F. License requirements regarding the LTOP system were incorporated in Amendment 33 to the Haddam Neck operating license. The inspector reviewed this Amendment and other referenced documents. System design records and drawings were also verified. During this review, NRC concerns were identified as outlined below. The inspector brought these concerns to the licensee's attentio Intended licensee actions are included for each ite Th~e licensee has experienced problems placing the LTOP system in service due to interlock instrumentation inadequacies which prevent opening the system isolation valves at the design setpoint. These problems have been documented in Licensee Event Reports 86-04, 18, 33, and 40, and NRC Re-gion I Inspection Reports 50-213/85-21 and 86-01. Amendment 33 states that LTOP testing assures system operability prior to reliance on the ,

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system. The licensee's previous testing program was normally performed after reliance on the system for plant cooldown had been establishe In response to recent problems with placing the LTOP system in service, the licensee has been performing pre operational testing of the isolation valve interlocks. The licensee is preparing a new Technical Specifica-tion change to place the system on-line at a lower temperature. This change is intended to provide more margin for the system interlocks to function properly. Upon completion of the license change, the licensee will implement a new pre-operational test procedure for LTOP system in-terlocks. The LTOP spring-loaded relief valves will continue to be tested in the refueling mode in accordance with ASME Section XI. Com-pletion of this item is tracked by NRC open item 213/85-21-0 b. The analyses demonstrating the adequacy of the LTOP system to mitigate RCS overpressure events were based on reactor vessel pressure / temperature (10 CFR 50 Appendix G) limits calculated for 14 Equivalent Full Power Years (EFPY) of reactor operation. The licensee re-evaluated these an-alyses when the Appendix G limits were extended to 22 EFPY of reactor operation in 1985. In order to establish continued acceptable results, unnecessary conservatisms were removed from the analyses by the license These deletions have not been reviewed by the NRC. Also, the NRC Safety Evaluation Report for the LTOP requirements notes that the flashing of reactor coolant relieving through the LTOP valves could reduce the maxi-mum relief flow ratc. With only one train of LT0P in operation, the

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i maximum heat-up overpressurization event may exceed the Appendix G pres-sure limit. The inspector questioned whether the current licensee an-alyses demonstrate adequate margin to the 22 EFPY limits assuming only one train of LTOP operable and the potential effects of coolant flashing within the LTOP syste The licensee plans to investigate the effects of flashing on the LTOP analyses by April 15, 1987, before any further cold shutdown operations. This item remains unresolved pending assess-ment of the acceptability of the removal of conservatisms and of the acceptability of flashing effects (UNR 213/87-06-01).

c. Licensee correspondence dated January 3,1978 committed to lock the LTOP motor operated isolation valve (M0V) breakers open to assure that the system was not inadvertently incapacitated. Inspector review of licensee operating procedures identified that, based on previous unnecessary RCS pressure blowdowns through the LTOP system, this practice had been abandoned to improve operator capability to respond to these event Also, MOV position indication is lost upon de energizing the MOVs. The licensee stated that the current practices ngarding control of MOV position would be reviewed, and that any required change to the January 3, 1978 commitment would be formally addressed prior to the next planned use of the LTOP system in July 1987. The inspector noted that new licen-see procedural practices call for annotation of procedural commitments in the respective procedures to assure that the commitments are formally changed prior to revision of the procedural requirement. This process should prevent recurrence of this problem. Completion of procedural changes will be followed with the changes noted in paragraph 8.d. belo __

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! During inspector review of LTOP system operating and test procedures,

concerns were noted as follows:

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Verification / control of pressure / temperature recorder operability during low temperature reactor system operation was not-implemente .

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Precautions and procedural steps were not written to emphasize mini- I

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mization of solid water operatio ,

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Alarm response strategy / procedures were not structured to. identify

an.LTOP event which lifts the spring-loaded relief va he at 380 psig, but fails to reach the system overpressure alarm setp;11nt of 400 psi Procedural controls regarding the limitations for Ctarting reactor coolant pumps, charging pumps, and/or high pressure safety injection

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pumps were not consistent with the potential significance of these operations during solid water operatio .

The licensee is evaluating the identified procedural deficiencies and i plans to make necessary procedure revisions prior to the next planned

solid water operations -in July 1987. This. item will remain unresolved

pending NRC review of these changes (UNR 213/87-06-02).

i l Fitness for Duty Program

j The licensee has implemented a fitness for duty program applicable to all

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-employees with unescorted access to nuclear facilities. An expansion of Northeast Utilities Policy and Procedure (NUP) 90: Alcohol, and NUP 91: Drug Abuse; the program requires annual drug testing and became effective February

, 10, 1987. Drug testing will be scheduled with annual physicals beginning

March 10, 1987. For those employees not requiring annual physicals, drug i testing will also be scheduled on an annual basis. All contractors and sup-

pliers with unescorted access to nuclear facilities will be subject to similar test requirements on or about June'1,1987.

Mandatory drug testing has been required for all' newly hired personnel since'

i July 1, 1986 and for all transfers to a nuclear facility since August 18, 1986.

Testing for cause, that is, for employees who appear to be unfit for duty, i

has been used since January 1, 1984 and will continue. A refusal to submit

! to testing has been and will continue to be equivalent to positive test re--

sult Testing will be performed by a qualified laboratory. Sample collection ~will not be witnessed but will be subject to strict contro Analyses will be

sensitive to amphetamines, barbituates, valium, cocaine, opiates, darvon, THC, ,

PCP, codeine, heroin and morphine. Positive results from initial screening i

, will undergo confirmatory testing using gas chromotography and mass spectro--

j meter techniques. A quality assurance and audit program will be instituted

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utilizing independent evaluators and spiked sample Positive confirmatory testing will result in revocation of unescorted access to nuclear facilities based on failure of physical examination requirements.

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The new fitness for duty program is currently in the implementation proces The underlying philosophy of the utility policy is that the employee is ultimately responsible for a safe, productive work environment. That re-sponsibility includes both self fitness and the fitness of other The lic-ensee's program is based on the August 1985 recommendations of the Edison Electric Institute Human Resource Management Division. The inspector had no

further question . Unresolved Items Unresolved items are matters about which more information is required in order to determine whether they are acceptable items or violations. Unresolved items identified during this inspection are discussed in Paragraph . Exit Interview I

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During this inspection, meetings were held with plant management to discuss  !

the findings. No proprietary information related to this inspection was identifie ,

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