IR 05000245/1980021
| ML19350D347 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/08/1981 |
| From: | Blumberg N, Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19350D331 | List: |
| References | |
| 50-245-80-21, NUDOCS 8104150293 | |
| Download: ML19350D347 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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g 0FFICE OF INSPECTION AND ENFORCEMENT i
Region I Report No.
50-245/80-21 Docket No.
50-245 License No.
DPR-21 Priority Category C
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Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 1 Inspection at: Waterford, Connecticut Inspection conducted:
October 27-31, 1980
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Inspectors:
N.J.Blumberg',ReactorInspecpr date signed date signed date signed Approved by:
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, b il918I E. G. Greenman, Chief, Nuclear Support date signed Section No. 2, RO&NS Branch
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Inspection Summary:
Inspection on October 27-31,1980 (Report No. 50-245/80-21)
Areas Inspected:
Routine, unannounced inspection by one region-based inspector of followup on previously identified inspection findings; administrative controls for facility procedures; conformance to Technical Specifications; verification of temporary and permanent procedure change in conformance to Technical Specifi-cation requirements and licensee procedures; verification that procedural changes are in conformance to 50.59(a) and (b) requirements; that checklists and related forms incorporated latest changes; and a facility tour.
The inspection involved 33 inspector-hours onsite by one region-based inspector.
Results: Noncompliances: None in four areas and one with examples in three areas (Deficiency - failure to maintain procedures up-to-date and failure to obtain an approved procedure change - paragraphs 2, 4.c.(1), 4.c.(2), and 7).
Region I Form 12 (Rev. April 77)
810.4150893
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DETAILS 1.
Persons Contacted R. Herbert, Superintendent Unit 1
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- E. Mroczka, Station Superintendent l
W. Romberg, Operations Supervisor
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- J. Stetz, Operations Assistant F. Teeple, Instrument and Control Supervisor K. Thomas, Unit 1 Staff Engineer J. Winn, Station Nuclear Records Supervisor USNRC
- G. Walton, Reactor Inspector
- T. Shedlosky, Senior Resident Reactor Inspector
- denotes those present at the exit interview.
The inspector interviewed other licensee suployees including reactor operators, staff engineers, and clerical personnel.
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2.
Licensee Action On Previous Insection Findings (Closed) Unresolved item (245/80-08-03): Procedure SP 1060 did not refer to fuel pool cooling pumps data sheet SP 1060-17; and did not provide instructions for use of form SP 1060-16, "In-Service Inspection Pump and Motor Record." The inspector verified that procedure SP 1060 has been revised to refer to data sheet SP 1060-17 and provides instructions for use of fonn SP 1060-16.
(Closed) Deficiency (245/80-08-01): Documentation of SP 680M, Annual Fire Protection System Pump Flow Rate Test, was not maintained for test performed
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on August 28, 1079, as required by Technical Specification 6.10.1.d.
The licensee provided to the inspector an " Annual Fire Pump Test Sheet" data j
recorded by fire insurance company inspectors which documented satisfactory
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operation of plant fire pumps on August 28, 1979.
This data was transferred to plant data sheet 680M-1, " Annual Fire Protection System Fire Pumps Flow Rate Test" which is being maintained as a plant record. Additionally, the inspector determined that a record of fire pumps flow test performed June 9, 1980 was being maintained, l
(0 pen) Unresolved item (245/78-34-03): Technical Specification (T.S.) Table 3.7.1 lists wrong positions for valves IC-3, IC-4, and CU-5; does not list valves FSV-9-75A-D; and surveillance testing required by Technical Specifi-cation 4.7.D.l.C was not accomplished for valves FSD9-75A-D. The licensee l
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stated that a T.S. change concerning valves IC-3, IC-4, and CU-5 would be j
submitted by July 30, 1980; and that valves FSV-9-75A-D would be modified during the upcoming refueling outage and a T.S. change would be submitted by January 1,1981. The inspector observed that a T.S. change had been submitted June 6, 1980 concerning valves IC-3, IC-4, and CU-5; and the licensee stated that FSV-9-75A-D were being modified during the current refueling outage. This item remains open until completion of action concerning valves FSV-9-75A-D.
(0 pen) Deficiency (245/80-08-02): The following inservice test requirements were not met:
Valve 1-IC-12, " Makeup to Isolation Condenser Stop," was not verified
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in the " locked open" position as required by ISI Table IWV-1.
During a previous inspection (245/80-08) the licensee stated that 1-IC-12 had been locked open and that OP 307-1, Isolation Condenser System Valve checkoff list had been changed to ensure 1-IC-12 is locked open.
During this inspection the inspector observed that a lock and chain has been installed on 1-IC-12; however, because of refueling main-tenance the lock is not in use and 1-IC-12 is currently shut. The inspector also detennined that an interim change had been written to COL OP 307-1 to ensure that 1-IC-12 was locked open.
However, this change was not properly posted to copies of COL OP 307-1 maintained in the Control Room fonns file cabinet in that reproduction caused the change number to be omitted and the Station Procedure Change Fonn which identified the desired condition for the valve was not posted to the COL. This is an example of an item of noncompliance which is further detailed in paragraph 4.c.(1) below (245/80-21-01).
Valve 1-RC-6, " Reactor Building Closed Cooling Water Inlet Check Valve,"
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was not exercised as required by ISI Table IWV-1.
The licensee is currently evaluating a modification to put isolation valves around this check valve and subsequently check the valves during containment local leak rate testing.
Valve 301-138, " Control Rod Drive (CRD) Return Isolation," was not
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verified open every three months as required by ISI Table IWV-1. The inspector verified that a change has been made to SP-1060-14, ISI Pump Vibration and Hydraulic Test, that will verify valve 301-138 is in the open position by checking the CRD flow indicator.
Corrective action for this valve is considered complete.
3.
Facility' Administrative Control Procedures The inspector reviewed on a sampling basis the minutes of Plant Operations Review Coninittee (PORC) Meetings and administrative procedures for conformance with Technical Specifications, Section 6, " Administrative Controls;"
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ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants;" and, Regulatory Guide 1.33,
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" Quality Assurance Program Requirements," with emphasis in the established controls for format, content, review, and approval of facility procedures.
The review included:
ACP-QA-1.02, Organization and Responsibilities, Revision 10,
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January 30, 1980.
ACP-QA-i.03, Assumption of Responsibilities By Key Personnel,
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Revision 5, August 15, 1980.
ACP-QA-1.04, Plant Opera tions and Review Committee, Revision 10,
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June 6, 1980.
ACP-QA-1.05, Site Operations Review Committee, Revision 4,
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August 29, 1980.
ACP-QA-3.01, Administrative Control Procedures and Station Forms,
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Revision 14, August 15, 1980.
ACP-QA-3.02, Station Procedures and Foms, Revision 14, August 15,
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1980.
ACP-QA-3.03, Document Control, Revision 11, August 8, 1980.
No unacceptable conditions were identified.
4.
Facility Procedures a.
The inspector reviewed facility procedures and temporary procedure changes, on a random basis to verify the following.
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Procedures and changes, if any, were reviewed and approved in
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i accordance with the requirements of the Technical Specifications and the licensee's administrative controls.
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l The overall procedure fomat and content were in confomance with the requirements of ANSI H18.7-1976, " Administrative Controls and
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l Quality Assurance for the Operational Phase of Nuclear Power Plants."
Acceptance and Operability Criteria were in conformance with the
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requirements of the Technical Specifications.
Procedures, checklists and related foms in Plant Working Files are current with respect to revision and on-the-spot change in conformance with the requirements of the Technical ~ Specifications.
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The applicable checklists were compatible with step-wise
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instructions in the procedures.
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Temporary changes were made in conformance with Technical
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Specification requirements and the licensee's administrative controls.
Technical content was adequate, using FSAR system descriptions,
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piping and instrument diagrams and Technical Specifications, where necessary, to verify that procedures were sufficiently detailed to control the operation or evolution described within Technical Specification requirements and limitations. The procedures reviewed with respect to this are marked with an asterisk (*).
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The following procedures were reviewed.
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(1) General Operating Procedures
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OP 205, Planned Shutdown to Hot Standby or Hot Shutdown, Revision 4, September 25, 1980.
OP 207, Scram Recovery, Revision 5, April 23, 1980.
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(2) System Operating Procedures Note: Annunciator response procedures were included as subsections of system operating procedures for annunciators which are associated with that system. At least two annunciator response procedures within each system operating procedure were selected at random for review.
OP 303, Reactor Cleanup System, Revision 11, April 12,
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1978 and associated annunciator response procedures for:
Cleanup Filter A or B High Differential Pressure; and
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Cleanup System Low Flow.
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OP 304, Standby Liquid Control System, Revision 9, September 10, 1980 and associated annunciator response procedures for:
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Standby Liquid Control Tank Hi/Lo Temperature Alarm; and Standby Liquid Control Hi/Lo Level.
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OP 306, Reactor Vessel Cooling System, Revision 7, February 23,
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1978 and associated annunciator response procedures for:
Reactor Head Cooling System Depressurized; and
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Head Spray Isolation Valve Open.
- selectea procedures reviewed for technical adequacy.
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OP 311, Containment System, Revision 7, April 20,1978,
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and associated annunciator response procedures for:
Primary Containment Hi/Lo Pressure Alarm; and
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Drywell High Temperature.
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OP 329, Standby Gas Treatment System, Revision 8, August 8,
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1980, and associated annunciator response procedures for:
SGT System A (B) Charcoal Bed Temperature Hi-Lo
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Alarm; and t
SGT System Low Flow Alarm.
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OP 333, Plant Air System, Revision 7, February 29, 1980,
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and associated annunciator response procedures for:
Station Air Compressor Trip;
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Instrument Air Compressor Trip; and
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Instrument Air Pressure Low Alarm.
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OP 344A,125 Volt D.C. Electrical System, Revision 10,
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l June 15, 1979, and associated annunciator response procedures l
for:
l 125 V.D.C. Bus 18A or 18B Undervoltage; and
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Loss of D.C. Control Power.
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IC 404A, Nuclear Instrumentation (APRM Channels), Revision 1,
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December 7,1978, and associated annunciator response pro-cedures for:
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APRM Hi-Hi Flux or Inop; and
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APRM Down Scale.
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Emergency Procedures
OP 502A, Anticipated Transient Without Scram, Revision 2,
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June 11, 1980.
OP SilA, Plant Shutdown Outside The Control Room With Initial
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Phase Performed In Control Room, Revision 2, February 23, i
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OP 516C, Control Rod Drive Hydraulic System Rupture, Revision 2, September 8, 1980.
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OP 517, Auto Pressure Relief Valve Stuck Open, Revision 3 April 20, 1978.
(4) Maintenance Procedures MP 701.1, Reactor Vessel Head Removal and Replacement,
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Revision 3, May 21, 1980.
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MP 710.1, Overhaul of MSIV Operator, Revis' ion 8, September 19, 1980.
MP 770.7, Vertical 4160 Volt Variable Speed Motor " Reactor
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Recirculating Water Pump Motor," Revision 1, August 2,1978.
MP 745.4, Isolation Condenser Disassembly and Assembly,
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Revision 2, July 23, 1980.
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Findings (1)
10 CFR 50, Appendix B, Criterion VI, requires, in part, that procedure changes be approved by authorized personnel and distri-buted to and used at the location where the prescribed activity is performed. Valve lineup checkoff lists (COL) and other operating procedure fonns and checkoff lists are maintained in a Control Room file cabinet. Operations Department Instruction 1-0PS-1.03 assigns responsibility to ensure operations forms and COLs be maintained current to the latest revision.
During a random inspection of these cabinets, the inspector determined that certain COLs and operations forms were not main-tained current, in that:
COL OP 207-1, Sc am Report Data Sheet, Revision 0, was main-
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tained in the cabinet although Revision 1 dated April 16, 1980 was in effect. Revision 1 has an additional requirement for the verification of the primary source of the scram.
COL OP 205-2, Procedures Required for Shutdown, Revision 1,
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plus interim change No. 1, was maintained in the cabinet although Revision 2, September 18, 1980, was in effect.
The inspector determined that Revision 2 had replaced interim change No. 1 to Revision 1 and there was no difference in content.
- Selected procedures reviewed for technical adequacy.
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COL OP 333-1, Service Air System Valve Checkoff List,
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Revision 0, was maintained in the cabinet although interim change No. I to Revision 0 dated September 3, 1980 was in effect.
Interim change No. I added three newly installed valves to valve lineup.
COL OP 307-1, Isolation Condenser System Valve Checkoff List,
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Revision 4, was maintained in the cabinet although interim
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change No. 1 to Revision 4 was in effect.
Interim change No. I changes the position of valve 1-IC-12
" Makeup to Isolation Condenser Stop" from "open" to " locked open" in order to meet inservice inspection requirements.
This change was written as partial corrective action for deficiency (24S/80-08-02) and was properly posted to the Control Room copy maintained on the procedures " bezel".
However, copies of COLs to be used for actual performance of valve lineup did not have change 1 posted. As previously
noted in paragraph 2 above the inspector considered imple-mentation of the corrective action to be inadequate.
One of the Control Room cabinet drawers has a posted sign which requests personnel to ensure that the COL which is being used contains the latest change. This has not been effective in that the following COLs were performed using out of date revisions:
COL OP 201-2, Panel 905 Pre-Critical Checklist, was performed
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July 12, 1980 using Revision 1 interim change 1, although Revision 2, dated November 14, 1979, was in effect; COL OP 201-4, Procedure Required for Startup, was performed
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July 12, 1980 using Revision 3 change No.1 although Revision 4, dated November 14, 1979, was in effect; COL OP 207-1, Scram Report Data Sheet, was performed July
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12, 1980 using Revision 0 although Revision 1, dated April 16, 1980, was in effect; and COL OP 321-1, Service Water Valve Checkoff List, was performed
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June 24, 1979 using Revision 1 although Revision 2, dated April 12. 1979, was in effect.
Except as previously noted for COL 207-1, there were no, or only minor, differences between the earlier and effective revisiens for the above COLs.
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Failure to maintain Control Room COL files current to the latest revision; and failure to use the latest revision while performing COLs is contrary to Technical Specification 6.8.1 and Operations Department Instruction 1-0PS-1.03, and constitutes one example of an item of noncompliance (245/80-21-01). An additional example is detailed in paragraph 4.c(2) below.
(2). Technical Specification 6.8.2 requires that changes to procedures be reviewed by the PORC and approved by the station superintendent.
Procedure OP 302, Control Rod Drive System, paragraph 7.11 provides procedure for control rod drive stall flow testing and specifies that data be recorded on COL OP 302-2 (Stall Flow Testing) Data Sheet. The inspector observed that for stall flow tests perfonned on June 26,1980, July 24,1980, August 25, 1980, and September 18, 1980, data was recorded on data sheets provided by the Reactor Engineer rather than on COL OP 302-2.
This deviation from procedure OP 302 was accomplished without obtaining an approved procedure change.
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Failure to obtain an approved procedure change when deviating from an approved procedure is contrary to Technical Specification 6.8.2 and is one example of an item of noncompliance (245/80-21-01).
i An additional example is detailed in paragraph 4.c.(1) above.
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(3) During inspection of administrative procedures, the inspector observed that controlled copies of procedures ACP-QA-102, Revision 10, and ACP-QA-3.02, Revision 14, were being maintained in the Control Room although revision 11 to ACR-QA-102 had been issued October 10, 1980 and revision 15 to ACP-QA-3.02 had been issued October 8, 1980.
A licensee representative stated that the latest revisions to these procedures had just been received and the inspector observed that they were promptly posted.
Further discussions with the licensee indicates that late distribution of procedure changes has been a continuing problem. The inspector informed the. licensee that changes to procedures should be posted on their effective dates. The licensee acknowledged the inspector's comments and stated that a i
method would be developed to ensure changes are posted by their effective date; and that this would be accomplished by June 1, 1981.
This item is unresolved pending licensee action and subsequent NRC:RIreview(245/80-21-02).
(4) The inspector observed that operating procedure, OP 333, Plant Air System, and emergency procedure, OP 512, Station Air Rupture, in part, provide for operation of Millstone Unit 2 air valves and
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providing plant air for Unit 1 from Unit 2; in addition, emergency (
procedures OP 511A-D, for various modes of control room evac-
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uation, states that the Unit 2 fire brigade will perfonn Unit 1 l
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fire brigade duties.
None of the above procedures had been reviewed by the Station Operating Review Committee (SORC) or by the Unit 2 PORC. The inspector informed the licensee that Unit 1 procedures which provide for operation of Unit 2 safety related equipment or the use of Unit 2 personnel designated for plant safety purposes should be reviewed by the SORC or Unit 2 PORC. The licensee ack-nowledged the inspector's comment and stated that SORC review would not be appropriate but that a method would be developed to
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ensure that procedures which provide for the use of safety related personnel or equipment in both units will be reviewed by both PORCs and stated that this will be accomplished by June 1,1981.
This item is unresolved pending licensee action and subsequent NRC:RI review (245/80-21-03).
(5) Paragraphs 2.2 of emergency procedures OP 511 A, B, C, and D, state the following:
"2.2 In the event that the Control Room is evacuated because of a fire, the fire brigade duties will be perfomed by Unit 2 personnel.
This will enable Unit 1 personnel to proceed with a safe plant shutdown in accordance with this procedure." The inspector con-ducted discussions with Unit 1 personnel trained in fire fighting procedures who, in turn, stated that Unit 1 and Unit 2 fire brigades were not cross trained in the specifics of the other plant, i.e.,
would not be familiar with the location of plant equipment or fire fighting equipment and that they would have to work under the direction of fire brigade members from the other plant. The above procedures imply that under certain conditions Unit 2 fire brigade would assume complete Unit 1 fire fighting duties while not unuer the dire-tion of Unit 1 fire brigade members.
The inspector infomed the licensee that the above procedures should M changed to ensure that Unit 1 fire brigade members are available to direct Unit 2 fire brigade members or that Unit 2 fire brigade members must be trained in Unit 1 plant specifics. The licensee acknowledged the inspector's coments and stated that the above problem would be evaluated and a resolution provided by June 1, 1981. This item is unresolved pending licensee action ar.1 sub-sequent NRC:RI review (245/80-21-04).
(6) Procedure ACP-QA-3.02 requires that section 8 of system operating procedures provide annunicator response procedures for annunciators of that system and that these procedures will contain the following:
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Name of alarm, panel, and coordinates;
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initiation device;
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setpoint;
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auto action;
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initial action; and
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subsequent action.
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Operating procedures for instrument systems such as neutron mon-itoring and reactor protection are written by the Instrument and Control Department. During review of IC 404A, Nuclear Instru-mentation (APRM) channels, the inspector determined that Paragraph 8 of the alarm procedures did comply with the above format.
Inspection of four additional procedures:
IC 401A, Nuclear Instrumentation (SRM channels)
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IC 402A, Nuclear Instrumentation (IRM channels)
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IC 403A, Nuclear Instrumentation (LPRM channels)
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IC 405A, Nuclear Instrumentation (TIP channels)
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determined that annunciator response sections of these pro-cedures were also not in the correct format. Although the following procedures were not reviewed this problem may also be applicable to them.
IC 406A, Process Radiation Monitor.
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IC 407A, Area Radiation Monitoring System.
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IC 408A, Reactor Protection System.
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IC 410A, Nuclear Instruments (RBM channels).
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The licensee stated that response procedures for these annunciators may be incorporated into other operating procedures and will be in the correct format. The licensee also stated that this item would be reviewed and appropriate corrective action taken (if required) by June 1, 1981.
This item is unresolved pending licensee action and subsequent NRC:RI review (245/80-21-05).
(7) The inspector reviewed valve lineup checkoff lists completed for the 1979 refueling outage and determined that valve lineups had not been accomplished for 22 of 63 systems. A licensee repre-sentative stated that there was no set plant policy as to when complete system valve lineups were to be done.
He stated, that in general, major plant systems and core emergency cooling systems
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were lined up at the completion of each refueling outage but that other systems which were in constant use or for which major work was not accomplished were not given complete system lineup checks.
Further, the licensee stated that as a result of and in response to an item of noncompliance identified in Unit 2 (336/80-09-01),
in which a HPSI pump was damaged due to improper valve lineup, a Millstone Station Administrative Control Procedure (applying to both Units 1 and 2) was in preparation which will state specifically as to when system valve lineups must be performed. A commitment has been made to have this instruction issued by January 8, 1981.
A Unit 1 representative stated that if this instruction has not been issued before the completion of current refueling outage, then temporary valve lineup guidelines will be developed, implemented and documented concerning which Unit I systems must be lined up.
This item will be reviewed during a subsequent NRC:RI inspection (245/80-21-06).
5.
Procedure Changes Resulting From Licensee Amendments The inspector reviewed license amendments (Amendments 59 through 68) which included Technical Specification changes, issued during the past twenty month period and verified that applicable procedures were reviewed as necessary to reflect these changes.
No unacceptable conditions were identified.
6.
Changes to Procedures as Detailed in the Safety Analysis Report Pursuant to 10 CFR 50.59(a) and (b)
l The inspector verified, on a sampling basis, that changes made to facility procedures during the past twenty month period were in compliance with l
10 CFR 50.59(a) requirements and that records of these changes were main-tained in compliance with 10 CFR 50.59(b). For the procedures reviewed, the licensee had determined that 10 CFR 50.59 safety evaluation documentation was not required (no change in procedures as described in the FSAR). The inspector had no questions in this area.
7.
Facility Tours The inspector toured various areas in the turbine building including the main turbine floor, the Standby Gas Treatment Room, and the heating and
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i ventilation room; the reactor building including the isolation condenser area, fuel pool cooling area, and control rod drive accumulators; and
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outside protected areas to verify posting of radiation areas, adherence to radiation work permits, integrity of plant equipment, and plant physical security. During this inspection the plant was in a refueling outage and a large amount of maintenance activity was in progress.
No unacceptable conditions were observed.
8.
Unresolv0d Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or items of noncompliance. Four urresolved items are identified in paragraphs 4.c.(3),
(4),(5),and(6).
9.
Management Meetings Licensee management was informed of the purpose and scope of the inspection at the entrance interview, and the findings of the inspection were periodically
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discussed with the licensee representatives as follows:
Date Reportable Details Coverec October 27 Entrance Interview October 28 4.c.(3)
October 29 4.c.
, 4.c. 2)
October 30 4.c.
, 4.c. 7)
October 31 4.c.
, 4.c. 5), Exit Interview I
l The inspector conducted an exit interview with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection, where the findings of the inspection were presented and acknowledged.
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