IR 05000245/1987032

Insp Repts 50-245/87-32,50-336/87-27 & 50-423/87-31 on 871130-1204.No Violations or Deviations Noted.Major Areas Inspected:Surveillance Test Program,In Plant Instrument Calibr,Test Equipment & Cold Weather Preparation

ML20149H053
Person / Time
Site:	Millstone
Issue date:	01/29/1988
From:	Blumberg N, Dev M, Finkel A, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149H052	List: IR 05000245/1987032 ML20149H051
References
50-245-87-32, 50-336-87-27, 50-423-87-31, NUDOCS 8802190083
Download: ML20149H053 (21)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-245/87-32 50-336/87-27 Report No /87-31 l 50-245 50-336 Docket No DPR-21 DPR-65 License No NPF-49 Licensee: Northeast Nuclear Energy Company ,

P. O. Box 270 Hartford, Connecticut 06141-0270

, Facility Name: Millstone Nuclear Power Station Units 1, 2 and 3  ;

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Inspection At: Waterford, Connecticut  !

Inspection Cond ed: Novert9r 30 - December 4,1987 Inspectors:

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/h8 ' # hY M, Dev, PE Reac or(Engineer n i 2f B6 d' ate r

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~p"A.F Kel,SeniorReaEterEngineer ca/se date l

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, p A lf/"'r D ' 27 38 l G. Napuda, Senior Reactor Engineer d&te

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Approved b 2 ) 1h'S N. Blumberg, CVief, Operational d rograms date i Section, DRS  !

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Inspection Summary: Inspection on November 30 - December 4, 1987 (Combined Inspection Report Nos. 50-245/87-32, 50-336/87-27 and 50-423/87-31 Areas Inspected: Routine unannounced inspection of licensee's Surveillance *

! Test program - Complex Safety-related System, inplant instrument calibration,

measuring and test equipment, cold weather preparation, and QA/QC interfaces for Millstone Nuclear Power Station Units 1 and 2. The Testing of Containment Penetration Conductor Overcurrent Protection devices was also reviewed at Unit Results: No violations or deviations were identifie i 8802190003 000203

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DETAILS 1.0 Persons Contacted Northeast Utility Service Company (NUSCO)

Northeast Nuclear Energy Company (NNECO)

R. Bates, Assistant Supervisor, Electrical Engineering, MP-2

• T. Brown, Assistant Supervisor, I&C, MP-1

• C. Clement, Unit Superintendent, MP-3

• Closius, Plant Quality Services Supervisor (NUSCO)

J. Criscione, Staff Engineer, MP-2

• F. DiCarlo, Assessment Services Specialist (NUSCO)

R. Enoch, I&C Supervisor, MP-3

• Gentry, Engineering Supervisor, MP-3 J. Harris, Operations Supervisor, MP-3

• H. Haynes, Millstone Station Service Superintendent (NUSCO)

J. Kennedy, Production Test Engineer, MP-2

' R. King, Assistant Supervisor, I&C, MP-1

• D. Kross, I&C Supervisor, MP-2

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• J. Leason, ISI Coordinator, HP-1

• C. Libby, Assessment Service Supervisor (NUSCO)

C. Monk, Control Operator, MP-1 G. Olson, Operations Engineer, MP-3

, P. Privizzone, Maintenance Engineer, MP-3 l

P. Przekop, I&C Supervisor, MP-1 R. Rathgeb, Maintenance Supervisor, MP-3 '

"S. Scace, Millstone Station Superintendent

• J. Stetz, Unit Superintendent, MP-1 l

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United States Nuclear Regulatory Commission (USNRC)

• S. Barber, Resident Inspector, MP-1

• Raymond, Senior Resident Inspector

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The inspectors also contacted licensee's other technical and adminis- L trative personnel during the course of this inspectio * Denotes those individuals who were present at the exit meeting on i 2.0 General The various documents / records such as procedures, data sheets, work )

orders, modification packages and Quality Assurance (QA) reports that '

were reviewed and used as reference requirements during the course of ;

this inspection are listed in Attachment 1. Also, implementing proce-dures were reviewed for technical adequacy and calibration / test results ,

were verified to meet acceptance criteri !

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Paragraph 3.0 discusses the inspection of Units 1 and 2; paragraph applies to Unit 1; paragraph 5.0 applies to Unit 2; and, paragraph applies to Unit Observations of ongoing activities and independent examination of in plant conditions are identified within the appropriate paragrap ,

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3.0 Surveillance and Calibration Program for Inplant Instrumentation (Units 1 and 2)

3.1 Program Review A review of administrative and calibration procedures and the master inplant calibration instrumentation schedules were made to verify tha .

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• Requirements and commitments listed in Attachment 1 were met;

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• Master inplant calibration schedules-and administrative control-systems had been established which identified the frequency of each calibration, the responsible group for performing each calibration and the status of each calibration of inplant

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instrumentation;

• Responsibilities had been assigned for maintaining the master i calibration schedules up to date; '

Procedures, written to an approved format and technical specification requirements, existed for conducting each calibration;

Responsibilities had been assigned for reviewing and evaluating

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the results of calibration data;

• Calibration requirements had been established and mainte.ined for equipment associated with safety related systems but which are

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not specified in Technical Specifications as requiring calibration; i

Responsibility had been assigned for ensuring that required schedules for all calibrations were satisfied;

Technical content of calibration procedures complied with technical specifications requirements;

Procedures contained controls to insure limiting conditions for operation had been met during the calibration; i

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Calibrations were performed to the required accuracy; and,

Measuring and test equipment used in the calibration was traceable to the work for which it was use .2 Implementation The master scheduling for Unit I has been incorporated inte the computerized Plant Maintenance Management System (PMMS) and the weekly published schedule lists those calibrations that must be done within the forthcoming four weeks. This printout provides the Work Order (WO) number, task, applicable procedure (s), system identifi-cation, instruments involved, QA/QC involvement and other pertinent i information. Discussions with the I&C Supervisor and planning staff indicated that refinement of the data base with respect to QA/QC designation and involvement is ongoing. The data base and existing calibration procedures have been crosschecked a number of time Several Technical Specificaticn (TS) Table 4.1.2 calibration require-ments were sampled to verify that a corresponding procedure existed; that the task was contaired in the data base including the correct calibration frequency; and completed calibrations met established i acceptance criteri The master scheduling for Unit 2 has been incorporated onto '

printed schedule sheets. These schedules have been formatted in ,

such a fashion that the issued monthly multisheet schedule lists all calibrations due the upcoming month (e.g., weekly, monthly,

" quarterly, semiannual, annual, refueling). Applicable procedures, ;

the dates within which the calibration must be done and other appro-priate information is provided on these sheets. Also, space is provided for technician comments and the date the task is complete ,

Several TS Table 4.3-1 calibration requirements were sampled to verify that a corresponding procedure existed; that the calibration and its frequency was reflected in the master schedules; and com-

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pleted calibrations met established acceptance criteri The onsite I&C Metrology Lab calibrates most of the portable

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measuring and test equipment (M&TE) that is used by each of the three units I&C Shops, Training Center and the Production Test

, group. Laboratories / Vendors approved by the QA organization must be used for M&TE that is sent offsite for calibration. Each of the groups is responsible for the M&TE it uses. The I&C Metrology Lab was toured and it was noted that some work on the physical facility and "equipment setup" remain to be completed because of a recent relocation of the laboratory.

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. 5 The calibration of Unit 2 Excore/Incore Nuclear Instrument Channels C and D was observe The task steps have been programmed for the Personal Computer (PC) that the two I&C technicians were using. A few noteworthy aspects of using a computerized calibration procedure were the display of only one step at a time in chronological order as the previous step was completed and an entry made into the computer; automatic alert of the technicians when unacceptable results were recorded and the printout of a corrective action form; and, the necessity of correctly completing each step before the program allows advancement through the procedure. The technicians had a current printed procedure in their possession and demonstrated agreement between it and the computer program. Currently, calibration results are recorded manually on data sheets. Discussions with the Unit 2 I&C Supervisor indicated that this practice will be discontinued when full confidence in the computerized program is attained. The develop-ment of other such computer programs and the program validation (e.g., line by line verification, benchmark tests) were also

' discusse .3 Quality Assurance Interfaces and Overview Discussions were held with the onsite QA/QC management with respect to the auditing and surveillance of calibration activities associ-ated with installed in plant instrumentation. A major change in QC overview technique is currently being planned and this is basically expanding the unannounced observation of ongoing activities and reducing the number of hold / witness points previously inserted into implementing work procedures. Extensive research and analysis of past inspection results revealed the followin A review of Work Orders determined that 60-80% of established hold / witness points were within the skills of the worker to determine acceptabilit There was a very low incidence of unacceptable work associated -

with hold / witness point Other work steps were identified where independent inspection had never been performe An intense analysis of this information led to the conclusion of i licensee management that a more effective and efficient use of  ;

resources could be realized by a restructuring of the QC overview

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, approach. The change to place more emphasis on surveillance type of overview has begun and is to be implemented at a slow pace. It was noted that thirteen QC Quality Activity Observations (i.e.,

surveillances) have been conducted on in plant calibration and ten i QC observations had been conducted on plant TS surveillance testing I during the past yea j

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. .6 A QA audit of plant ceiibration/ testing was ongoing ~during this inspection. The checklists were reviewed and the conduct and

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planning ofLthe audit was discussedLand observed with QA auditors

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and management. It was noted that an audit' attribute was the verification that sampled TS. requirements were indeed included in

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existing procedures. This technique and other observation type attributes were determined to have been increased from the numbe previous in the checklists for this' functional are .4 Conclusions and Findings The program for calibration of in plant installed instrumentation asi ',

established is accurate, clearly described and well mana.ged. Both the computerized scheduling at Unit 1 and the schedule sheets used at Unit 2 control the assignment and completion of tasks. The I&C staff and supervision have a clear understanding of the administra-tive control system.

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Technicians performing the calibrations are knowledgeable with

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respect to their duties and procedures being used. Execution-of work steps were done conscientiously and in a confident manne The most notable human factors improvement in the conduct of in plant calibration of instrumentation is the use of a Personal Computer at Unit 2 to display work steps; guide the technician; ;

determine acceptability of results and automatically initiate a corrective action document when appropriate; prompt and require the worker to follow procedural steps; and, retain results for record purpose The research and analyses of inspection results history by the ,

Quality Assurance group in an effort to identify.a more effective and efficient use of their resources is commendable. An improvement was also noted in the auditing techniqu Management involvement and support is evident and reflected in the quality of the established program, the manner in which it is implemented and being improved, and the effort to enhance the QA overview effect;venes ! No violations oc deviations were identifie .0 Mp-1 Surveillance Test program and Cold Weather Preparation 4.1 MP-1 Surveillance Test Program 4. Scope and Criteria Emphasis in this inspection was placed on the review of the adequacy and effectiveness of the implementation of the licensee's TS related surveillances and inservice

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inspection (ISI) program Calibration and. control of installed equipment and measuring and. test equipment was '

discussed.in paragraph 3. The program was reviewed to the_

following requirements:

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10 CFR 50, Appendix B

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MP-1 Technical Specifications (TS), Section 4, Surveillance Tests

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MP-1 Final Safety Analysis Report (FSAR), Sections 6.3, Emergency Core Cooling System (ECCS), and 7.3- c Engineered Safety Feature Systems

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Regulatory Guide 1.33, Quality Assurance Program (Operation)

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

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ANSI N45.2.6-1978, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel i

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Appropriate MP-1 Administrative Control Procedures and Operations and I&C Surveillance Procedures as '

listed in Attachment 1- ,

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4. Program Review f

The licensee's surveillance test-program, and inservice inspection and testing of pumps and valves were reviewed

to ensure that the licensee has established:

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Overall control for surveillances, inservice inspec-tion, post-maintenance testing and post-modification

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testing

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Test procedures to meet the Technical Specifications requirements and objectives including test schedule and frequencies

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Master test schedules for surveillances and ISIS

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Mechanism for tracking of the completed tests

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Responsibility and authority for review of the completed tests

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< 8 4. Implementation Review and Findings 4.1.3.1- The inspector reviewed selected functional test-ing of the safety-related core spray (CS) and low pressure coolant injection (LPCI) (sub) systems of the emergency core cooling system (ECCS). Sec-tion 7.3 of the FSAR describes and analyzes the instrumentation and controls used to initiate and '

control the operation of the engineered safety feature (ESF) system which-includes ECC .1. The MP-1 I&C group conducts TS related surveil-lances, and the MP-1 engineering staff coordinates inservice inspections and testing of functional attributes of pumps and valves. These activities are accomplished through approved surveillance  ;

procedures in accordance with the licensee's administrative procedures to meet the require-ments set forth in the facility's Technical Specification These procedures have estab-lished test objectives, acceptance criteria, i applicable references, prerequisites, initial conditions, test precaution, and delineated ,

steps to accomplish test activitie The pro-cedures are reviewed biennially by cognizant plant staffs and approved by the PORC and plant management prior to us Some of the I&C surveillance procedures reviewed were found to have referenced obsolete FSAR sec-tions and the licensee's department instruction The licensee representative acknowledged that the FSAR was recently updated, and currently the I&C

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staff is reviewing the I&C procedures to verify the impact of the FSAR update, and incorporate any changes as require .1. The I&C and Inservice Inspection (ISI) engineer-ing coordination staff have established master surveillance schedules for TS related surveil-

lances and inservice inspections. The schedules are reviewed and the surveillance tests status updated periodically. The I&C surveillance test schedules are published weekly and a work order is initiated through the plant maintenance manage-ment system (PMMS). The I&C supervisory staff reviews the work order for its adequacy prior to the job assignment. The ISI staff follows similar controls in establishing inservice inspection requirements and performing the tests.

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. 9 4.1. The I&C staff performing the TS related surveil-lance tests reviews the associated procedures including the test data forms (I&C Form 400 series) before commencing the tests. Accordingly, minimum crew requirement, availability of cali-brated test equipment, operations approval and ,

coordination, and QA/QC. hold and witness points are established. The ISI activities'are limited in nature, and as such the ISI coordinating staff establishes coordination with I&C and operations staff to accomplish inservice inspections and testin ,

The inspector witnessed the TS related Reactor Low-Low Water Level Functional and Calibration ,

Test performed by the I&C staff. The low-low water level is detected by four independent level switches connected in a one-out-of-two taken twice logic array. These same devices also initiate starting of the diesel generator and the gas turbine on receipt of a low-low water level signal. The I&C surveillance procedure SP 412C provided for-the testing and calibration i of the reactor low-low water level instruments

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LIS-263-72A, B, C, 0 and LITS-263-73A, i The inspector also witnessed the MP-1 engineering staff coordinate certain inservice inspections and testing in accordance with approved opera-tions surveillance procedures. The surveillance '

verification of the core spray system pumps and

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valves was conducted in accordance with Procedure l

. SP 621.10, and the accuracy of the remote indi- !

cation of valve operation was checked in ac- !

cordance with Procedure SP 621.11. Similarly, the LPCI system pumps, motor operated valves and l check valves operational readiness verification l was conducted in accordance with Procedure SP l 622.7, and the accuracy of the remote indication I of valve operation was checked in accordance with Procedure SP 62 .

These tests were conducted in adherence with the I associated procedures, and were well coordinated among participating organizations, such as I&C, operations and engineering. Test data were ,

legibly recorded and independently verifie Post-testing system restoration was carefully completed and independently verified prior to returning the system to operatio j

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4.1. The inspector also reviewed selected I&C surveil-lance tests, and inservice inspections conducted by the MP-1 engineering staff. In each instance, procedural steps, data recording, independent verification, test acceptance and test approval were properly documente The completed test reports were easily retrievable through the licensee's nuclear records management syste .1. The licensee's Quality Service Division (QSD)

is currently conducting an audit to verify the licensee's compliance of the Technical Specifi-cations related surveillances to the station Administrative Control Procedures (Attachment 1).

The audit covered the general overview of all three units, including MP-1, with respect to the licensee's surveillance testing progra The individuals performing these tests were found to have adequate training and experience, and were conversant with the tests' procedural and functional requirements. The inspector reviewed the training records and certifica-tions of selected individuals who were assigned to the surveillance test activities discussed in paragraph 4.1.3.4. They met the requirements delineated in ANSI N45.2.6-1978. The inspector i also verified that the I&C and inservice inspec- l tion coordinating groups were adequately staffe . Conclusion Based on the review of the licensee's surveillance test procedures, inservice inspection procedures, discussion with the licensee's cognizant individuals, and witness of the test programs, the inspector concluded that the licensee's surveillance program implementation is effectiv .2 MP-1 Cold Weather Preparation This inspection verified the effectiveness of the licensee's cold weather preparation program implementatio The licensee has established an off-normal operations procedure ONP-514 This incorporates a checklist based on the licensee's past cold weather experience and the plant specific requirement The procedure provides an outline of steps undertaken to maintain the plant in a safe condition in the event of sustained subfreezing

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. 11 temperature In addition, the operations staff periodically makes rounds and verifies that equipment, system and process lines im-portant-to-safety are adequately protected against extreme cold weather conditions. This activity is accomplished in accordance with the Plant Equipment Check Log Form 1-0PS-10-0 The MP-1 I&C maintenance staffs also periodically make rounds and verify the operability of instrumentation and control circuitries, sensors, thermostats and other devices used for monitoring, heat tracing, protection and control of equipment, system and process lines. Any deficiencies identified are corrected and dispositioned through the maintenance work order ,

The inspector discu.; sed the MP-1 winterization program with the cognizant operations and I&C staffs and reviewed related activities and documentation. The inspector concluded that the licensee's action to implement MP-1 winterization program is adequat .0 Loss of Offsite Power / Black Out (LOP /BO) MP-2  :

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The inspector performed an examination of selected portions of the Loss of Offsite Power / Black Out system components and the cold weather protection !

associated with this system. To enhance their system design, the licensee has installed new and modified existing equipment for the MP 1/2 Appendix R Backfeed; modified their emergency diesel generator automatic start sequence system; issued a Connecticut Valley Electric Exchange (CONVEX)

procedure and program; and performed enhancement changes in their 345kV station insulator i 5.1 Appendix R Modification - Millstone Units No. 1 and 2

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AC Power Crosstie Northeast Nuclear Energy Company (NNECO) proposed to modify Mill- !

stone Unit No. 1 to provide a capability to connect the Unit No. 1 ,

emergency AC power system to the Unit No. 2 emergency bu The modification supports the Unit No. 2 alternate shutdown capability required to meet the provisions of 10 CFR 50 Appendix R, Section l III.G. During this review of the Unit No. 2 LOP /B0 design, the '

inspector reviewed the breakers, surveillance testing and the status

4 of the design modifications that were completed during the last Unit ,

No. 2 outage. The inspector, using the design criteria of Plant l

Design Change Reowst (PDCR) No.1-98-86, reviewed the following ;

installations t assure that they complied with the as-built draw-i ings, the PDCR requirements and station operation procedures: l

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Replacement of the existing 4kV bus 2F with a vacuum breaker switchgear

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Modification of th~e existing RSST bus duct tie to align the bus

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Complete Phase 1 and Phase 2 testin ,

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The inspection of the selected design modifications above and a-review of the test data taken during the system testing verified that the extent of the design change was complied wit r

5.2 Diesel Generator Automatic Start Sequenc '

The licensee has issued Plant Design Change Request (PDCR) .

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No. 2-87-86 which removed the Safety Inspection System (SIS) auto-_ -

matic start signal from both emergency diesel generators (EDGs). The reason for the change was the possibility of an EDG failure which can  !

be caused by running their diesel unloaded when an SIS signal is .!

received. The licensee's original design automatically started their  !

EDGs when either a Loss of Offsite Power (LOP) or an SIS is receive .

The emergency system automatic start sequence (ESAS) receives the l

signal, processes it, and initiates the EDG control circuitry to  !

! start the EDG Their original Final Safety Analysis Report (FSAR) r

] stated that an SIS nortrally causes both diesels to start as a pre-cautionary measure only. A Westinghouse report stated that removal i

! of their SIS auto start does not impact the design basis accident ,

t analytical assumptions. With the SIS aute start removed, the EDGs will auto start on a LOP. The inspector reviewed the Engineered Safety Feature System (ESF) Integrated Test procedure to verify that  !

the TS requirements of the diesel system have been complied with and }

j that the test data recorded complies with the requirements of their I

procedures. A review of their 50.59 safety analysis report indicated i that there was not any unreviewed safety questions associated with ,

i this change. The inspector reviewed the EDGs procedure to verify that l the following parameters of the diesel system were tested:

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A LOP signal starts the EDG ,

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The required listed breakers opene !

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The diesel generators start from an ambient condition and are ready for loading, with their output breakers closed, within 30

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seconds of the undervoltage ir,itiation signa I

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The sequence operated to energize appropriate equipment within the specified time intervals.

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That all non-emergency diesel generator trips are bypassed by I

the LOP start signal except overspeed, generator differential current, voltage restrained overcurrent and low lube oil j pressure (2 of 3).

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The EDGs test data reviewed by the inspector verified that the test performed complied with the procedure requirements.

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5.3 Connecticut Valley Electric Exchange (CONVEX)

l The licensee has taken action to place the plant in a safe condition t

during a severe storm, high winds or high tides. Administrative Operating Procedure (AOP) 2560 has established the action the licensee plans to take in the event certain criteria is reached. In conjunction with AOP 2560, the licensee has prepared a CONVEX operat-ing instruction (COI) 8601, which provides a method of deenergizing the entire Millstone 345kV substation. The physical location of the l

Millstone 345kV substation makes this station prone to salt contami- . nation. Site history data indicated that salt contamination can happen as quickly as 30 minutes from an operating substation to one that could short out from the accumulated salt deposits. A0P 2560 and the COI 8601 allow the EDGs to be brought c- line while shutting down the site reactor .4 345kV Station Coating Program Flashovers and heavy electrical discharge activity have occurred on external insulation at the Millstone site in periods when winds have carried salt from Long Island Sound. The licensee has been upgrading various insulators over the past few years but during a recent storm in the spring of 1986, frequent discharge activity was observed at this site. A joint program between Northeast Utilities and the '

Electric Power Research Institute (EPRI) High Voltage Transmission Research Center (HVTRC) was carried out in 1986 to determine a recom-mendation for improving their dry salt insulator tracking proble EPRI research project report No. RP 2472-3, December 1986, I recommended the c7ating of the 345kV Station Insulators with an j

RTV coating (Sylgard) material manufactured by the Dow Corning Corporation. The test report in general states that the RTV coated i j

insulators showed a dramatic improvement in performance in tests when compared with uncoated insulators. The test report also stated that af ter many hours of exposure to the severe salt mist environment, the coated insulators withstood the maximum live to ground operating voltage. Also, switching impulse tests were made to determine whether the RTV coatings would degrade insulation strength. It was documented in the report that no such degradation occurred at overvoltage levels )

i of 2.8 per unit. Approximately 75% of the Millstone site has been coated with the RTV material on the 345kV yard insulators. During this inspection, the inspector witnessed the application of the RTV coating being applied to 345kV insulators. The results of the RTV coating material on the 345kV insulators is being monitored by the Millstone Unit No. 2 electrical maintenance organi:atio ._ . . . . ~.

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In addition to the COI 8601, A0P 2560, and.the RTV coating of.the 345kV insulators, the licensee has installed yard hydrants and dedi-cated hoses,-nozz)es, and wshdown equipment to maintain the 345kV

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yard equipment clear of salt to, minimize flashovers and electrical discharges.

5.5 ConclusionandFindins; The licensee has demonstrtted by testing and analysis that.they have '

met their TS requirement for' verification that their EDGs will carry !

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I th & plant loads when a LOP signal is received. They have also ,

performed o'esign changes and prepared procedures to enhance the '1 operation of their 345kV lines to the site. These changes should !

have a direct effect on the licensee's ability to safely shut this site down and protect the safety and health of the publi No violations or deviations were identified.

6.0 Containment Peretration Conductor Overcurrent orotective Devices (Circuit .

Breakers) - MP-3  ;

6.1 Proposed TS Change for Overcurrent Circuit Breakers i'

Northeast Nuclear Energy Company (NNECO) has proposed to amend its .

Millstone Unit No. 3 Operating License by requesting a change to ;

i Technical Specification Section 4.8.4.1.a.2. Specifically, the pro- '

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posed changes to Technical Specification Section 4.8.4.1.a.2 will (

require that surveillance testing requirements for molded case '

circuit breakers and unitized starters which are used at Millstone

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Unit No. 3 for containment oleqtrical penetration secondary over-current protection, comply with the NEMA AB2-1980 criteri ,

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{ The existing Technical Speciffeation requires that testirg of molded l l case circuit breakers and unitized starters follow the same proce- l 4 dures as the electrically operated power air circait breakers.

Testing of the electrically operated power air' circuit breakers j f consist of applying a current with a value equal to 300% of the i

, pickup of the long delay trip element and 150% of the pickup of the '

3 short-time delay trip element. The present Technical Specification j section also requires that the instantaneous elsment be Lested by applying a current equal to 20% of;the pickup value of the elemen (

l These specific values are not applicable to molded case circuit '

breakers or unitized starters as these devices have only one time '

delay element and one instantaneous elemen .i i

NEMA AB2-1980 recognizes that it is impractical to field test circuit breakers in accordance with UL 489, therefore, NEMA AB2-198 ,

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. 15 provides the following recommendations for selecting test parameters for field testing of molded case circuit breakers (250 AMP frame and less):

a) Instantaneous Test -25% to + 40% of low and high setting-(respectively)

b) Long Time Test 300% of concinuous rating The additicnal 40% tolerance is requested for testing of molded case breakers to assure operability of the instantaneous trip elemen This element is tested by applying a seven cycle (0.12 sec.)_ current _ pulse and verifying the breaSer trip tim Accordingly, NNEC0 proposes to make the following changes to Tech-nical Specification Section 4.8.e.l.a.2 for selection test current values:

Present Test Current per Proposed Test Device Technical Specification Current Molded Case Circuit % of long time % of continuous Breaker delay pickup rating or % of short time none Unitized Starters deley pickup % of tra. tan- % to +40% of taneeus element instantaneous element trip values or range limit The inspettor witnessed the surveillance testing of six different containment penetration overcurrent devices performed in accordance with Station Procedure (SP) 3712T. This surveillance station pro-

edure requires the present testing tolerance ac defined in Technical Specitiertion section 4.8.4.1.a.2, but where the test data exceeds the 29% value but less than the -25% to +40% value, the licensee is holding the test data approval pending NRC approval of the requested TS chai e. The test results, of the breaker test witnessed by the i inspecter were within the present TS tolerances and wert signed by licensee's surervisio I The celuulations and engineering analysis to justify that the pene- )

tration f ault current and the thermal rating of the penetration is j not degraded by the selected protective relaying is df: cussed in 4 Millstane 3 Electrical Penetration Protection report. A review of I tne above report and test witnessing by the inspector verified that the 15 change request to change the containment penetration over-l

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current device surveillance testing for molded case breakers will not exceed the thermal limits of the penetration that the breakers protec The inspector'had no further questions in this are .2 Station Operating Procedures for Overcurrent Protective Devices Durin;; a review of the overcurrent protective system procedures, the inspector identified that procedures had over three changes attached to the procedures that were not incorporated into a pro-cedure revision. Quality Assurance procedure ACP-QA-3.02 requires that after three changes to a procedure, the procedure will have the changes incorporated into a new revision. During a review of the licensee audit / surveillance program on procedures, the inspector verified that this problem was identified in Quality Assurance Surveillance Report No.- 387-37, October 10, 1987. The licensee is reducing this backlog at a rate of 2% per week. The expected com-pletion date is the second quarter of 1988. The inspector verified that each procedure change is manually incorporated into the control room procedures which are used by the operations personnel. The licensee stated that upon completion of the Emergency Operating Procedure (EOP) upgrade program, they believe they should signifi-cantly reduce the present backlog. Their trending program, which started in May 21, 1987 to present, indicates that their procedure change and incorporation program is ahead of schedule at this tim After reviewing the licensee's method of updating changes into their operating procedures, their manpower associated with this task and management attention an.1 support of the program, the inspector had no further questions in this are No violations or deviations were identifie .0 Management Meetings The plant management was informed of the scope and purpose of this inspection at an entrance interview conducted on November 30, 1987. The findings of the inspection were periodically discussed with the licensee's cognizant representatives during the course of this inspection. The exit interview was conducted on December 4, 1987, at which time the findings of the inspection were presented (reference Paragraph 1 for attendees). The licensee did not indicate that any proprietary information was contained within the scope of this inspectio At no time during this inspection was written material provided to the licensee by the inspector . _ ._ __

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ATTACHMENT 1 I

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ADMINISTRATIVE PROCEDURES (ACPs) (AOPs)

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ACP-QA-2.02C, Work Orders, Rev. 15, September 21, 1987  !

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ACP-QA-2.02A, Installation Inspections, Rev. 14, September 21, 1987-ACP-QA-1.00, Quality Assurance -~ Quality Control Program, Rev. 9,

November 4, 1987

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ACP-QA-4.01A, System and Component Housekeeping, Rev. 2, September 21, 1987 ACP-QA-4.01, Plant Housekeeping, Rev. 15, October 6, 1987 -

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AOP 2560, Storms, High Winds or High Tides, Rev. 2, January 28, 1987

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ACP-QA-9.02B, Master Test Control List, Rev.12 l

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OPERATING PROCEDURES (ops)

1-OPS-10.09, Plant Equipment Check Log, Rev. 29, November 6, 1987

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ONP 5148, Freezing Temperatures, Rev. 2, March 4, 1987  :

OP2343, 4160 Volt Electrical System, Rev. 7, Change No. 6, July 31,1987 I t

OP3346A, Emergency Diesel, Rev. 2, Change No. 16, November 25, 1987 l

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j OP3338A, Radioactive Solid Waste, Rev. O, Change No. 7 l OP3351E, Access to CO2 Protected Area, Rev. O, Change 11, May 1987 i OP3341, Fire Protection Carbon Dioxide System, Rev. 2, Change 5, March 13, 1987 CALIBRATION SURVEILLANCE PROCEDURES (SPs)

l SP 412H, Core Spray Header Differential Pressure Switch Functional and Calibration Test, Rev. 7, April 23, 1986

q SP 412J, Core Spray System Automatic Actuation, Rev. 7, May 13, 1987 i l

SP 419B, Feedwater Regulation Valve Logic Test J

SP 412K, LPCI/ Containment Cooling System Logic Test, Rev. 5, June 4, 1987

! IC 450, Unit 1, Instrument and Control Department Training, Rev. 8, March 12, 1986

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Attachment 1 -2  !

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CALIBRATION SURVEILLANCE PROCEDURES (SPs) (Continued) ,

IC 450A, Instrument and Control Contractor / IMP Training, Rev. 1, t September 25, 1985

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IC 460A, Biennial Review of Instrumentation and Control Procedures,.

Rev. 1, September 25, 1985 -

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IC 490A, Training, Certification and Qualifications of Instrument and -

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Controls Personnel, Rev. O, September 25, 1987- '

IC 493A, Preparation, Review and Approval of Unit 1 I&C Procedures, Rev. 3, November 20, 1987 ,

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SP 1061, ISI Power Operated Valve and Check Valve Operability Program, Rev. 4, October 26, 1983 SP 412A, Reactor Low Pressure Valve Permissive Functional and Calibration '

Test, Rev 7, December 5, 1985 l

r SP 412C, Reactor Low-Low Water Level Functional and Calibration Test, Rev. 11, May 6, 1986 SP 4120, High Drywell Pressure Functional and Calibration Test, Rev. 6, '

December 30, 1986 SP 412G, Break Detection Valve Permissive Functional and Calibration Test, Rev. 8, March 12, 1986 SP 412GA, LPCI Break Detection Pressure Switch Calibration Test, Rev.1, June 18, 1986 i SP 621.10, Core Spray System Operability Test, Rev. 8, July 7, 1987

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SP 621.11, Core Sprcy Remote Valve Indication Check (ISI), Re January 25, 1984 l SP 622.7, LPCI System Operability Test, Rev. 12, September 22, 1986 ,

SP 622.8, LPCI System Remote Valve Indication Check (ISI), Rev. 1, January 25, 1984 SP 1060, l ISI Program Pump Vibration and Hydraulic Test, Rev. 8, i June 5, 1987 j

SP 2613C, Engineered Safety Features System (ESF) Integrated Test, Rev. 10, October 14, 1987 SP 3712T, Containment Penetration Overcurrent Device Surveillance Testing for Load Center Breakers, MCC, and Molded Case Breakers, Rev. 2, November 6, 1987

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. Attachment 1 3 CALIBRATION SURVEILLANCE PROCEDURES (SPs) (Continued)

SP 3712T-4, Containment Penetration Load and Current Test Tables, Rev. O, Change 2, January 4,1986 SP 2401E, Calibration of Excore Nuclear Instruments to Incores, Rev. 8, December 1, 1987 SP 24011, Local Power Density Test, Rev. 7, December 1, 1987 SP 4060, Main Steam Line Radiation Monitor Detector Calibration, Rev. 5 SP 2401K, High Power Trip Calibration, Rev 3, January 5, 1987 SP 2402B, Pressurizer Pressure Calibration, Rev. 5, December 7, 1986 SP 2402D, Steam Generator Level Calibration, Rev. 4, December 12, 1986 SP 2403B, ESAS Undervoltage Bistable Calibration, Rev. 4, December 8, 1986 SP 2403D, Containment Pressure Calibration, Rev. 5, October 16, 1986 SP 408C, Reactor Vessel Low Water Level Scram and Low-Low Level Isolation Functional and Calibration Test, Rev. 5 IC 400A-11, Condensate Storage Tank Level Calibration, Rev. 7, March 5, 1987 IC 400A-17, Reactor Vessel Wide Range Level Calibration, Rev. 6, August 3, 1987 IC 400A-27, "A" Steam Line Pressure Calibration, Rev. 4, July 6,1987 IC 400A-33, Reactor Core Pressure Drop Calibration, Rev, 3, May 29, 1987 IC 400A-48, Reactor Feed Pump Discharge Pressure Calibration (ISI), Rev. 2, July 23,1987 IC 400A-63, LPCI Minimum Flow Line Pressure Calibration (ISI), Rev. 3, April 11, 1987 IC 400A-83, LPCI Pumps Flow Calibration (ISI), Rev. 3, January 15, 1987

IC 400A-95, Reactor Pressure / Level Instrument Calibration, Rev. 2, !

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Attachment 1 4

$URVEILLANCE WORK ORDERS M3-86-07414, Panel 3RCP*PNL3A, Breaker F4K, 18 Month Surveillance Requirement M3-86-07418, Panel 3RCP*PNL3A, Breaker F3M, 18 Month Surveillance Requirement M3-86-07421, Panel 3RCP*PNL3B, Breaker R2M, 18 Month Surveillance Requirement M3-86-07469, Pressurizer Heater Backup, Heaters 36, 65 and 66 and Associated Breakers

. PLANT DESIGN CHANGE REQUEST (PDCR)

PDCR No. 1-98-86, Millstone Units 1/2, Appendix R, Backfeed Outage Work, November 1986 PDCR No. 2-87-86, EDG Auto. Start-Sequence Change, December 20, 1986 QUALITY ACTIVITY OBSERVATION REPORTS (QAOR, i.e., 0VALITY ASSURANCE SURVEILLANCE)

Unit 1 QAOR 187-14, May 19, 1987, Rod Block Monitor Functional Testing QAOR 187-21, June 23, 1987, Local Leak Rate Testing QAOR 187-26, July 9, 1987, Bolt Replacement on Motor Operators QAOR 187-44, July 30,1987, Revien of ILRT Procedure QAOR 187-52, December 2, 1987, Local Leak Rate Testing QAOR 187-54, September 16, 1987, ILRT Unit 2 QAOR 287-05, February 13, 1987, Review of Sealing and Seal Repair Electrical Cable and Piping Penetrations Procedure QAOR 287-06, February 26, 1987, Fire Penetration Seals

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Attachment 1 5 QUALITY ACTIVITY OBSERVATION REPORTS (QA0R, i.e., QUALITY ASSURANCE SURVEILLANCE) (Continued)

Unit 3 QA0R 387-07, March 6, 1987, Onsite Vendor Inspections of Snubbers QA0R 387-29, July 6,1987, Onsite Vendor Air Flow Measurement Testing QAOR 387-31, August 10, 1987, Receipt Inspection of Measuring and Test Equipment QA0R 387-37, October 22, 1987, Operations Procedures and Change Incorporation QAOR 387-42, November 10, 1987, 8 Diesel Generator Maintenance QAOR 387-49, November 21, 1987, Local Leak Rate Test Instrumentation Calibration Records OTHER DOCUMENTATION P&ID 25202-26008, SH 1, Core Spray, Low Pressure Coolant Injection, and Emergency Service Water System Composite, Re July 22, 1986 P&ID 25202-26008, SH 6, Core Spray System, Rev.1, July 22,1986 P&ID 25202-26008, SH 7, Core Spray System, Rev.1, July 22,1986 Licensee Letter B12750, November 19, 1987, Millstone Unit No. 3, Containment Penetration Conductor Overcurrent Protective Devices Licensee Letter B12754, November 24, 1987, Millstone Unit No. 3, Supplement Information - Containment Penetration Conductor Overcurrent Protective ,

Devices ll National Electrical Manufacturers Association (NEMA) Publications No. AB3, Molded Case Circuit Breakers and Their Application Stone and Webster Engineering Corporation, NERM-71, Rev. O, November 9, 1985, i Electrical Penetration Protection, Millstone Unit No. 3 Licensee Letter GEE-85-1737, October 1, 1985, MP-1/2 Appendix R Backfeed Connecticut Valley Electric Exchange (CONVEX) Operating Instruction No. 8601, Millstone 345KV Substation Salt Decontamination General Electric Molded Case Circuit Breaker Maintenance Manual, GET 279G EPRI Research Project Report RP2472-3, December 1986