IR 05000245/1992028

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Insp Repts 50-245/92-28,50-336/92-30 & 50-423/92-27 on Stated Dates.No Violations Noted.Major Areas Inspected: Plant Design Changes/Mod,Lers,Nonconformances,Audits & QA
ML20128E258
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 01/25/1993
From: Paolino R, Ruland W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128E225 List:
References
50-245-92-28, 50-336-92-30, 50-423-92-27, NUDOCS 9302100363
Download: ML20128E258 (8)


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U. S. NUCLEAR REGULATORY COMMISSION REGION 1 REPORT / DOCKET NOS. 50-245/92-28 50-336/92-30 50-423/92-27 LICENSE NOS.

DRP-21 DRP-65 NPF-49 LICENSEE:

Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06140-0270 FACILITY NAME:

Millstone Units 1,2, & 3 INSPECTION AT:

Corporate Office - East Berlin, Connecticut INSPECTION DATES:

November 6-10,1992 and November 16-20, 1992 INSPECTORS:

R. Bhatia, Reactor Engineer, Electrical Section, EB, DRS J. Zimmerman, Reactor Engineer, Electrical Section, EB, DRS

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R. J. fjholino, Sr. Reactor Engineer,

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Electrical Section, EB, DRS APPROVED BY:

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. .'Ruland, Ch'ief, Elec}dc[Section,

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~Date gineering Branch, DR7 Areas Insoected: Announced inspection to assess licensee's engineering support of various plant activities including plant design changes / modification, licensee event reports, non-conformances, audits, and quality assurance.

Results: Design changes and modifications reviewed were of good quality and technically accurate. Backlog reduction of engineering activities was progressing satisfactorily. Two unresolved items were identified. One item pertained to the adequacy of the engineering resolution for Audit No. A-30181, finding UOI-2, which involved the manual con'rol of emergency diesel generator ambient room temperature during seasonal changes. Manual temperature control was based on a once per shift monitoring of the non-vital fan system and the non-vital temperature indicator to maintain the 55 degree ambient temperature specified for the emergency diesel generator room. The second unresolved item concerned Audit No. A-30196, involving effectiveness and implementation of EQ related maintenance at all three Millstone sites.

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1.0 PURPOSE The purpose of this inspection was to assess the quality of the licensee's engineering activities, such as major / minor design changes and plant modifications, the technical evaluation report process and resolution, licensee event reports and review of corrective actions of previously identified open inspection items.

2.0 DESIGN C11ANGE AND PLANT MODIFICATION PROGRAM IMPLEMENTATION Major design changes are processed with the corporate group having the lead for overall design, design review and discipline specialty support, with the plant in a support role for procedure changes, testing, and turnover. Temporary modifications are also controlled by procedures and receive engineering review for technical adequacy and safety impact. A sampling of work orders and modifications processed in 1992 were reviewed to assure that maintenance activities had not resulted in design changes. No unintended design changes were identified. Sample plant design modifications (PDCRs) listed below include a variety of temporary and permanent changes to the electrical / mechanical systems, The modification packages and the installation of plant design changes were reviewed to verify that:

Modifications were reviewed end approved by the onsite and offsite review

committees.

Design changes and modifications were controlled by approved procedures.

  • Post-modification test procedures and results are adequately reviewed.
  • Station procedure modifications are made prior to the modification being declared

operable.

Operator training was conducted prior to declaring modification operable.

  • Marked-up copies of as-built drawings are distributed prior to declaring the

modification operable. Administrative controls were established to maintain as-built drawings.

Preventive maintenance and test programs were properly updated.

Installed modifications conformed with the design package.

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a Modification packages selected for review from each facility included:

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PDCR MP2-007-92, Revision 0. Replacement of station battery charger 201-B.

PDCR MP2-79 92, Revision 0. Addition of Condensate Storage Tank Nitrogen o

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Blanket.

e PDCR MP3-92-038, Revision 0. Installation of manual isolation valves upstream of steam generator blowdown sample isolation valve.

o PDCR MP3-92-105, Revision 0. Replacement of Limitorque (3 MSS *MOV18D)

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PDCR MP1-47-92, Revision 0. Valve (1-IC-30) replacement.

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PDCR MPI-97-92, Revision O. Replacement of existing fault detector relays

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50PW/7BG and 50PW/7PG.

PDCR MP1-46-92, Revision 0. Set point change for recombiner preheater pressure e

control valve.

PDCR MPl-85-92, Revision 0. Increase penetration conductor size for 1-IC-4.

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PDCR MP2-154-181, Revision 0. Encapsulation of safety related MCC's B51, B61,

& B52.

e PDCR MP2-152-92, Revision 0. RPS pressurizer pressure alarm modification -

PORV actuation logic reversal, PDCR MP2-078-92, Revision 0. ESAS ATI test window modification /SRAS logic o

modification.

Note: For these last two PDCR's the licensee has committed to satisfactorily comp 1ete all

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testing prior to restart.

The NRC inspectors determined the engineering basis for the above PDCRs was sound. Pre-operational tests conducted for the above modifications were thorough and detailed.

Administrative procedures were followed as applicable for the PDCRs review process and identified components in these packages. The inspectors determined that the drawings and the procedures update process associated with sample PDCRs were adequate. The safety evaluations were complete and considered well done. Material and equipment selected were

found to be suitable for the application, design inputs were incorporated and installed equipment complied with the QA procurement requirements and engineering specifications.

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The modifications were supported by calculations that were completed in accordance with l

applicable procedures and post modification test confirmed component function. Testing was found to be appropriate for the scope and nature of the design changes.

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In summary, the inspectors determined that the modifications were processed by both the site and corporate engineering groups in accordance_with a well defined program. The programs

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for completing the design modification and its implementation were generally of good

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j quality. The modification packages were complete, reviewed by authorized cognizant personnel and approved in accordance with established procedures and regulatory

requirements.

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3.0 NONCONFORMANCE CORRECTIVE ACTIONS s

l Procedure No. NEO 2.05, Revision 2, "Nonconformance Reports," is used for identifying, documenting, dispositioning, and approving the dispositioning for nonconforming materials, j

j parts, and components. In the field, the Non-Conformance Report (NCR) is not used to l

identify deficiencies but to provide engineering direction to the field when conditions adverse

to quality cannot be made to conform to requirements. Disposition categories of NCRs may include: Use-As-Is, Repair, Rework, Scrap, and Return to Supplier.

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The inspector selected six NCRs for review to determine whether these nonconformances were identified and dispositioned in accordance with established applicable procedures.

i Nonconformances reviewed for this determination included samples from each facility, as

follows:

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NCR No. 292-040, Undersized Motor Shaft at Bearing Seating.

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NCR No. 292-266, "As-found" VOTES Testing exceeds total thrust.

  • NCR No. 292-099, Seismic Qualification of Valves.
  • NCR No.192-097, Replacement of non-QA breaker MCC-E6-10.

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NCR No.192-089, Thrust exceeded.

j The inspector's review of the above NCRs determined that satisfactory implementation of the

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U NCR disposition action in accordance with applicable procedures was evident. The Quality Service Department's reinspection, verification and review of activities performed, as

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applicable, provided acceptable justification for closure of the above NCRs.

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4.0 ASSESSMENT AND STAFF SERVICES Northeast Utilities (NU) Quality Services Department (QSD), assessment and staff services audit program at Millstone was reviewed for its effectiveness and implementation at all three Millstone sites. The licensee's self-assessment programs consist of various engineering and

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plant activities, including a risk reduction task force, QA audits, surveillance and independent safety evaluation group review. The inspectors reviewed two audits performed by the assessment and staff service group that were conducted in 1992. Assessments were made in the following areas:

MP-2 Audit No. A-30181, MP-2 Diesel Ventilation System.

  • Open item UOI-2 of Audit No. 30181 questioned the design basis for a non-vital ventilation system used in controlling the specified 55 degree ambient temperature of the Diesel room.

This item was closed by the licensee based on engineering resolution calling for once per shift monitoring of the emergency diesel generator room ambient temperature and manual control of temperature regulating equipment as needed. The licensee was unable to provide support documentation regarding the ad quacy of the once per shift monitoring of the emergency diesel generator room ambient temperature in maintaining the 55 degree temperature during seasonal changes.

This item is unresolved pending NRC review licensee evaluation and corrective action (50-336/92-30-01).

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As a followup to Audit No. 30196, the licensee's EQ Master list (EQML) and Component Replacement Schedule (CRS) books for all three Millstone sites were reviewed. The EQML is plant specific and identifies electrical equipment or components which are required to be environmentally qualified for use in a harsh environment. The CRS books contain system component evaluation work sheets (SCEWS) which are composed of the following sections:

title block, environmental conditions and qualifications, references and notes. The EQML and CRS book are controlled and maintained in accordance with the NU Quality Assurance Program (NUQAP).

The MP sites use administrative control procedure, ACP-QA-2,16, " Nuclear Plant Environmental Qualification Program (NEQ 2.21)," to establish the NU Nuclear Plant Environmental Qualification Program. At each site, the maintenance, engineering and instrumentation & control (I&C) departments have controlled copies of the EQML and CRS book (s).

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The engineering department of Unit I was found to have missing SCEW sheets which could result in an EQ component exceeding its qualified life. At the time of the inspection, there was no formal transmittal process for SCEW sheets in place. The person responsible for the engineering CRS book receives any changes or updates, and sends the copies to the designated personnel in maintenance and I&C.

The engineering department of Unit 2 was found to have SCEW sheets that were changed and not formally updated into the CRS books. In one case, a SCEW sheet was changed in 1989 through an informal transmittal from the corporate EQ department. At the time of the inspection, the SCEW sheet had not been updated to reflect the change made to the qualified life. The engineering department relied upon the informal transmittal data when determining the qualified life rather than the information found on the SCEW sheets in the CRS book.

The CRS books for the Unit 3 engineering department were found to be complete and up-to-date. Unit 3 had an interim tracking system in place to ensure that SCEW sheets which were in the process of being updated provided guidance as to the proper qualifications for electrical equipment or components. This information was printed weekly and reviewed by maintenance until the completed SCEW sheet was issued. At the time of the inspection, no interim tracking system similar to Unit 3's was available for Units 1 and 2.

The Audit No. A-30196 resulted in similar findings. The audit identified five open items, citing examples of discrepancies found in component replacement schedules, requirements not being incorporated into the PMMS data base, and conflicting time requirements for EEQ related maintenance between the Component Replacement Schedule and the PMMs.

This item is unresolved pending NRC review of the licensee's evaluation of the audit report deficiencies, the extent of the problem, and the adequacy of corrective actions (50-245/92-28-01,50-336/92-30-02 and 50-423/92-27-01).

5.0 LICENSEE EVENT REPORTS Licensee Event Reports (LER) were reviewed for root cause, safety significance determinations, and adequacy of corrective action. The inspectors determined that further information was not necessary and verified that the reporting requirement of 10CFR50.73, Station Operating Procedures, and Technical Specificalicns 6.6 and 6.9 had been met. The following LER's were reviewed:

LER 50-423/92-005-00, Failure to Notify MRC of Ct.ange to FSAR Chapter 14.

e LER 50-423/92-020-00, Both Traim, of Auxiliary Filter Inoperable.

e LER 50-336/92-006-00, Containment Isolation Valve Design Deficienc ___ ___ _ __ ____ _ _ _ _ _ -__ _ _ - ____ _ __ _ _ _

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LER 50-336/92-010-00, Main Steam Safety Valve Setpoint Drift Discovered During

As-Found Simmer Test.

  • LER 50-245/92-016-00, RPS EPA Overvoltage Relays Out-Of-Tolerance.

6.0 STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS (Closed) Unresolved Item No. 50-245/91-020-001 pertaining to discrepancies identified in the EQ Master List, Revision 4, dated Jar.uary 20,1991. The terminology used in listing the limit switches and solenoid valves was identical. In addition, the EQ Master List did not identify all of the containment isolation valves.

The inspector reviewed the EQ Master List, Revision 5, dated January 22,1991, and the current EQ Master List, Revision 6, dated July 13,1992. The EQ Master List, Revision 6, had been fully revised to address the unresolved issue. The terminology had been corrected and the missing isolation valves had been added to the list. This item is closed.

7.0 UNRESOLVED ITEMS Unresolved items are matters needing more information to determine whether an item is acceptable or a violation. Unresolved items are identified in Paragraph 4.0.

8.0 EXIT MEETING The inspectors met with licensee representatives (listed in Attachment A) at the conclusion of the inspection on November 20,1992. The inspector summarized the scope of the inspection, the inspection findings.

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ATTACilMENT A Persons Contacted Northeast Utility Service Comc_ any

+* J. F. Bibby, Managet Nuclear Project Service (MP-2)

- G. E. Carlin, Supervisor Project Services (MP-1)

W. M. Cushmann, Engineer (MP-1)-

J. T. Harris, Director, Engineering Department R. M. Kacich, Director, Nuclear Licensing B.- S. Kaufmann, Supervisor Quality Services

+* R. L. McGuinness, Supervisor Nuclear Licensing M. S. Watkins, Senior Engineer

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M. J. Wilson, Supervisor Nuclear Licensing

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H. H. Wong, Supervisor Cost & Scheduling -

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R. S. Peterson, Senior Licensing Engineer H. P. Risley, Directot Project Services

A. R. Roby, Manager Electrical & I/C Engineering

+ - T. B. Silko, Licensing Engineer B. J. Smith, Engineering Technician

R. J. Young, Supervisor Electrical (MP-3)

U.S. Nuclear Regulatory Commission A.- Lohmeier, Senior Reactor Engineer (R-1)

NOTE:

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identifies personnel present at exit meeting of November 20,1992.

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sign identifies personnel present at mini-exit meeting of November 6,1992.

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