IR 05000245/1993020
| ML20056H251 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/27/1993 |
| From: | Cheung L, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20056H245 | List: |
| References | |
| 50-245-93-20, NUDOCS 9309090048 | |
| Download: ML20056H251 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
f REPORT NO.
50-245/93-20 i
DOCKET NO.
50-245 LICENSE NO.
DPR-21 LICENSEE:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06141-0270 FACILITY:
Millstone Nuclear Power Station, Unit 1 l
l INSPECTION DATES:
July 19-23,1993 INSPECTOR:
Leonard Cheung, Senio - ca : tor Engineer Date / '
Electrical Section, EB DR 5 27
APPROVED BY:
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. H. Ruland, Chief,/$lecfrical'Section
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- ngineering Branch, DRS 9309090048 930901~
PDR ADDCK 05000245 O
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Area insoccted: Announced inspection to review the licensee's corrective action on previously identified inspection findings.
Results: One violation was identified during this inspection. This item is discussed in paragraph 2.6. Of the eight open items reviewed, four items were closed; the other four were updated. The status of these eight items is summarized as follows:
Discussed in item No.
Iilk Paragraph Status 91-81-06 Inadequate Design Review 2.7 Open of MOV l-IC-04 Power Feed 91-81-07 Inadequate Onsite Supply 2.3 Closed of EDG Fuel 91-81-08 Procedure for Operating 2.1 Closed Switchgear HVAC 91-81-09 Unqualified Cooling Coils 2.4 Open for EDG Room 91-81-11 Gage Calibration in EDG 2.5 Closed i
Air Start System 91-81-12 Biennial Review of 2.6 Open Station Procedures 91-81-13 Battery Sizing Criteria 2.2 Closed 91-81-15 Periodic Testing of MCCBs 2.8 Open
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DETAHS 1.0 PURPOSE The purpose of this inspection was to review and verify licensee corrective adions for
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inspection findings identified during the September 1991 Electrical Distribution System Functional Inspection (EDSFI) for Millstone Unit 1. The review included the licensee's actions addressed in their written response dated February 10, 1992, to the Notice of Violation contained in the EDSFI report.
2.0 STATUS OF PREVIOUSLY IDENTIFIED INSPECTION ITEMS 2.1 (Closed) Violation 91-81-08 pertaining to lack of approved procedures for operating t
the heating, ventilation and air conditioning (HVAC) system of the switchgear area.
The original steam heating coils were removed from the HVAC system in 1990 due to high energy line break concerns. No replacement for the steam coils was provided and no approved procedures were established by the licensee to maintain design room temperatures in the winter. The licensee believed that the heat generated by the electrical equipment is l
adequate to provide room heating, and normally ventilation is required to cool the room to desirable temperature. Corrective actions taken by the licensee involved revising procedure OP 327, " Heating, Ventilation and Air Conditioning," and operator temperature logs (OPS
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Forms 696.2-3 and 696.2-1); and the installation of thermometers in the emergency diesel generator (EDG) rooms, battery rooms and 125 Vdc and 24 Vdc switchgear areas. The operators are required to verify that the temperatures in these areas are within design limits once a shift, except the EDG rooms, which are checked twice a shift. If the temperature at any area is found to be unacceptable, OP 327 stops and starts the ventilation unit to correct
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the temperature. After reviewing the revised procedure during this inspection, the inspector
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raised the concern that the battery room temperature might drop below the design i
temperature of 60"F, as there was no margin between the acceptable temperature and the design temperature, and battery room B has two outside walls causing heat losses. The temperature logs can be taken at a maximum interval of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> between shifts. In i
response to the inspector's concern, the licensee provided the temperature logs of the last two winters covering January and February of each year. The inspector found that the minimum temperature recorded was 67"F. The licensee also revised the temperature logging frequency from once a shift to twice a shift.
The licensee is in the process of adding high and low temperature alarms to then areas, eliminating the need for operator surveillance. The design changes for the EDG rooms (PDCR l-99-92) are scheduled to be completed in January 1994, and the design changes for the other areas (battery rooms, battery charger areas) are scheduled for completion in July 1994.
The inspector considered the licensee's corrective actions adequate. This item is closed.
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2.2 (Closed) Unresolved item 91-80-13 pertaining to battery sizing criteria and battery operating procedures.
l During the September 1991 inspection, it was identified that the UFSAR and the Technical Specifications contained inconsistent battery sizing criteria (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> vs. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). Subsequent
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to the inspection Endings, the licensee conducted an evaluation in late 1991, and determined that both batteries A and B should have 2-hour duty cycles. This evaluation was documented in Millstone 1 Change Serial No. 91-MPI-6, " Technical Review, Corrections and Changes to Millstone Unit 1 FSAR Section 8.3.2," dated October 4,1991. This 2-hour duty cycle is i
consistent with the Technical Speci6 cation requirements. The licensee revised the FSAR accordingly and submitted the changes to the NRC on March 31,199'
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The September 1991 inspection also addressed the concern of load stripping requirements.
The inspector reviewed operations procedures OP 344A, "125 Vdc Electrical System,"
Revision 26, and ONP 503C, "Imss of Offsite AC Power (Station Blackout)," Revision 6.
The procedures explicitly speci5ed the load stripping requirements (paragraphs 2.3.1 through
2.3.3 of ONP 503C and paragraphs 5.9 and 5.11 of OP 304A).
The licensee also revised the battery loading calculation (PA90-105-318 El dated June 3,1993, which supersedes PA83-068-221 GE, Revision 1). This calculation provides 2-hour loading pro 61es for batteries A and B.
The inspector considered the licensee's corrective actions to be adequate. This item is closed.
2.3 (Closed) Violation 91-87-07 regarding inadequate onsite supply of fuel for the emergency diesel generator.
The licensee's corrective actions involved revising the fuel tank calculations and fuel level procedures. Although the licensee stated in their response to the Notice of Violation that calculation 90-105-797 ES and the procedure revision were completed before the end of February 1992, the inspector's review of these documents during this inspection indicated that there were inconsistencies between the calculation and the procedures. Subsequently, the licensee revised calculation 90-105-797 ES twice and the procedure once. The latest versions of the calculation and procedures indicated that the licensee has provided adequate administrative control to maintain the fuel storage tank level above 113 in., which provides a
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usable amount of fuel greater than the Technical Speci6 cations requirement of 23,400 gallons (5-day diesel fuel). The inspector reviewed: 1) calculation 90-105-797 ES, " Minimum Available Fuel Oil Volume," Revision 1, dated July 23,1993, and Revision 2, dated July 30,1993; and 2) temporary changes to Procedure SP 668.8, " Gas Turbine and Diesel Fuel Inventory," Revision 9, and Procedure OP 338, " Standby Diesel Generator,"
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Revision 31, and t
determined the licensee's corrective actions to be adequate. This item is closed.
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2.4 (Open) Violation 91-81-09 regarding the use of unqualified cooling coils for the replacement of safety--related EDG room cooler.
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Subsequent to the September 1991 EDSFI, the licensee evaluated the seismic qualification of the cooling coils in air handling units HVH-1 and HVH-2, in an effort to upgrade the cooling coils to safety grade. A consultant (Stevenson & Associates) was hired for this effort. The evaluation determined the cooling coils to be seismically quali6ed. The detail of the upgrade
process and system walkdown were discussed in NRC inspection reports 50-245/91-24 and
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50-245/91-16.
t In their response to the Notice of Violation, the licensee committed to perform two veri 6 cations:
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Identify all heating and ventilation equipment in the Production Maintenance a.
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Management System and verify the QA classification; and
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For all heating and ventilation equipment that is, or will be evaluated as, QA Category 1, verify that no non-QA work or modifications have been performed on this equipment.
The licensee hired EBASCO to cover these verifications. EBASCO's effort identified additional components in air handling units HVH-3A, HVH-4A, and HVH-5 that were found to be non-QA items. These items are:
HVH Unit Non-OA Component or Work HVH-3A Replaced fan motor; repaired floating base weld HVH-4A Replaced inboard and outboard shaft bearing; rebuilt shaft i
HVH-5 Replaced motor sheave, motor bearing and fan sheave (pulley)
The licensee was in the process of upgrading these items to safety grade by evaluation. The licensee stated that this effort would be completed by September 30,1993.
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This item remains open pending NRC veri 6 cation that the upgrade of the above equipment to safety grade is complete.
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2.5 (Closed) Unresolved item 91-81-11 pertaining to lack of calibration requirements of the pressure gages in the emergency diesel generator air starting system.
The pressure gages PI-33-7 and PI-33-10 are used to confirm the operability of the air starting system check valves. The licensee included the calibration requirements of these gages in station procedure IC-400A, " Calibration of Instruments Used to Satisfy Technical i
Specification Requirements and/or Computer Core Performance Calculation Inputs,"
Revision 14. The inspector reviewed procedure IC-400A and confirmed that page 400A-109
specified the calibration tolerance of these two gages. The inspector also reviewed the data sheets of the calibrations performed on August 21,1992, and found them to be in accordance j
with the procedure. This item is closed.
l 2.6 (Open) Violation 91-51-12 pertain *ng to failure to perform biennial review of station procedures.
During the September 1991 EDSFI, it was identified that over 100 station procedures had not received biennial reviews as required by Administrative Procedure ACP-QA-3.02D. In their j
response to NRC's Notice of Violation, the licensee stated that this deficiency would be
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corrected and full compliance with ACP-QA-3.02D would be achieved by l
December 31,1992. Dur:ng this inspection, a review of the latest Quarterly Status Report (MP-93-377, dated May 10, 1993) found that there were more than 200 station procedures whose bien'iial reviews were overdue. Some of these procedures did not receive. reviews for more than hree years (last review date - August 1989).
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The licensee stated that they were implementing a procedure upgrade program with l
considerable engineering resources expended in upgrading station procedures. The licensee also stated that the unreviewed procedures would be reviewed before they were allowed to be used.
On February 28,1992, the licensee revised ACP-QA-3.02D to allow alternate methods of documenting the biennial review as follows:
"If it is not desirable to implement the revision, perform the following:
Indicate on SF 364, Documentation of Biennial Review, that the review was a.
performed and a revision is required prior to use.
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Prepare a memo to controlled copy holders to stamp the cover sheet of the procedure, 'DO NOT USE'.
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Present the completed SF 364 to PORC/SORC for approval.
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Forward the SF 364 to the of6ce supervisor to update the Biennial Review Index and distribute the memo."
l The electrical maintenance department at the station used a special process to handle those
procedures whose biennial reviews were overdue. They pr yate a "DO NOT USE" procedure (to satisfy item b.
coversheet and attached a copy of this sheet to each ovt m
above). However, item a., c., and d. were not accomphsned. Therefore, this process still did not comply with procedure ACP-QA-3.02D.
This deficiency was identified by the NRC almost two years ago. During the past two years, the number of overdue station procedures actually increased. The inspector determined that lack of prompt corrective actions to resolve the deficiency of failure to comply with the procedural requirements constitutes a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, which states, in part, " Measures shall be established to assure that condition adverse to quality, such as failures, malfunctions, deficiencies,..... and nonconformances are promptly identified and corrected." (50-245/93-20-01)
i 2.7 (Open) Violation 91-81-06 pertaining to inadequate design review of a design
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i change (PDCR 1-94-80) to the electrical penetration for the power feed of MOV 1-IC-4.
The original modification was performed in 1980. Inspection report 91-81 indicated that three corrective actions were r quired to resolve this issue: 1) modify the electrical penetration for MOV l-IC-4 'o comply with criteria established by the Systematic Evaluation Plan (SEP) an.tlysis; 2) prepare a controlled calculation to document the analysis performed for Fu Topic Vill-4 analysis; and 3) prepare a design basis document to be utilized for i
future modiCations affecting electrical conductors of containment penetrations. The inspector reviewed the licensee's corrective actions completed so far. For item 1, the licensee generated plant modi 6 cation PDCR-1-85-92, " Increase Penetration Conductor Size for 1-IC-4." The inspector determined that the PDCR package contained adequate design j
review, including the safety evaluation. The plant modification was completed in July 1992.
J For item 3, the licensee generated a document entitled " Electrical Penetration," which included electrical conductor sizing criteria for the penetration, dated November 2,1992.
This document was included in " Millstone Unit 1 Design Basis Document Package." The electrical conductor sizing criteria used in this document were the same as used in the SEP.
The inspector considered the licensee's corrective action for items I and 3 to be adequate.
Discussion with the licensee indicated that completion of item 2 depends on the result of the short-circuit calculations which is part of the licensee's computer program called " OPAL."
The licensee expects the "OPA1 " program to be completed by December 1993.
This item remains open pending NRC review of licensee actions for item 2 above.
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2.8 (Open) Unresolved Item 91-81-15 pertaining to lack of periodic testing of molded case circuit breakers (MCCB).
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In their response to NRC's concern during the September 1991 inspection, the licensee stated that they had developed Procedure Irr-1421B for testing MCCBs. However, the periodic test program was not yet implemented. As part of a pilot program, the licensee tested approximately 12 existing and all new MCCBs during the 1991 refueling outage, when the EDSFI was taking place. The licensee's schedule was to implement the test program during the next refueling outage, originally scheduled for March 1993, but rescheduled to January 1994 due to some mini-outages. Discussion with the licensee indicated that this
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program was being transferred from the General Test Service department to the Electrical Maintenance department. New test procedures have yet to be developed by the Electrical Maintenance department. The licensee targeted the full implementation date of this program to be December 31,1993, and the starting date of breaker testing during the January 1994 refueling outage. This revised schedule still meets the original verbal commitment by the licensee during the EDSFI.
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This item remains open pending NRC's verification of the licensee's implementation of MCCB periodic test program.
I 3.0 EXIT MEETING The licensee management was informed of the scope and purpose of the inspection at the entrance meeting on July 19, 1993. The findings of this inspection, specifically, failure to complete biennial reviews of station procedures, and the status of previously identified items, were discussed with the licensee representatives during the course of the inspection and
presented to licensee management during the exit meeting on July 23,1993. The licensee did not dispute the inspection findings during the exit meeting. A list of attendees is
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presented in Attachment 1.
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ATTACHMENT 1
i Persons Contacted N. Bergh Unit 1 Maintenance Manager T. Cleary Licensing Engineer
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G. Cornelius PSD Supervisor R. Ewing PSD Electrical Engineer
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S. Frankhauser PSD Mechanical Engineer
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K. Murphy Unit 1 Electrical Engineering G. Van Noordennen Licensing Supervisor D. Vail PSD Electrical Engineering Supervisor l
All of the above personnel attended the exit meeting on July 23,1993.
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