IR 05000336/1979004
| ML19289E845 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/27/1979 |
| From: | Baunack W, Kister H, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19289E839 | List: |
| References | |
| 50-336-79-04, 50-336-79-4, NUDOCS 7905290166 | |
| Download: ML19289E845 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-336/79-04 Docket No.
50-336 Licenst No. DPR-65 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 2 Inspection at:
Waterford, Connecticut Inspection conducted:
February 20-23, 1979 Inspectors:
k k bafvwh 3[3
~7 9 R. P., Z e,an, Reactor I spector ddte s'igned h ) k L cu d sh,h9 Y. H.'Baunac, Reactor Inspect r
'dat6 signed 7!79
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0 P. D. Graham Reactor Inspecjtor
'd te signed d.17 /7 7 Approved by:
)f. B. Kistdr> Chief, Nuclear Support
' date/ sign'ed Section No. 2, RO&NS Branch Inspection Summary:
Inspection on February 20-23, 1979 (Report No. 50-336/79-04)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors of licensee action on previous inspection findings; administrative controls of facility procedures; format and technical content of facility procedures; pro-cedure revisions resulting from Technical Specification Amendments; procedure revisions made in accordance with 10 CFR 50.59(a) and (b); temporary procedure changes; administrative control of safety related calibrations, surveillance calibration of safety related components and equipment required by Technical Specifications; calibration required by Technical Specifications of components and equipment associated with safety related systems and/or functions; calibra-tion and control of test equipment; technician qualification; and facility tour.
The inspection involved 65.5 inspector-nours onsite by three NM. regional based inspectors.
Results:
No items of noncompliance were identified during this inspection.
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^708 Region I Form 12 7905290166 (Rev. April 77)
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DETAILS 1.
Persons Contacted Northeast Nuclear Energy Company G. Closius, Quality Control Engineer
- E. Farrell, Superintendent, Unit 2 B. Grillo, Instrument Specialist
- H. Haynes, Instrument and Control Supervisor J. Heg, Shift Supervisor J. Kelly, Operations Supervisor B. Loomis, Instrument Specialist J. Moffatt, Assistant Operations Supervisor
- J. Opeka, Station Superintendent R. Spiess, Instrument Specialist A. Strong, Shift Supervisor USNRC
- T. Shedlosky, Resident Reactor Inspector The inspector also interviewed other licensee employees, in-cluding instrument technicians, control room operators and general office staff.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (336/78-30-01):
By review of procedure changes to SP 2601A, SP 2601B, the PDCR checklist, and discussions with personnel, the inspector verified that corrective action has been taken as stated in the licensees response to this item of noncompliance dated November 8,1978.
(Closed) Unresolved Item (336/78-30-02):
Procedure ACP-QA-3.03, Document Control, Revision 8, December i, 1978, specifies the method by which P&ID's are kept current for the interim between when a modification has been completed and a new revised print is issued.
Control Room copies of P&ID's were verified to have been updated as required by ACP-QA-3.03.
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(Closed) Noncompliance (336/78-30-03):
Surveillance Procedure 2605A was verified to have been revised to include containment isolation valves 2-AC-46 and 2-AC-51.
(Closed) Noncompliance (336/78-31-01):
Failure to include re-quired documentation on Maintenance Request.
ACP-QA-2.03 was verified to have been revised to include the requirement to document the functional check.
On a sampling basis, the inspector reviewed MR's for safety-related activities, completed since January 1, 1979, to confirm that the required documentation existed on the MR's.
(0 pen) Unresolved (336/73-31-02):
Record retention of MR's for safety-related activities.
ACP-QA-2.03 has been revised requiring a carbon copy of all MR's to be maintained on file for a six year period.
Upon a sample review of completed MR's since January 1, 1979, the inspector noted that various carbon copies were difficult to read in places, and one copy which was illegible in the space provided for description of work performed.
The li-censee representative stated that the problem may be due to the original MR being filled out with a felt tip pen, vice a ball point pen.
The licensee representative further stated that a memorandum will be issued requiring all MR's to be filled out with a ball point pen.
In the case where the carbon copy of a MR was illegible in part, the original was produced providing the appiopriate description of work performed.
This item remains unresolved pending licensee action and subsequent NRC:RI review.
(Closed) Noncompliance (336/78-31-03):
Failure to identify com-ponents to be covered by the Quality Assurance Program.
The Category I Material, Equipment and Parts L1st (MEPL), was verified to have been revised to include the internal parts set forth in the item of noncompliance.
The inspector reviewed the procedure entitled, The Determination of QA Category I Applicability for Inservice Nuclea: Units, Revision 0, November 28, 1978.
The pro-cedure requires an evaluation, to be performed by the Engineering Department, to determine whether or not replacement parts in a Category I component should be identified as QA Category I based on their function in the component, potential failure modes and whether or not failure could cause Category I equipment to mal-function when needed.
The inspector reviewed all evaluations performed since January 1,1979, and concurred with the findings.
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3.
Administrative Controls for Facility Procedures Administrative controls w're reviewed to determine the licensee's system for implementing requirements associated with the control of facility procedures as specified in Technical Specification, Section 6; and, ANSI N18.7, " Administrative Cantrols for Nuclear Power Plants." Areas of emphasis were in the established controls for format, content, review (including periodic review), and approval of facility procedures.
The following documents were reviewed:
Administrative Control Procedure (ACP) - Quality Assurance
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(QA) - 3.01, ACP's and Station Forms, Revision 4, August 17, 1978.
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ACP-QA-3.02, Station Procedures and Forms, Revision 8, January 5, 1979.
ACP-3.02B, Listing of Unit 2 Station Procedures, Revision 2,
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December 1,1978.
ACP-QA-3.05, Review and Approval of Vendor Procedures, Re-
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vision 3, October 31, 1978.
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ACP-8.09A, Change and/or Revision Review, Revision 1, October 20, 1978.
No items of noncompliance were identified.
4.
Technical Content of Facility Procedures a.
Facility procedures were reviewed on a sampling basis using FSAR System Descriptions, Piping and Instrument Diagrams and Technical Specifications, where necessary to verify that pro-cedures were sufficiently detailed to control the operation or evolution described within Technical Specification Requirements.
The procedures reviewed with respect to this area are marked by an asterisk (*) in the next paragraph (Paragraph 5, Review of Facility Procedures).
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b.
During the review of the procedure for Loss of Shutdown Coolins,.
located in Section 8 of OP 2310, Shutdown Cooling, Revision 3, November 9,1978, it was noted that only a partial loss of shutdown cooling is addressed.
The procedure considers loss of one of two Low Pressure Safety Injection pumps. A total loss of shutdown cooling is not covered by a procedure.
The licensee representative acknowledged the inspector's concern and stated that the procedure will be revised to include the condition of a total loss of shutdown cooling by April 1, 1979. OP 2310 will be reviewed by NRC:RI following the revision date.
5.
Review of Facility Procedures a.
Facility procedures were reviewed on sampling basis to verify the following:
Procedures, plus any changes, were reviewed, approved and
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retained in accordance with the requirements of the Technical Specifications and the licensee's administra-tive controls;
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The overall procedure format and content were in con-formance with the requirements of the Technical Speci-fications and ANSI N18.7, " Administrative Controls for Nuclear Power Plants";
Checklists, where applicable, were compatible with the
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step-wise instructions in the procedures; Appropriate Technical Specification limitations had been
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included in the procedures; and,
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Temporary changes were made in conformance with Technical Specification requirements and the licensee's admini-strative controls.
(This temporary change review included procedures in addition to those listed below).
b.
The following procedures were reviewed:
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Administrative Procedures
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ACP-QA-2.03, Performing Non-category I Work, Revision 3, February 1, 1979.
ACP-QA-3.03, Document Control, Revision 8, December 1,
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1978.
General Plant Operating Procedures
-* Operating Procedure (0P) 2205, Plant Shutdown, Revision 4, April 18, 1978.
-* OP 2206, Reactor Shutdown, Revision 3, June 5, 1978.
-* OP 2204, Load Changes, Revision 3, April 18, 1978.
OP 2207, Plant Cooldown, Revision 6, June 5, 1978.
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System Operating Procedures OP 2304A, Volume Control Portion of the Chemical and
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Volume Control System, Revision 4, October 17, 1978.
OP 2309, Containment Spray, Revision 4, October 27,
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1977.
-* OP 2307, Low Pressure Safety Injection, Revision 4, December 11, 1978.
OP 2316A, Main Steam System, Revision 7, October 24,
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1978.
-* OP 2326A, Service Water System, Revision 3, November 6, 1978.
OP 2330A, Reactor Building Close6 Cooling Water System,
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Revision 4, July 25,1978.
Emergency Procedures EP 2508, Loss of Reactor Build'.ng Closed Cooling Water,
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Revision 2, February 16, 1977.
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-* EP 2518, Loss of Service Water, Revision 2, July 31, 1978.
EP 2509, Steam Line RuptJre, Revision 2, June 29,1976.
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EP 2519, Electrical Emergency (Loss of Main DC Bus),
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Revision 0, September 18, 1975.
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OP 2321, Feedwater System, Revision 4, August 7,1978.
(Loss of Feedwater, Section 8)
-* OP 2310, Shutdown Cooling, Revision 3, November 9, 1978.
Alarm Response Procedures Alarm procedures are incorporated within the format and con-tent of System Operating Procedures, and were reviewed con-currently with the respective procedures identified above.
Maintenance Procedures
-* MP 2719B, Removal and Installation of Diesel Exhaust Manifolds, Revision 0, January 18, 1977.
MP 2720F1, Battery Inspections, Revision 0, April 29,
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MP 2736A, Battery Pilot Cell Surveillance, Revision 1,
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September 27, 1976.
MP 2721F, Repair of Service Water Piping, Revision 2,
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October 28, 1978.
-* MP 27308, Main Steam Safety Valve Testing, Revision 0, March 28, 1978.
Surveillance Procedures
-* SP-2620A, CEA's Partial Movement, Revision 3, January 5, 1979 (including OPS Form 2620A-1, Rcvision 1, April 8, 1979.
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-* SP 2619A, Control Room Shift Checks, Revision 2, June 14, 1977, (including OPS Form 2619A-1, Revision 13, February 5,1979).
-* SP 26190, Startup Surveillance Checklist, Revision 0, August 8,1975.
c.
During the above review, the following conditions were noted by the inspector:
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Technical Specification Amendment 38, in part, omitted
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requirements concerning part length CEA's to reflect a plant modification which removed part length CEA's from the core. Three procedures, OP 2204, SP 2620A and SP 2619D, still referenced part length CEA's in the acceptance criteria portion of the procedures.
OP 2205, precaution step 4.5 stated that four reactor
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coolant pumps must be in service whenever reactor power is greater than 5%.
However, Technical Specifications require four pump operation whenever the reactor is cri tical. The inspector noted that conformance with Technical Specifications, concerning reactor coolant pump operability requirements was satisfied in the step by step plant shutdown and startup procedure.
The licensee representative acknowledged the inspector's findings.
By the conclusion of the inspection, procedure changes were instituted removing reference to part length CEA's from the procedures noted above, and bringing precaution step 4.5 of OP 2205 into conformance with Technical Specifications.
No items of noncompliance were identified.
6.
Procedure Changes Resulting from Technical Specification Amendments The inspector reviewed Licensee Amendments 33, 37, 38, 39, 45 and 46, and verified that applicable procedures were revised as necessary to reflect the changes to the Technical Specifications.
No items of noncompliance were identified.
Results of the review concerning License Amendment 38 are addressed in paragraph 5.c.
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7.
Changes to Procedures as Described in the Safety Analysis Report Pursuant to 10 CFR 50.59 a and b
a.
The inspector reviewed licensee records to identify changes to procedures which are described in the Final Safety Analysis Report (FSAR) and to verify thht these changes, if any, were reviewed and maintained by the licensee in accordance with 10 CFR 50.59(a) and (b).
Records reviewed were associated with the procedures noted in the previous paragraph (Paragraph 5, Review of Facility Procedures) and included the licensee's procedure history file.
Of the procedures / changes to procedures sampled, the inspector did not identify any change to procedures as described in the FSAR.
It was noted that the licensee has established admini-strative controls for such changes and that these controls do not conflict with 10 CFR 50.59 requirements.
No items of noncompliance were identified.
8.
Administrative Control of Safety Related Calibrations The inspector reviewed the licensee's administrative procedures relating to the performance of calibrations of safety related components as a basis for reviewing test procedures and calibra-tion data sheets.
The following procedures were reviewed.
ACP-QA-1.02, Organization and Responsibilities, Revision 4,
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February 8,1979.
ACP-QA-3.03, Document Control, Revision 8, December 1,1978.
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ACP-QA-3.02, Station Procedures and Forms, Revision 8, January
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5, 1979.
ACP-QA-9.02, Plant Surveillance Program, Revision 5, November
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13, 1978.
ACP-QA-9.04, Control and Calibration of Measuring and Test
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Equipment.
IC-2429A, Calibration of Instrumentation not covered by Technical
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Specifications but used to Satisfy Technical Specification Requirements - Operating, Revision 0, January 8,1977.
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IC-24298, Calibration of Instrumentation not covered by Tech-
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nical Specifications but used to Satisfy Technical Specifica-tion Requirements - Shutdown, Revision 1, April 19,1977.
No items of noncompliance were identified.
9.
Surveillance Calibrations of Safety Related Components and Equipment Required by Technical Specifications a.
The inspector reviewed calibration procedures and associated data sheets on a sampling br. sis to verify the following:
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Calibration frequency requirements have been met;
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Applicable system status during component calibration was
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in conformance with the Technical Specification limiting conditions of operation; Procedure format provided detailed stepwise instructions;
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Procedure review and approval were as required by Technical
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Specifications; Trip points of calibrated components were in conformance
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with Technical Specification requirements; and, Technical content of procedures was sufficient to result
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in satisfactory calibration.
b.
Tht. following calibration procedures / data were selected for the above review.
Procedure No. SP-240lJ, Thermal Margin / Low Pressure
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Calculator Test, Revision 0, January 19, 1979.
Data was reviewed for five calibrations performed September 28, 1978 through January 25, 1979.
Procedure No. SP-240lM, Reactor Protection System Core
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Protection Calculator Calibration, Revision 1, January 19, 1979.
Data was reviewed for calibration performed February 22, 1978.
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Procedure No. SP-240lK, High Power Calibration, Revision
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0, December 7, 1978.
Data was reviewed for calibrations
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performed April 8, 1978, July 21, 1978, October 18, 1978, and January 9, 1979.
Procedure No. SP-240lF, RPS Hi-Power Trip Test, Revision
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0, December 7, 1978.
Data was reviewed for seveu tests performed August 7,1978 through February 5,1979.
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Procedure No. SP-2407, In Core Detector Assembly Instru-mentation Calibration, Revision 0, January 4,1979.
Data was reviewed for calibration performed April 16, 1978.
Procedure No. SP-2402E, Pressurizer Level Instrument
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Calibration, Revision 0, February 16, 1979.
Data was reviewed for calibration performed January 27, 1978.
Procedure No. SP-2403A, ESAS Bistable Trip and Auto-Test
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Inverter Test, Revision 0, January 10, 1979.
Data was reviewed for tests performed October 10, 1978, November 8,1978, December 13, 1978, and January 10, 1979.
Procedure No. SP-2403D, Containment Pressure Calibration,
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Revision 0, June 31, 1978.
Data was reviewed for test performed December 1,1977.
Procedure No. SP-2402B, Pressurizer Pressure Calibration,
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Revision 1, January 4, 1979.
Data was reviewed for test performed November 21, 1977.
Procedure No. SP-240lG, RPS Bistable Trip Test, Revision
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0, July 25,1978.
Data was reviewed for five tests performed October 4,1978 through February 5,1979.
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Procedure No. SP-2402D, Steam Generator Level Caiibration, Revision 2, March 22,1976.
Data was reviewed for test performed January 13, 1978.
Procedure No. SP-2404R, Containment Particulate Process
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Radiation Monitor Calibration, Revision 2, January 23, 1976.
Data was reviewed for calibration performed August 22, 1978.
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Procedure No. SP-2404G, Containment Process Radiation
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Monitoring Instruments Functional Test, Revision 0, January 4, 1979.
Data was reviewed for five tests per-formed July 25, 1978 through January 23, 1979.
Procedure No. SP-2405C, Seismic Events System Calibra-
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tion, Revision 0, February 16, 1979.
Data was reviewed for test performed September 28, 1978.
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Procedure flo. SP-2405E, Spectral Response Seismic Monitor Calibration, Revision 0, January 31, 1979.
Data was re-viewed for test performed June 1,1978.
Procedure No. SP-24053, Seismic Events System Channel
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Functional Test, Revision 1, February 16, 1979.
Data was reviewed for tests performed May 22, 1978, and flovember 3, 1978.
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Procedure No. SP-2405D, Peak Recording Acceleration Cali-bration, Revision 0, January 19, 1979.
Data was reviewed for test performed February 10, 1978.
c.
Findings Procedure SP-240.'K, High Power Calibration specifies the lower trip setpoint at 14.36% full power. Technical Specification Table 2.2.1, Item 2, specifies the lower trip point at a minimum of 15% rated thermal power.
This discrepancy was discussed with the licensee and NRR.
Results of this dis-cussion indicate the intent of the Technical Specification was not to limit the lower trip point at 15% of rated thermal power.
The licensee will submit a Technical Specification change to clarify this matter.
This item is unresolved pending NRC:RI review of the action described above.
(336/79-04-02).
Technical Specification 4.3.3.2.b requires the periodic channel calibration of the incore detection system which exempts the neutron detectors but includes all electronic components.
A channel calibration is defined as the adjust-ment, as necessary, of the channel output such that it 204-/
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responds with the necessary range and accuracy to known values of the parameter which the channel monitors.
A review of procedure SP-2407, In-core Detector Assembly Instrumentation Calibration (stated to be the nical Specification 4.3.3.2.b) procedure which satisfies Tech-
, and discussions with licensee representatives indicates that procedure SP-2407 is basically a cable continuty verification, and does not appear to satisfy the requirement for a channel calibration.
The licensee
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agreed to review this procedure and other procedures associated
with the incore detection system and the computer to verify that the requirements of Technical Specification 4.3.3.2.b are being satisfied.
This item is unresolved pending NRC:RI review of the action described above (336/79-04-03).
10.
Calibration Required by Technical Specifications of Components and Equipment Associated with Safety Related Systems and/or Functions a.
The inspector reviewed on a sampling basis, the program established for calibration of components associated with safety related systems required by ANSI 18.7-1972 and Appendix "A" of USNRC Regulatory Guide 1.33, November 1972.
These components are used to monitor system parameters to comply with the safety limits, limiting conditions of operation, and/or meet the surveillance requirements of the Technical Specifications.
The following were verified:
Specific requirements have been established for the below
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calibrations including schedules and frequencies; Procedures have been reviewed and approved in accordance
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with the Technical Specifications, contain acceptance criteria consistent with the Technical Specifications, and contain detailed instructions commensurate with the complexity of the calibration; and, Technical content of procedures are adequate to perform a
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satisfactory calibration.
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b.
Calibration data for the following components were reviewed.
Boric Acid Pumps Discharge Pressure (TS 4.1.2.6.b), Form
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2429A-1, PI-206 and PT-208.
Data was reviewed for test performed March 20, 1978.
Refueling Water Storage Tank Temperature (TS 3.5.4.c),
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Form 2429A-21, TT-3005.
Data was reviewea for test performed February ll,1978.
Condensate Storage Tank Level (TS 3.7.1.3), Form 2429A-
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24, LT 5282.
Data reviewed for test performed February 24, 1978.
Reactor Building Closed Cooling Water Discharge Pressure
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(TS 4.7.3.1.a.2), Form 2429A-29, PT-6008, PT-6009 and PT-6010.
Data reviewed for test performed February 17, 1978.
Service Water Discharge Pressure (TS 4.7.4.1.a.2), Form
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2429-36, PT-6474, PT-6480 and PT-6487.
Data reviewed for test performed February 23, 1978.
High Pressure Safety Injection Pumps Discharge Pressure
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(TS 4.5.2.a.1.b), Form 2429A-11, PT-30lX, PT-30lY, PT-301 Z.
Data reviewed for test performed March 18, 1978.
Low Pressure Safety Injection Pumps Discharge Pressure
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(TS 4.5.2.a.2.b), Form 2429A-12, PT-302X.
Data reviewed for test perfonned March 18, 1978.
No items of noncompliance were identified.
11.
Calibration and Control of Test Equipment The inspectors reviewed the calibration and control of test equip-ment used as standards in the calibration of components identified in Paragraph 9 to verify the following:
Establishment and adherence to calibration schedules.
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Maintenance of calibration records identifying standards used
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which have traceability to the National Bureau of Standards or other independent testing organizations Proper storage and labeling of test equipment.
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Adequate control of test equipment including record keeping.
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The following devic 2s were selected as a sampling:
Pressure Gauge 273
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Heise Test Gauge 202
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Digital Voltmeter 409
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Digital Voltmeter 311
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No items of noncompliance were identified.
12.
Technician Qualifications The inspectors discussed tha qualification records of four currently assigned technicans having responsibility for calibration testing of safety related systems and components. This review was performed to verify that the individuals experience level and training were in accordance with ANSI N18.1, "Sr ection and Training of Nuclear Power Plant Personnel."
No items of noncompliance were identified.
13.
Facility Tour During the inspection, a tour of the facility was conducted of the Turbine Building, Auxiliary Building, and portions of the security fence.
The inspector observed plant operations. (including a fire drill), housekeeping, monitoring instrumentation, radiation control measures, and controls for Technical Specification com-pliance.
In addition, the inspecto; observed control room opera-tions on both day and evening shifts for proper control room manning, and facility operation in accordance with selected administrative and Technical Specification requirements.
No items of noncompliance were identified.
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14, Unresolved Items Unresolved items are findings about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraph 9.c.
15.
Exit Interview The inspector met with licensee representatives (denoted in Para-grr.ph 1) at the conclusion of the inspection on February 23, 1979.
T;1e inspector summarized the purpose, scope and findings of the inspection. A subsequent discussion on the findings occurred in a telephone conversation between Mr. Farrell and Mr. Baunack on February 1, 1979.
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