IR 05000336/1980008

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IE Insp Rept 50-336/80-08 on 800623-27.Noncompliance Noted: Surveillance & Inservice Insp Activities Performed W/O Consistent Use of Procedure
ML19351D377
Person / Time
Site: Millstone Dominion icon.png
Issue date: 07/23/1980
From: Chung J, Greenman E, Mccann J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19351D367 List:
References
50-336-80-08, 50-336-80-8, NUDOCS 8010100044
Download: ML19351D377 (13)


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U. S. NUCLEAR REGULATORY COMMISSION Q

OFFICE OF INSPECTION AND ENFORCEMENT

REGION I

Report No.

50-336/80-08 Docket No.

50-336 License No.

DPR-65 Priority Category C

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Licensee:

Northeastern Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06061 Facility Name:

Millstone, Connecticut Inspection At:

Waterford, Connecticut Inspection Cond ted:

June 23-27, 1980 j/

N Inspectors:

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. Cnung, Rea or Inspector

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4 1 O cCann, Reat t Jhspector Atat4 10 0

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lAs YP3 haub, React Ingpector

/date Approved by:

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E. Gnfenman, Chief, Nuclear Support Section

' datfe No. 2, RO&NS Branch Inspection Summary:

Inspection on June 23-27, 1980 (Report No. 50-33/80-08)

Areas Inspected:

Routine, unannounced inspection by three region based

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inspectors on previous inspection findings; administrative controls for sur-veillance procedures; surveillance testing; inservice inspection program; per-formance of surveillance and inservice inspection tests; surveillance changes

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in conformance to License Amendments; technician qualification; and facility tours.

This inspection involved 59 inspector-hours onsite by three region -

l based inspectors.

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Results:

Of the eight areas inspected, no items of noncompliance were observed i

in seven areas and one item of noncompliance was identified in one area (Defici-ency - surveillance and inservice inspection activities performed without con-sistent use of procedures).

Region I Form 167 (August 1979)

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DETAILS 1.

Persons Contacted

  • A. G. Cheatham, Radiological Services Supervisor
  • J. O. Crockett, Engineering Supervisor - Unit 2
  • F. R. Daeims, Quality Services Supervisor
  • H. F. Haynes, I&C Supervisor - Unit 2
  • J. J. Kelly, Unit 2 Superintendent
  • E. J. Mroczka, Station Superintendent
  • V. Papadopoli, QA Supervisor
  • R. A. Place, Maintenance Supervisor - Unit 2
  • S. E. Scace, Operations Supervisor - Unit 2 S. Sudigala, Reactor Engineer - Unit ?

A. Weber, Shift Supervisor - Unit 2 USNRC

  • J. T. Shedlosky, Senior Resident Inspector
  • R. P. Zimmerman, Resident Inspector The inspector also interviewed other licensee employees and consulting technicians during the inspection, including reactor operators, technical support, administrative, and clerical personnel.
  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (336/78-07-04):

Failure to maintain surveillance test records for Fire Protection System.

The inspector verified by review-ing the surveillance requirements of Fire Detection Instrumentation and Fire Suppression Systems that no requirement existed to perform the tests prior to March 3, 1978, when the Surveillance Program for Fire Protection System was added to the Technical Specifications by Amendment 35 to the license.

Also reviewed were the minutes of the December 16, 1977 meeting of the Plant Operations Review Connittee which approved the procedures and forms to implement the new surveillance requirements.

(Closed) Unresolved Item (336/79-28-01):

No procedure addressed the dis-semination of contractor /sub-contractor quality information other than audit results.

The inspector verified that the following procedure ade-

quately addresses reporting of contractor quality performance information.

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NUSCO Nuclear Engineering and Operations Procedure, NE0 2.10, Monitor-

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ing and Reporting of Contractor's Quality Assurance Performance, Revi-sion 0, January 25, 1980.

(Closed) Unresolved Item (336/79-28-02):

No implementing procedures could be identified that require that reworked, repaired and other such items be

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tested and inspected in accordance with original requirements.

The inspec-tor verified by review of the following procedure that reworked or repaired items must be retested to meet the original or equivalent acceptance criteria.

ACP-QA-5.01, Non-conforming Materials and Parts, Revision 7, May 23,

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(Closed) Unresolved Item (336/79-28-03):

Establish controlled procedures which delineate the authority, duties and responsibilities of the Construc-tion Quality Assurance Unit and the Quality Control Unit as described in

" Jurisdiction Statements" (JS-192 and JSc-367).

The inspector verified by review of the following documents that the requirements of NUSCO Jurisdiction Statements JS-192 and JSc-367 were incorporated into controlled procedures.

NUSCO Quality Assurance Department Procedures Manual

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Procedure No._

Revision Date 1.03

December 5, 1979 1.14

December 27, 1979 1.16

December 20, 1979 1.17

December 20, 1979 1.22

January 2, 1980 1.23

December 17, 1979 2.02

January 18, 1980 2.10

January 18, 1980 NUSCO Generation Engineering Procedures Manual, Procedure 3.18,

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Revision 0, October 1, 1979.

NUSCO Generation Construction Procedures Manual, Procedure 2.07A,

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Revision 1, March 7, 1980.

NUSCO Generation Construction Quality Control Manual, Procedures

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QC-G-2.01 and QC-G-4.01, Revision 1, March 7, 1980.

(Closed) Unresolved Item (336/79-28-04):

Reflect the recent station reorganization in procedure QA-1.02.

The inspector reviewed Procedure QA-1.02, Revision 10, January 30, 1980, which describes the current QA organization at Millstone Point.

3.

Administrative Controls for Surveillance Procedures The inspector performed a review, on a sampling basis, of the below listed administrative procedures for conformance with Technical Specifications, Section 6, " Administrative Controls", ANSI N18.7-1972 " Administrative Con-trols for Nuclear Power Plants" and Regulatory Guide 1.33 " Quality Assur-ance Program Requirements".

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ACP-QA-9.028, Unit 2 Surveillance Master Test Control List, Revision 3,

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January 30, 1980.

ACP-QA-9.06, Inservice Inspection Program, Revision 1, August 3, 1978

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ACP-QA-9.02, Plant Surveillance Program, Revision 6, January 30, 1980

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ACP-QA-3.02, Station Procedures and Forms, Revision 13, June 20, 1980

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No items of noncompliance were identified.

4.

Surveillance Testing a.

The inspector reviewed surveillance tests on a sampling basis to verify the following.

Tests required by Technical Specifications are available and

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covered by properly approved procedures.

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Test format and technical content are adequate and provide satis-factory testing of related systems or components.

Tests have been reviewed as required by Facility Administrative

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Requirements.

Tests were performed within the time frequencies specified by

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the Technical Specifications and appropriate action was taken for any item failing acceptance criteria.

b.

The following surveillance tests were reviewed to verify the items identified above.

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EN21014, Azimuthal Power Tilt-Tq, Revision 0, May 10, 1979.

Data were reviewed for the seven tests performed March 24, 1980 through May 5, 1980.

SP2401J, Thermal Margin / Low Pressure Calculation Test, Revision 2,

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April 23,1979.

Data were reviewed for the four tests performed January 25, 1980 through April 24, 1980.

SP2402C, Steam Generator Pressure Calibration, Revision 0,

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January 4, 1979.

Data (form #2402C-1) were reviewed for one i

test performed March 24, 1979.

SP2403A, ESAS Bistable Trip and Auto Test Inserter Test,

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Revision 1, March 22, 1979.

Data (Form 2403A-1) were reviewed for the five tests performed December 11, 1979 through April 10, 19d0.

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SP2403B, ESAS Undervoltage Calibration, Revision 1, February 28,

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1979.

Data (Instrumentation Data Sheet 24038-1) were reviewed for the five tests performed February 9, 1980 through June 9,1980.

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SP2601H, Facility II Charging Pump Operability Test, Revision 3, April 26, 1980.

Data (0ps Form 2601H-1) were reviewed for the five tests performed March 10, 1980 through June 15, 1980.

SP2605A, Verifying Containment Integrity, Revision 1, September 22,

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Data (0ps Form 2605A-1) were reviewed for the five tests performed January 24, 1980 through April 25, 1980.

SP2606B, Facility II Containment Spray Pump Operability Test,

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Revision 2, May 2, 1978.

Data were reviewed for the four tests performed January 24, 1980 through April 24, 1980.

SP26098, Enclosure Building Filtration and Control Room Venti-

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lation Operability Test - Facility II, Revision 2, November 9, 1978.

Data (0ps Form 26098-1) were reviewed for the seven tests performed January 23, 1980 through May 26, 1980.

SP2610A, Motor Driven Auxiliary Feedwater Pumps Operability Test,

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Revision 1, March 14, 1977.

Data (0ps Form 2610A-1) were reviewed for the five tests performed February 21, 1980 through April 16, 1980.

SP2610B, Turbine Driven Auxiliary Feedwater Pump Operability Test,

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Revision 2, April 26, 1978.

Data were reviewed for the five tests performed January 18, 1980 through April 16, 1980.

SP2610C, Auxiliary Feedwater System Lineup and Operability Test,

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Revision 1, April 26, 1378.

Data (Ops Form 2610C-1 and 2) were reviewed for the ten tests performed January 30, 1980 through May 18, 1980.

SP26128, Service Water Pump Operability Test - Facility II,

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Revision 2, April 13, 1978.

Data were reviewed for the six tests performed March 24, 1980 through June 13, 1980.

SP2613E, Diesel Fuel Oil Sampling, Revision 0, March 12, 1979.

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Data (0ps Form 2613E-1) were reviewed for the five tests per-formed April 1, 1979 through April 7, 1980.

n OP2618A, Monthly Fire Protection System Fire Pump Auto Start

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Test, Revision 1, March 18, 1980.

Data were reviewed for the five tests performed February 19, 1980 through June 16, 1980.

SP2618D, Fire Protection System Sprinkler and Deluge Functional

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Test, Revision 1, March 6, 1980.

Data were reviewed for three

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tests performed April 12-May 7, 1980, December 20, 1979 and January 10, 1980 (The latter two were retest after maintenance).

SP2618F, Fire Putsp Performance Test, Revision 2, March 18, 1980.

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Data were reviewed for one test performed April 12, 1980.

SP2619A, Control Room Shift Checks, Revision 3, February 20, 1979.

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Data (0ps Forms 2619A-1 and 2) were reviewed for forty-nine checks performed May 1, 1980 through May 23, 1980.

SP2619D, Startup Surveillance Check List, Revision 1, March 7,

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Data were reviewed for the twenty checks performed August 26, 1979 through April 30, 1980.

SP2730A, Pressurizer Safety Valve Test, Revision 2, October 23,

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Data (Maintenance Form 2630-1) were reviewed for the three tests performed March 17, 27 and 23 of 1979.

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SP28836, Safety Injection Tank Analysis for Boron, Revision 0, May 5, 1977.

Data were reviewed for the twenty analysis per-formed August 24, 1979 through May 20, 1980.

No items of noncompliance were identified.

5.

Inservice Inspection Program a.

The inspector reviewed the in-service inspection plan and procedures on a sampling basis to verify the following:

Tests are in conformance with the in-service inspection program

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requirements.

Test frequency is in conformance with Technical Specifications

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and the In-Service Inspection Program.

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Test format and technical content are adequate and provide satis-

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factory testing of related systems or components.

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Test results have been reviewed as required by facility adminis-

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trative requirements and appropriate action was taken for results failing acceptance criteria.

Tests are performed by qualified personnel.

b.

The following In-service Inspection plans, procedures and test results were reviewed to verify the above as applicable.

Inservice Inspection Ten Year Program for Northeast Nuclear

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Energy Co. Millstone Unit 2; Pump and Valve In-service Testing section.

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EN21101, ISI Pump and Valve Operability Evaluation, Revision 1,

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October 12, 1979.

EN21103, Service Water Pump 'B' (P-58) Operational Readiness

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Test, Revision 1, January 24, 1980.

(1) Form EN21102, Service Water Pump 'A' (P-5A) Operational headiness Test, Revision 1, January 24, 1980.

Data were reviewed for the five tests performed Jar:uary 11, 1980 through June 3, 1980.

(2) Form EN21103, Service Water Pump 'B' (P-58) Operational Readiness Test, Revision 1, January 24, 1980.

Data were reviewed for the four tests performed January 11, 1980 through April 23, 1980.

EN21105, Auxiliary Feedwater Pump 'A' (P-9A) Operational

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Readiness Test, Revision 1, January 24, 1980.

(1) Form EN21105-1, Auxiliary Feedwater Pump 'A' (P-9A)

Operational Readiriess Test, Revision 1, January 24, 1980.

Data were reviewed for the four tests performed January 4, 1980 through June 24, 1980.

(2) Form EN21106-1 Auxiliary Feedwater Pump 'B' (P-98)

Operational Readiness Test, Revision 0 April 26, 1979.

Data were reviewed for the four tests performed January 1, 1980 through June 24, 1980.

EN21110, RBCCW Pump 'C' (P-41A) Operational Readiness Test,

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Revision 1, January 24, 1980.

No data reviewed.

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EN21117, Containment Spray Pump 'A' (P-43A) Operational

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Readiness Test, Revision 1, January 24, 1980.

No data reviewed.

EN2118, Charging Pump 'A' (P-18A) Operational Readiness Test,

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Revision 1, February 2, 1980.

(1) Form EN21118-1 Charging Pump 'A' (P-18A) Operational Readiness Test, Revision 0, April 26, 1979.

Data were reviewed for the five tests performed January 24, 1980 through May 5, 1980.

(2) Form EN21119-1 Charging Pump (P-18C) Operational Readiness Test, Revision 0, April 26, 1979.

Data were reviewed for the four tests completed January 11, 1980 through April 7, 1980.

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EN21131, Chemical and Volume Control System Values, Operational

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Readiness Tests, Revision 1, October 30, 1979.

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(1) Form EN21131-2, CVCS valves operational readiness test, Revision 1, October 30, 1979 and Forms EN21101-2 and 3 Valve Operability Evaluation, Revision 1, October 12, 1979.

Data were reviewed for the two tests completed for valves CH-089, CH-190, CH-505, CH-518 and CH-519 on May 10, 1980 and November 27, 1979.

EN21133, Reactor Coolant System Valves Operational Readi-

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ness Tests, Revision 1, Octcber 30, 1979.

Data were reviewed for the four tests (valves RC-001, RC-002 and

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RC-003) performed November 25, 1979 through May 10, 1980.

EN21136, Safety Injection and Containment Spray System Valves

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Operational Readiness Tests, Revision 1, October 30, 1979.

h (1) Form EN21100-3, Revision 0, April 26, 1979.

Data were reviewed for the three tests (valves SI-651 and SI-652)

performed May 17, 1980, November 27, 1979 and August 26, 1979 and the four tests (valves SI 706 A, B, C and D) per-formed July 25, 1979 threugh May 17, 1980.

(2) Form EN21136-1C Safety Injection and Containment Spray System Valves Operational Readiness Test, Revision 0, January 18, 1980.

Data were reviewed for three tests (valves CS-1A, CS-2A, and CS-14A and B) performed Mr.r 23, 1980, February 28, 1980 and December 29, 1979.

EN21137, Pump Vibration Monitoring Equipment Operating Procedure,

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Revision 1, June 18, 1980.

EN21141, Inservice Inspection Revision 0, April 28, 1980.

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No items of noncompliance were identified.

6.

Inspector Witnessing of Surveillance Tests and Inservice Inspections a.

The inspector witnessed the performance of surveillance testing and inservice inspection of selected componentt to verify the following.

Procedure was available and in use.

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Special test equipment required by procedure was calibrated and

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in use.

Test pre equisites were met and initial conditions were observed

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properl.

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The procedure was adequately detailed to assure performance of a

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satisfactory surveillance or inservice inspection.

b.

The inspector witnessed the performance of two inservice inspections for the containment spray pump and service water pump, and four sur-veillance tests as follows.

SP26068, Containment Spray Pump 'B' Operability Test performed

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June 25, 1980.

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EN21117, Containment Spray Pump 'B' Operational Readiness ISI test performed June 25, 1980.

SP26128, Service Water Pump Operability Test performed June 25,

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EN21103, Service Water Pump 'B' Operational Readiness ISI test

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performed June 25, 1980.

EN21014, Azimuthal Power Tile test performed June 25, 1980.

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d SP2401J, Thermal Margin / Low Pressure Calculator Test performed

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June 25, 1980 and June 26, 1980.

c.

Findings (1) The inspector identified the following.

The inspector observed that the Azimuthal Power Tilt test,

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EN21014, was performed without reference to the written procedure, and consequently without observing the prerequi-sites and initial conditions which are required by the procedure.

Prerequisite 4.4 in the procedure states that "all 4 power range safety channels are operable if tilt is.to be deter-mined using excore channels".

Contrary to this prerequisite, the tilt determination was made using both incore and excore detectors while safety channel D was bypassed for thermal margin testing.

Initial condition 5.1 in the procedure requires that "the reactor is being maintained in a steady state condition" for the tilt determination.

However, the tilt determina-tion was made while the reactor was in a start-up xenon transient at 82% of full power level.

The licensee acknowledged that the above conditions existed during the test, and further stated that the test will be repeated in accordance with the procedure.

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Combined tests of surveillance and inservice inspection

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requirements for containment spray 'B' pump operability were observed.

The ISI test was performed using 444A Mini-UBIQUITOUS Spectrum Analyzer (Serial No. 70-48023, ID C-146-03), for which the licensee could not produce cali-bration record.

This is contrary to the test procedure, where the test technician is required to verify the calibration of test equipment.

When the inspector questioned the validity of the tests, a licensee representative stated that the analyzer will be calibrated and previous test results completed with the equipment will be reviewed.

The failure to use procedures consistently while performing tests and subsequent failure to meet the requirements specified in the procedures are contrary to Technical Specifications 6.8.1; ANSI N18.7-1972, Paragraph 5.1.2; Procedure ACP-QA-9.02; and con-stitutes a deficiency level item of noncompliance (336/80-08-01).

(2) During these tests, the inspector also observed the following.

Test steps 7.5 and 7.7 of the Thermal Margin / Low Pressure

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Calibration Test, SP2401J, require that a potentiometar be adjusted to reach desired Digital Volt Meter (DVM) readings for nuclear power sub-channel and temperature voltage inputs, respectively, and that these valves be recorded on the data sheet (I&C Form 2401J-1).

The inspector observed that the valves obtained by adjusting the potentiometer were entered as "As Found" data, and later transcribed as "As Left" da*.a.

A licensee representative acknowledged in a subsequent dis-cussion that since there were no requirements of "As Found" DVM reading in the procedure, data should not be recorded for these steps in the "As Found" column, and that changes would be incorporated into the procedure to eliminate this practice.

Test step 7.2 of the procedure requires adjustment of a

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potentiometer for an Axial Shape Index (ASI) reading oW the DVM to within 1.003 ASI.

The inspector noted that adjust-ment to within this tolerance was extremely difficult due to the high sensitivity of the DVM to potentiometer adjust-

l ments in the desired range.

Extremely small movement of the potentiometer resulted in ASI fluctuations of over 0.2 ASI.

A licensee representative acknowledged the difficulty and stated that appropriate measures would be taken to allow

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l easier adjustment of the ASI voltage to within tolerance.

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The inspector observed that after completing the test for

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the first of 4 channels (Channel A), the remainder of the test was delayed until the morning of the next day.

The inspector determined, by asking the test technician, that this particular test was frequently performed over a two day period due to the length of time required to complete tne test.

There was no indication that the initial conditions and prerequisites for this test were re-checked when the test was resumed the following morning.

The technician perform-ing the test stated that he did check the prerequisites and initial conditions prior to re-starting the testing but that there was no requirement to record this re-check on the data form.

The licensee representative acknowledged the inspector's concern that plant conditions could change significantly between the time testing is stopped and the time it is re-started.

The above three items will be reviewed during a subsequent NRC:RI inspection.

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Surveillance Changes Resulting from License Amendments The inspector reviewed license amendments (Amendments 43 through 55), which included Technical Specifications changes, and verified that applicable surveillance and inservice inspection requirements were revised as neces-sary to reflect these changes.

No items of noncompliance were noted.

8.

Technician Qualificat;ons The inspectors reviewed the qualification records of selected technicians and craft personnel who were involved in plant operations, surveillance and inservice inspection activities, to ensure that the personnel qualifi-cations met the minimum training and experience guidelines of ANSI N18.1,

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Select. ion and Training of Nuclear Power Plant Personnel, Section 4.

l The qualification records of nine personnel were selected from four depart-

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ments; one maintenance technician, four instrument and control technicians, I

three plant operators, and one engineering technician.

No items of compliance were identified.

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9.

Control Room Observations and Facility Tours The inspector toured accessible areas of the Turbine / Generator Building, Auxiliary Building, service areas, and Control Room and observed housekeep-ing practices, work in progress, Control Room manning, operations daily logs, and general conditions.

The inspector expressed safety concern with regard to the following practices.

At least six persons were noted to be extremely perfunctory in frisk-

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ing upon leaving surface contamination areas.

Health Physics Procedure 902/2902 is vague regarding protective cloth-

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ing requirements for entering surface contamination areas with levels greater than 1000 DPM/100 cm2 (100 DPM alpha) when no physical work is to be performed.

In one instance, an Eberline RM-3C was used with the audio indication

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turned fully down.

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An Eberline RM-3C used to frisk personnel leaving the Auxiliary Build-ing was found to have its audible alarm set'at 350 cpm in a location where the background level was relatively stable at approximately 30 cpm.

The alarm setpoint of approximately 320 cpm above background appears to be extraordinarily high.

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The licensee acknowledged the inspector's comments, and will review these areas.

The inspector had no further questions in this area.

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Unresolved Items Unresolved items are matters about which more information is required to clarify whether they are acceptable, items of noncompliar.ce, or deviations.

No unresolved items were identified.

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11.

Entrance and Exit Interviews Licensee management was informed of the purpose and scope of the inspection at the entrance interview, and the findings of the inspection were periodi-cally discussed with the licensee representatives as indicated in the following summary.

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Date (Reportable Details Covered June 23, 1980 Entrance Interview June 25, 1980 2,6.C(1),B.C(2)

June 26, 1980 2,6.C(1),B.C(2)

June 27, 1980 2, 6.C(1), Exit The inspector conducted an exit interview with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection, where the findings of the inspection were presented and acknowledged by the licensee.

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