IR 05000336/1987014

Insp Rept 50-336/87-14 on 870706-10.No Violations Noted. Major Areas Inspected:Activities Associated W/Licensee Steam Generator Surveillance & Preventive Maint Activities

ML20235J190
Person / Time
Site:	Millstone
Issue date:	09/10/1987
From:	Lodewyk A, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235H384	List: IR 05000336/1987014 ML20235H382
References
50-336-87-14, NUDOCS 8710010343
Download: ML20235J190 (5)

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U.S.NUCLEARREGULATORYCOMMISSIONl REGION:I <1 Report No'. 50-336/87-14 Docket N I License N DPR-65 Licensee: Northeast Nuclear Energy Company P. O. Box 270H-Hartford, Connecticut 06141-0270

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Facility Namei Millst'one Nuclear Power Station, Unit 2 L

' Inspection At: Waterford, Connecticut- -

Inspection Conducted: July 6-10, .1987 ,

Inspector: _w f d/#'7

,rpfJ.Lodewyk, Reactor. Engineer .date .!

Approved by: _ .

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. trosnider, Chief, Materials & date rocesses' Section, EB, DRS Inspection Summary: Inspection on-July 6-10, 1987. .(Report No.;50-336/87-14)

l Areas Inspected: A routine, unannounced inspection was c'nducted o by one i region-based inspector of activities associated with'the licensee's steam '

generator surveillance and preventive maintenance activities. Follow-up on  ;

licensee's actions on three previously identified NRC items of concern- '

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resulted in closure of those item i

_Re sults: No violations were identifie ,

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DETAILS 1.0 Persons Contacted i l

Throughout this inspection, various site and engir:eering representatives j were interviewed' for information and auditing purposes. Some of those ']

persons contacted include the following:

l Northeast Nuclear Energy Company (NNEC) 'I Paul Parulis,. Senior Engineer i

• Brenden Duffy, AES, Unit 2 i Clifford Libby, Supervisor, Assessment Services  :

^R. Thomas Blanchad, Jr. , ISI Coordinator, Unit 2  !

C. Perkins, Licensing (Berlin)

J. Waters,. Station Chemist

• J. Stetz, Unit 1 Superintendent'

O.S. Nuclear Regulatory Commission (NRC)

• Geoffrey E. Grant, Resident Inspector  !

T. Rebelowski, Senior Resident Inspector a

• Denotes some of those persons-present at the exit meeting conducted at the close of this inspectio .0 Licensee Action on Previously Identified Inspection Finding .1 (Closed) Unresolved Item 336/86-24-01 This item involved updating the facility Technical Specification section-on steam generator tube sleeve plugging limits. Previous. reviews of-Technical Specification plugging criteria noted that the plugging limit for degraded' steam generator tube sleeves had not been defined. Review of licensee correspondence revealed that a sleeve plugging limit had been es-tablished; however, Technical Specification surveillance requirements had not been updated to reflect the approved criteria. Thus, engineering practice has been to plug tubes or insert slee'ves in tubes indicating 220% through-wall eddy current test signals which is a conservative plugging / sleeving criteria. This item was opened pending clarification of the tube plugging / sleeving limit to avoid unwarranted plugging of steam generator tubes and unnecessarily decreasing steam generator reactor coolant flow and heat transfer capabilit The licensee's previous analysis had determined that' sleeved tubes need not be plugged with less than 40% through wall flaws. The licansee has applied for a Technical Specification Amendment with the Office of Nuclear Reactor Regulation to incorporate the sleeve plugging limit for future steam generator surveillance testin Further tracking and approval of the licensee's actions in this area will be provided through the NRC's licensing ~ project manage This

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itm is closed.

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2.2 (Update) Unresolved Item 336/85-02-01 This. item involved Quality Assurance lead auditor training and qualification programs. A-routine, NRC inspection identified a concern regarding the formal training and qualificat' ion of lead QA auditors reviewing technical functional area The inspector determined the following.during this inspection. I addition to a standard QA auditor training program, the licensee provides training in technical fields through corporate. sponsored courses. Specific training classes are available within the en-

! gineering/ technical, academic, and administrative fields through'

contractors or internal staf Examples of those courses offered include: Codes and Standards; Radwaste Management;; Nondestructive Examination; Plant Chemistry; and Work Orders. Classes such as these are available to QA auditor personnel and completion of technical training is based upon availability during work schedule The licensee's corporate training staff intends to complete a job-task-analysis of the QA auditor position with regard to training, qualification and requalificatio This item remains open pending completion of the licensee's job task analysis and NRC review of licensee' actions in this are .3 (Closed) Unresolved Item 336/85-08-02 This item involved the-inoper-ability of main steam subsystem piping snubbers. Previous NRC walkdown inspection of main steam subsystem piping (4"-EBD(B)-1)

identified the following inoperable snubbers: J a) Hanger No. 413082A (pipe clamp) with two hydraulic snubbers, I Serial Nos.12232 and 11576; b) Hanger No. 4131-35 (U-bolt) with mechanical snubbers, Serial-Nos. 13915 and 13890; and, c) Hanger No. 413081, with mechanical snubber, Serial No. 10989.

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Subsequent ISI Engineering personnel snubber visual inspections i l in accordance with procedure No. NU-VT-1, confirmed and addressed )

the inadequacies in the above listed snubber The unacceptable j snubbers were repaired or replaced through maintenance work order '

requests. An engineering evaiuation determined the cause.of the snubber failures to be due to thermal piping growth. The 1985 Visual

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j Inspections included 100% of the installed mechanical and hydraulic j snubbers to ensure additional snubbers were not rendered inoperable q due to thermal growth. Plant Design Change Request 85-025 was issued i and completed to provide the changes necessary to ensure proper oper- I ation of the main steam subsystem snubbers. Post-modification and l post-system operation visual inspections verified proper installa- )

tion of the newly configured supports without rendering the snubbers '

inoperabl Based upon re' view of the licensee's snubber repairs, i

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engineering evaluation, corrective actions and visual inspection results, this item is close !

3.0 Licensee Activities to Maintain Steam Generator Integrity  ;

i The licensee's steam generator (S/G) preventive maintenance program (as it is related to maintaining S/G integrity.and controlling station secondary water chemistry) was reviewed. relative to commitments provided in the licensee's response to Generic Letter 85-0 '

Licensee performance in S/G preventive maintenance was-determined by interviews with chemistry, radiation protection, maintenance, quality assurance, and plant engineering personnel; and by review of selected j procedures, reports and records. The review addressed the licensee's chemistry, maintenance, Inservice Inspection (ISI) and ALARA program procedures, policies and implementatio Those plant procedures, records and reports selected for review were found to contain:

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critical chemical variables and limit / action levels for secondary q

water chemistry control 4 l

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monitoring and inspection of condenser internals (including periodic eddy current inspection of condenser tubes when practicable)

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cleanliness, personnel and material accountability requirements J

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supplemental S/G tube inspections beyond Technical Specification requirements j

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routine egg-crate radiography to ensure S/G tube support and reduce the potential for excessive tube vibratio !

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Based upon the personnel interviews and document reviews, it appears  ;

that the licensee is performing site activities in accordance with their response to Generic Letter 85-0 Additional inspection of the licensee's actions to optimize the Millstone Unit 2 S/G inspection program was performe In February 1987, a re-analysis of S/G eddy current data was initiated as a result of an unre-lated primary to secondary tube leak. As a result of data reanalyses, it was-determined that 38 tubes that should have been repaired or plugged had  :

not been repaired by sleeving or plugging. Although the majority of the missed tubes could be explained by the accepted 10% sizing deviation associated with eddy current test (ECT) accuracy, some defect calls were missed as a result of other ineffective practices or events that occurred within'the vendor's ECT Program. This issue wa previously addressed in  !

inspection report 50-336/87-4. The licensee's proposed action plan to minimize the possibility'of missed defect calls in future S/G inspections include changes in ECT data analysis and data managemen _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _

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Several ' defect calls were missed as a result of a reviewer's override of primary and secondary analyses. Intended corrective actions include-concurrence of such overrides by an additional qualified reviewe The licensee also intends to develop plant specific data analysis guidelines to assist in ECT analysi Another problem identified was improper reporting of the inspection results by a data analyst (e.g., incorrect reporting of the. length of a tube being tested). The action plan for reporting errors involves

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developing reporting guidelines which require documentation of the exact

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location in the tube where an eddy current test probe stop !

Data management system improvements are to include computer based abili-l ties to identify discrepancies by. comparison of independent data analysis I results. Additional review by qualified personnel to assure vendor compliance with ECT specifications is intended. This is to include monitoring and direct overview by plant ISI personnel as well as.addi-tional checks by contractor personnel.

l The proposed corrective action includes a data management and training course for analysts as well as test and practical demonstration of the program requirements. All proposed tasks are to be completed prior to the next scheduled Unit 2 outage in January 198 No violations were identifie .0 Exit Meeting l

l The inspector met with the licensee representatives (denoted in para-graph 1) at the close of this inspection on July 10, 1987. The inspector summarized the purpose, scope, findings and observations

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l of this inspection. At no time during this inspection was written material provided to the licensee by the inspector.

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