IR 05000336/1990002
| ML20012B795 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/08/1990 |
| From: | Anderson C, Cheung L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012B793 | List: |
| References | |
| 50-336-90-02, 50-336-90-2, IEB-80-06, IEB-80-6, NUDOCS 9003160289 | |
| Download: ML20012B795 (9) | |
Text
ypg
--
,
>
s
..
fkp
- '
^
y :n >
H
,
.
7._ = f.
_
e'
U. S NUCLEAR REGULATORY COMMISSION
REGION I
'
' '
Report No.
50-336/90-02 Docket No, 50-336 b
License'No. DPR-65 sc
.
.
[.H,'
. Licensee:. Northeast Nuclear Energy Company
'P. O. Box 270-
'
Hartford, Connecticut 06141-0270 iL
Far:11ty Name: tl 1 stone Unit No. 2 L
Inspection Conducted: January 23-26, 1990 W
.
}
p j
g-t'eonard Cheung7pe 1or actor Engineer
'da e G
)
p fs
<
.
,
Approved by:
-
,
C J.-Agderson Chief, Plant System date i
.Section, EB/0RS
,
Inspection Summary:
Inspection of January 23-26, 1990 (Inspection Report No.
50-336/90-02)
s Areas-Inspected:.A special.. announced inspection 1) to address allegations associated with the Acoustic Valve Monitoring' System (AVMS), and 2)'to review 4the licensee's' responses to IE Bu11etin 80-06. This inspection was conducted
'from January ~23 through January 26, 1990.
'Results: iThe licensee's responses and corrective actions'for IE Bulletin
-!
- -80-06.are adequate. This item is c'osed, The allegations associated with
.the AVMS involved five. issues. Three issues were substantiated resulting in a-
.non-cited violation,. one. issue is' indeterminate, and ene-issue. is unresolved'
(see Section 6.3 of this report"for the unresolved item).
j o
.{
o
- '
r w'
_.j
-
>
i
.
b 31%hb5 f
.
O m
.
d
'....
.-
.
Details 1.0 Persons Contacted See Appendix A 2.0 Background
-An NRC inspection dealing with multiple allegations was previously conducted during the period July 10-21, 1989.
During that inspection, several allegations relating to the Acoustic Valve Monitoring System (AVMS) were examined and the results were documented in NRC Inspection j
Report No. 50-336/89-13. On November 15, 1989, one of the allegers called
'
the NRC inspector and stated that: 1) for allegation A 6.7, A.6.8 and A.12.5 of Inspection Report No. 50-336/89-13, the surveillance test and functional test procedures referenced in the report were not the revision used at the time of the plant modification in 1983, and 2) the inspection team had not addressed one of his concerns.
The concern was that follow-ing the 1988 refueling outage, for a period of approximately 8 months, the functional test procedure (SP-24108) for the AVMS had not been properly updated, as required by the surveillance test procedure. As a result, an outdated procedure had been used for the monthly functional tests during that period.
3.0 Purpose-The purpose of this inspection was 1) to examine the allegers concerns associated with the AVMS and 2) to review the licensee's response and
-
t corrective actions for NRC IE Bulletin 80-06.
This bulletin was transmitted
!
to the licensee on March 13, 1980, addressed generic design problems in l
Engineered Safety Feature reset-controls. During the. course of this j
inspection, three more issues concerning the AVMS were raised by the l
alleger. Two of these issues are addressed in this report. The third
!
issue is an unresolved item requiring additional information from the
licensee for NRC review.
j i
'4.0' Allegation Concern Pertaining to a Vendor Recommended Test
!
The alleger stated that in 1983, a modification was taade to upgrade
the acoustic sensors to meet the equipment's qualification requirements.-
He obtained a copy of a job order which showed that the manufacturer's
recommended post-modification test was not accomplished. The data sheet =
in the job order was never completed.
This is the save allegation as item j
1 of A.6.7 in Inspection Report No, 50-336/89-13.
4.1 Discussion The job order referred to by the alleger is Job Order No. 283-924A.
This job order was indicated as completed in December 1983. At that
.
-.
-
-
- - - - - -
.. -.,.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
-
..
..-
.
!
'
time, the effective revisions of Procedures SP 2410B and SP 2410A L
a were revision 0.
The inspector reviewed job order package No. 283-924A
,
and noted that the vendor's recommended test No. 30354-I-02, entitled
""
"Unholtz-Dickie Signal Conditioner Modification Check-Out Instructions,"
was not performed by the licensee and that the data sheet on page 4 r~
of the test instruction wa: blank. The inspector also reviewed
' '
procedures SP 2410A, revision 0, and SP 2410B, revision 0; the record of a surveillance test dated December 29, 1983, and the record of a functional test, dated December 29, 1983. All of these tests were
<
conducted during the 1983 refueling outage.
The licensee's justification for not performing.the vendor's recommended test was-that:
1) the vendor's recommended test is not a
,
requirement, and 2) all essential steps of the vendor's recommended h
test were covered by the above mentioned two tests. These test L:
procedures are compared as follows:
,
Corresponding Section of Vendor Recommended Test SP2410A, Revision 0 Procedure #30354-1-02 and SP2410B, Revision 0 3.0 Test Setup 3.1
" Connect Equipment...
SP2410B paragraphs As Indicated..."
7.53 to 7.69 3,2.1 " Set Controls...
SP 2410B paragraph 7.61'
HP Filter Out" 3.2.2 "LP Filter Out" SP 24108 paragraph 7.61 3.2.3 "FS Range...
SP 2410B paragraph to 10g" 7.61, FS to Ig 3.2.4 " Sensitivity...
SP 2410B paragrarh 7.62 10.1 pC/g" 3.2.5 " Bias...
TEC Procedure implied 9ma 15%
by steps 3.2.5 and 4.1 that 9ma gives 60%
indication
e
-
p
-..
..
o
6
'
.
g
,
4.0 Test Procedure P
4.1
" Verify... meter SP 2410A paragraph 7.2.2 reads 60 16%
<
-4;2
" Verify...
SP 24108 paragraph 7.62-IKH sinewave.."
4.3
" Verify 1.015%
SP 2410B paragraph 7.62 volt rms..."
4.4
" Record all Results" IC Form paragraph 2410A-1 IC Form paragraph 24108-1~
The vendor recommended test generates a charge input signal via an electronic charge generator.
The licensee used an insitu charge transducer for charge signal input (accelerometer).
4.2 Conclusion The inspector concluded that this allegation was substantiated in that the-licensee did not complete the vendor's recommended test data-
-
sheet..However, the essential steps of that test were performed as part of the surveillance test (SP 2410B) and the functional test (SP 2410A).
Both of these tests were completed during the 1983 refueling outage in which the modification was completed.
5.0: Allegation Concerns Pertaining to Failure to Update a Functional Test Procedure-The alleger stated that station surveillance procedure SP-2410B requir_es that-the monthly test procedure (SP 2410A) be revised after each surveil-lance test to: incorporate new test data and new noise spectra.
The revised-functional test procedure is to be used for the subsequent monthly func-
.tional test following the surveillance test, However, for a-period of-about eight months following the 1988 refueling outage, SP 2410A was not properly revised and the outdated procedure was used in several monthly functional tests.
5.1 Discussion
"
l
"
The inspector determined the following.
Surveillance test procedure SP 2410B, paragraph -7.7b requires the
,
functional test procedure (SP 2410A) to be revised after completion
{
of the surveillance test and the accompanying functional test to
'
reflect the new spectrum sheets. Millstone 2 restarted on
February 15, 1988, following the refueling outage which began on
<
January 1, 1988. A surveillance test was performed before restart I
!
=
!
,!
,
- -...
m. n d'
.
.
I and'the accompanying functional test was conducted on February 17, 1988.
Procedure SP 2410A was not revised until July 6,1988 (Change 1 of Revision 3).
During this period, at least two monthly functional tests were performed without updating the procedure.
Because of the frequent shutdown of Millstone 2 during this period, the affected number of functional tests was not as many as expected.
The plant operating history during this period is as follows:
l February 15, 1988 - restart from refueling outage February 25, 1988 - 100% power April 8, 1988
- shutdown April 18, 1988
- 100% power May 6, 1988
- shutdown May 24, 1988
- 100% power June-7, 1988
- shutdown June 15, 1988
- 100% power The licensee made the functional test a Technical Specifications item which requires it to be performed monthly, when the plant is operating.
During this inspection, the licensee's engineering evaluated the changes made in the July 6,1988 revision of SP 2410A, and was able to show that the AVMS was operable (capable of indicating the PORV block valve's open or closed position) and the acceptance criteria were not affected by the changes.
Therefore, the functional tests conducted without using the updated procedure were not considered a Technical Specification (hardware) violation.
However, the licensee's failure to update their functional test procedure as required by paragraph 7.76 of surveillance test pro-cedure SP 2410B is a violation of' Technical Specifications paragraph 6.8.1 which requires procedures to be established, implemented and-maintained. This violation is not cited in this report on the basis that the licensee took proper corrective action on. July 6, 1988, the functional test procedure was properly revised afterward, and this violation, if cited, would be a Severity Level V-violation (failure to follow procedure).
In addition, a violation for failure to follow procedures was issued to the licensee on October 11, 1989, following the July 1989 inspection (part B of Appendix A, inspection No. 50-336/89-13, a Severity Level IV for multiple examples of failure to follow procedures). The licensee's corrective actions with regard to following procedures will be reviewed as part of the follow-up on that violation.
5.2 Conclusion
'
This' allegation is substantiated resulting in a non-cited violation. The events as they occurred did not result in any actual degradation of the AVMS.
O
'
x,
,
..
...
i
l
.
,
,
,
,
6.0 Additional Concerns Associated with the Acoustic Valve Monitoring System During the course of this inspection, three additional concerns associated with the AVMS were raised by the alleger. -These are discussed
-
as follows:
6.1: The alleger stated that after the 1983 modification for the AVMS, a functional test was performed on December 29, 1983. The test record indicated that the "as-found" and as-left" meter reading for all four valves were all 60%. These data were difficult to believe because it is physically impossible to obtain a meter reading of 60%
-due to circuit saturation.
6.1.1 Discussion
-
On January 25, 1990, the NRC inspector observed two tests of the l
AVMS. The first test indicated that a 60% meter reading could not be achieved for all four valves when the preamplifier bias currents were increased to more than 20 ma.
The second test was performed on a spare instrument which was removed from the instrument rack and was used before for valve position
'
monitoring. After the "zero" of the instrument was properly adjusted, the licensee was able to demonstrate a meter reading of greater than 65%. However,- the functional test procedure contains no instructions for "zero" adjustment before obtaining the meter reading.
6.1.2 Conclusion I
The inspector concluded that this issue is indeterminate because of possible "zero" drift of the instrument during the past six'
years.. No safety concern is involved since the current functional test procedure indicates that any meter reading between 30% and 80% is considered to be acceptable.
6.2 The alleger stated that on August 26, 1988, two technicians were directed by the licensee engineering to measure the preamplifier bias current of the AVMS. The measurement results indicated that the bias currents were all around 4 ma instead of the 9 ma bias current recommended by the vendor.
6.2.1 Discussion The inspector reviewed the test record of the subject test and found that the measured preamplifier bias currents for all four valves ranged from 3.417 ma to 4.715 ma.
The inspector also reviewed a memo issued by the licensee's engineering, dated March 9, 1989. The memo indicates that a test was conducted which demonstrated that the AVMS preamplifier functioned properly with bias current between 2 ma and 9 ma.
- - -
.
[
L
...
_js=
'
I.'
i 7-
,
p 6.2.2 Conclusion The inspector concluded that this issue is substantiated.
However, no safety concern is involved as the AVMS was demonstrated to be operable with preamplifier bias current between 2ma and 9ma.
6.3 The alleger stated that before the July 1988 revision of the functional test procedure (SP 2410A), 18 KHz was used as a reference e
" resonant peak" in the noise spectra.
This " resonant peak" was no longer recognizable during the 1987 and 1988 period,'but the I&C technicians continued to indicate in the functional _ test data sheets that this resonant peak was present.
It appears that the I&C technicians do not understand the meaning of this resonance peak.
The alleger wanted to know the safety significance of this activity.
During this inspection, sufficient data could not be obtained from the licensee to address this issue.
This item is unresolved pending NRC review of the licensee's response to this issue (50-336/90-02-01).
7.0. Licensee's Corrective Actions in Response to IE Bulletin 80-06
'
IE Bulletin No. 80-06 was issued by-the NRC to.the license on March 13, 1980, requesting licensee's response to a generic design problem in the Engineered Safety Feature (ESF) reset controls. The licensee responded to the NRC in a-letter dated June 13, 1980, stating that the control circuitry of 33 items needed to be modified.
Subsequent responses from the licensee, dated _0ctober 20, 1980, January 5, 1981, February 13, 19u1 and March 20, 1981, stated that six items had been deleted from the modification list. Justi-i fication was provided.
In addition, three items were repeated (P-42A,
'
P-42B and TV-6307) on the modification list. Therefore, only 24' items needed to be modified. Two PDCR's were used by the-licensee for the modification of these 24 items: PDCR No.. 2-139-80, dated September 5, 1980, for 16' items and PDCR No. 2-152-80, also dated September 5,'1980, for the remaining 8 items. The inspector reviewed the two PDCRs and the five
response letters. The inspector also verified that all items identified on I
the modification list were covered.
The inspector considered the licensee's responses and corrective actions to IE Bulletin 80-06 to be adequate. This item is closed.
'
8.0 Unresolved Item
An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item or a violation. An unresolved item identified during this inspection is discussed in Details,
paragraph 6.3 of this report.
!
i
_... _ ___ <..
.
..
..
.
.
9.0 Exit Meeting
.The inspectors met with licensee representatives (See Appendix I) at the conclusion of the inspection on January 26, 1990. The inspectors summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by the inspector did not contain any proprietary information.
The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information.
i
,
,.,..., _ _ _..
_ _ _ _ _ _
-h--,-.-
,... -,
,,,,,,,,..
...
,...
.
..
,,
l APPENDIX I EXIT INTERVIEW ATTENDEES MILLSTONE UNIT 2 JANUARY 26, 1990 The below listed personnel attended the exit meeting held by the NRC on
'
January 26, 1990.- Other licensee personnel were contacted during the inspection as the activities interface with their area.
T.'Arnett, Unit 2 I&C Engineer J. Becker, Unit 2 Acting I&C Supervisor D. DelCore, Sr., Unit 2 Instrument Specialist J. Keenan, Unit 2 Superintendent J. Persio, Equipment Analysis Engineer, Northeast Nuclear Energy Corporation P. Smith, Unit 2 Assistant Supervisor
.
%
y
.
.
.