IR 05000336/1995201

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-336/95-201

ML20138H891
Person / Time
Site:	Millstone
Issue date:	12/30/1996
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9701060281
Download: ML20138H891 (3)

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December 30, 1996

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Mr. Bruce l President and Chief Executive Officer  !

i Northeast Nuclear' Energy Company l

c/o Terry Harpster  :

P. O. Box 128  !

L Waterford, Connecticut 06385-0128

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! SUBJECT: INSPECTION NOS. 50-336/95-201

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Dear Mr. Kenyon:

This letter refers to your letter dated July 31,1996, in response to our -

May 31,1996 letter.

i-Thank you for informing us of the corrective and preventive actions documented in your ,

letter. We note that your work control process for Unit 2 was reviewed during NRC '

Inspection 50-336/95-34 was found to be acceptable based on corrective actions taken for .

a previously identified violation (50-336/94-30-01 - Poor Maintenance Work Practices).

The deficiencies identified in the later violation were similar to the problems also identified in deficiency 50-336/95-201-06. The corrective actions taken for Violation 336/94-30-01 also apply to deficiency 336/95-201-06. Based on corrective actions detailed in Inspection )

95-34, deficiency 95-201-06 is closed.

The actions taken for the deficiencies 336/95-201-03 and 336/95-201-07 will be examined during future inspections of your licensed program.

Sincerely, ORIGINAL SIGNED BY:

Jacque P. Durr, Chief Special Projects Office Office of Nuclear Reactor Regulation l Docket Nos. 50-336 s

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060065 i

i 9701060281 961230 PDR ADOCK 05000336 G PDR

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! . Mr. Bruce .

cc w/o cv of Licensee's Response:

T. C. Feigenbaum, Executive Vice President - Chief Nuclear Officer  !

M. Bowling, Jr., Unit 2 Recovery Officer l l D. M. Goebel, Vice President, Nuclear Oversight  ;

l J. K. Thayer, Recovery Officer, Nuclear Engineering and Support l P. D. Hinnenkamp, Director, Unit Operations l H. F. Haynes, Director, Nuclear Training

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P. M. Richardson, Nuclear Unit Director, Unit 2 J. F. Smith, Manager, Operator Training F. C. Rothen, Vice President, Work Services cc w/cv of Licensee's Response:

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L. M. Cuoco, Esquire l J. R. Egan, Esquire #

V. Juliano, Waterford Library i

Department of Public Utility Control S. B. Comley, We The People '

l State of Connecticut SLO Designee i

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Mr. Bruce Distribution w/cv of Licensee's Response:

Region i Docket Room (with concurrences)

M. Kalamon, SPO, RI NRC Resident inspector Nuclear Safety Information Center (NSIC)

PUBLIC D. Screnci, PAO l

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DOCUMENT NAME: G:\ BRANCH 6\REPLYLTR\95201.RPL To receive a copy of this document, indicate in the box: 'C" = Copy without attachment / enclosure 'E' = Copy with attachment / enclosure !

'N' = No copy OFFICE Rl/DRP gg Rl/DRP / l /

NAME DATE NBlumberg 08/4 f06 JDurr 'm' - f l125d96 l ,

OFFICIAL RECORD COPY l l

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'N Northeast 2 **" S*** 8'", er 06037  ;

i i Utilities System 5,the vune. senice comroy i P.O. Box 270 Hartford,cT06 41-0270 i (203) 665-5000 l

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July 31, 1996 l

t Docket Nos. 50-336 l B15797 :

Re: 10CFR2.201 '

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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 l Millstone Nuclear Power Station, Unit No. 2

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Response to Request For Additional Information Inspection Report 50-336/95-201 t-In the letter of May 3, 1996, * the Staff requested Northeast Nuclear Energy Company (NNECO) to respond, within 60 days of receipt of the letter, to three deficiencies that were identified during the Restart Assessment Team Inspection at Millstone Unit No. 2 (MP2) which was conducted from May 8, 1995 through June 9, l

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1995. Specifically, the Staff requested that-NNECO respond to deficiencies 95-201-03, 95-201-06, and 95-201-07. In the request, the Staff asked that NNECO state (1) whether or not NNECO agrees with the deficient condition; -(2) if corrective

! actions are needed, what, if any, has NNECO taken or plans to '

take to correct the immediate deficiency and to preclude further recurrence, and (3) root cause(s) of the deficiency.

l Attachment 1 contains NNECO's response to this Request For

! Additional Information.

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Jacque P. Durr let _f to Ted C. Feigenbaum, " Request for Response to NRC ~ s;5ection 50-336/95-201", dated May 3,1996.

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U.S. Nuclear Regulatory Commission.

, . B15797/Page 2

l If you have any questions regarding information contained herein, please contact Mr. Michael D. Ehredt at (860) 440-2142.

l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: T. C. Feigenbaum Executive Vice President and Chief Nuclear Officer By: VCGt.A-

! S". E. $c6ce l Vice President cc: T. T. Martin, Region I Administrator l D. G. Mcdonald Jr., NRC Project Manager, Millstone Unit l No. 2 f P. D. $ wetland, Senior Resident Inspector, Millstone Unit No. 2

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Docket.No. 50-336 B15797 i

Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Response to Request For Additional Information Inspection Report 50-336/95-201

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July 1996 l

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U.S. Nuclear Regulatory Commission l

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B15797/ Attachment 1/Page'l l

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Deficiency 95-201-03

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j Guidance' contained in the station directive on procedural I classification (Millstone Procedure DC-4), which has resulted in the classification of.all maintenance procedures as " General Use," is inconsistent.with station expectations regarding procedural adherence. Consequently, all mechanical and l electrical maintenance procedures are not required to be in-hand at the jobsite and followed directly. Maintenance craft personnel's' understanding of guidance on how to use procedures was found to vary significantly among individual craft persons.

A specific example was observed where limited written procedure guidance was provided to plant operators at a remote location in the plant. Only two sections of OP-2348A, "6,900 and 4,160 Volt Breaker Operation" were available to plant equipment operators in i the safety related switchgear room. This procedure was classified as a " General Use" procedure and, as such, the full procedure was not required to be at the job site. This was determined to be an example of how the procedure classification process has contributed to a lack of clear understanding on procedural usage and adherence. This issue is further discussed in Paragraphs 3.2.2 and 4.2.2 of inspection report IR 50-336/95-201.

Response:

1. NNECO agrees that this is a deficient condition with the following exception: " General Use" procedures are' required !

to be located at the job site or in proximity to job site, and are referred to, as required, during work activity to ;

ensure the task will be performed correctly and is performed

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procedure section by section or task by task.

2. The Procedures Upgrade Program has issued 2 separate memos to all directors and department managers. Memo PUP-95-181 informed the directors and department managers of the NRC !

concerns regarding classification of procedures and re-em1.iasized the responsibility of the department managers to ensure that procedures are properly classified per the definitions of station procedures.

Memo PUP-95-179 informed the department managers that the Level of Use for procedures would require re-evaluation when the procedures are upgraded or revised.

3. This deficiency was a result of inadequate management attention to proi:edure classification. l

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U.S. Nuclear Regulatory Commission

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. B15797/ Attachment 1/Page 2 Deficiency 95-201-06:

Electrical technicians discovered that they were working on an energized motor operated valve (2-MS-86A). This valve was not

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safety related; however, this was a continuation of previously identified problems concerning improper tagouts. Corrective actions to previous problems had not been adequately performed.

Administrative Procedure ACP-QA-2.06A was jnadequate in that it did not delineate clear responsibilities for the individual in the tagging process. This issue is discussed in more detail in Paragraph 4.1.2 of inspection report IR 50-336/95-201.

Response:

1. NNECO agrees that this is a deficient condition.

2. Due to the repetitive nature of tagging related problems, a i specific Adverse Condition Report (ACR), ACR 365, was written to address the tagging issue on a broad-based level including scoping of the tagging boundary, the identification and preparation of tags, and the review of the adequacy of tagouts.

The following corrective actions resulted from the root cause investigation of the problem:

a) Station Procedure WC-2, " Tagging", was implemented on Millstone Unit No. 2. WC-2 explicitly defines j the tagging process and assigns individual i responsibilities to each step of the process, b) All involved departments (Operations, Instrument &

Control, Maintenance, Technical Support Engineering, Design Engineering, Outage Management, Generation Test, and Chemistry)

underwent training on the requirements of WC-2.

c) Additional work practices were instituted which require a second check of the tagging within the Electrical Maintenance group prior to forwarding a tagging request to the Work Control Group, and

! requires that all exposed conductors will be checked for potential at the beginning of work and after a shift change.

3. This deficiency was a result of inadequate procedural guidance concerning the tagging process, no delineation of the responsibilities for the tagging process, and insufficient training of personnel involved in the tagging process.

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l U.S. Nuclear Regulatory Commission

. B15797/ Attachment 1/Page 3 Deficiency 95-201-07:

l Settings-for adjustable instantaneous trip devices on certain l safety related molded case circuit breakers were not specified on controlled drawings or procedures. If improperly set, these

! adjustable trip devices could cause spurious tripping of l associated safety related equipment. This issue is further

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discussed in Paragraph 4.5 of inspection report IR 50-336/92-201.

Response:

1. NNECO agrees that the setpoints for the Molded Case Circuit

, Breakers with adjustable instantaneous trip units should be l documented.

l 2. Molded case circuit breakers (MCCB) installed at MP2 are l equipped with thermal and magnetic (i.e. instantaneous) trip  !

! units. The thermal feature provides circuit overcurrent l

protection while the magnetic trip provides fault (short i

l circuit) protection. MCCBs are installed in a variety of l electrical power and distribution equipment, including motor l

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control centers, distribution panels, battery chargers, and i inve::ters . While the majority of the breakers are equipped with fixed (non-adjustable) instantaneous trip units, twenty-seven are equipped with an adjustable instantaneous trip feature. As tabulated in Attachment 2, nine of the breakers are installed in motor control centers to provide branch feeder protection, twelve are installed in the 125 vdc safety-related battery chargers as input or output i breakers, and the remaining six are installed in the de input of the 120 vac inverters. Setpoints for the

adjustable trip feature of the breakers are not documented l in either a controlled procedure or drawing.

l Test records for the existing breakers were reviewed and the adjustable setpoints were identified. A subsequent review of the setpoints concluded that they were acceptable as-is.

NNECO will take the following corrective action:

a) The setpoints for the adjustable instantaneous trip units of the affected breakers (as shown on the table contained in Attachment 2) will be incorporated into a l controlled plant procedure. The estimated completion date for this corrective action is December 31, 1996.

{ 3. This deficiency was a result of the setpoints not being

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documented in the permanent plant records as part of the

. original plant design.

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Docket No. 50-336 B15797

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Attachment 2

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Millstone Nuclear Power Station, Unit No. 2 i

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Molded Case Circuit Breakers

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With j Adjustable Instantaneous Trip Units '

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July 1996

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Unit 2 Molded Case Circuit Breakers Adjustable Instantaneous Units

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GTSID LOCATION SIZE EQUIPMENT POSITION BE051 201A 600 201 A-1 CHARGER DC OUTPUT Hi BE052 201A 600 201A 2 CHARGER DC OUTPUT Hi ,

BE053 201A 175 201 A-1 CHARGER AC INPUT HI BE054 201A 175 201 A-2 CHARGER AC INPUT HI BC057 2018 600 2018-1 CHARGER DC OUTPUT HI BC058 201B 600 201B 2 CHARGER DC OUTPUT HI BC059 201B 175 2018-1 CHARGER AC INPUT HI BC060 201B 175 2018 2 CHARGER AC INPUT Hi BE047 201C 600 201C-1 CHARGER DC OUTPUT HI BE048 201C 600 201C-2 CHARGER DC OUTPUT HI BE049 201C- 175 201C-1 CHARGER AC INPUT HI BE050 201C 175 2010-2 CHARGER AC INPUT HI BA002 B5103 200 "A" CHARGING PUMP HI BA004 B5105 200 "B" CHARGING PUMP HI B8027 B5229 150 INSTRUMENT AIR COMPRESSOR HI BB033 B5236 ' 225 COMPUTER UPS ALTERNATE SUPPLY HI

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BC001 B6102 200 . C" CHARGING PUMP HI l BC004 B6105 200 i"B" CHARGING PUMP HI BD007 B6209 125 iTURBINE TURNING GEAR LO BD028 B6237 150 -

INSTRUMENT AIR COMPRESSOR F3B HI j BD035 B6245 225 COMPUTER UPS HI BB055 INV 1 250 INVERTER 1 DC INPUT HI BD053 : INV-2 250 INVERTER 2 DC INPUT HI BA059 INV-3 250 INVERTER 3 DC INPUT HI BE046 INV 4 1 250 INVERTER 4 DC INPUT HI BB056 INV 5 1 250 :

INVERTER S DC INPUT HI j BD054 INV-6 l 250 INVERTER 6 DC INPUT H1

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