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,0, UNITEo STATES e
NUCt. EAR REGULATORY COMMISSION I*
REGION I e'
478 ALLENoALE RoAte i
KING OF PRUS$tA. PENNSYLVANIA 19404 EAY 141931 s
This letter refers to allegations that you provided to us on October 12,1990, alleging problems with both the drawings and seismic qualification of the reactor coolant flow transmitters, procedural deficiencies with SP-2402A, and problems with the functional testing of reactor coolant system flow, reactor coolant pump speed, and the RPS turbine trip; and on December 7,1990, alleging inaccurate drawing updates associated with modifications on the main turbine electrohydraulic system.
We referred these issues to the licensee for their review and followup and their responses are attached for your information. The licensee review of these items found many of the concerns to be valid; however, no programmatic deficiencies or problems requiring additional expenditure of manpower were identified. A number of the issues were not substantiated.
Please advise us if you wish to further pursue any of these matters.
Thankyou for informing us of your concerns.
Si rely; Edward Wenzinger, Chief Reactor Projects Branch 4
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Attachments: As stated
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HUBBARD92-162 PDR
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- ALLEGATION RECEIPT REPORT l O fi'l-[90 Iltonwt A11'egation No.
k~hb -N ~ M 7 (leave blant)
Name:
Address:
Phone:
City / State / Zip:
Confidentiality:
Was it requested?
Yes No X Was it initially granted?
Yes No Was it finally granted by the allegation panel Yes No Does a confidentiality agreement need to be sent to alleger?
Yes No Has a confidentiality agreement been signed?'
Yes Na Memo documenting why it was granted is attached?
Yes No k
Position /
Title:
e Facility:
Idwe--l-Occket No.:
60 B f,
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f (Allegation Summary (brief description of concern (s):
( 0 Re.c). cootee+ A.e T J. A im o, no eS,.ero, no4 sels-;t c
SP-2Voi4 C(o2 M An de m L b e v.(M T5 d-c-OL,e
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Number of Concerns:
7 Employee Receiving'A11egation: M l b,9,eys? / d 8
(firsttwolinitiftsandlastname)
Type of Regulated Activity (a) L Reactor (d) _ Other: Safeguards (b) _ Vendor (e) _
(c) _ Materials (Specify)
Materials License No. (if applicable):
Functional Area (s): [(a) Operations (e) Emergency Preparedness
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(b) Construction f Onsite Health and Safety.
(c) Safeguards g Offsite Health and Safety (d) Transportation h Other:
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(NRC Region I Form 207 Revised 10/89)
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L Tne alleger came to the resident of fice at appro::imately 10:00 a.m. to discuss the contents of five internal we rep h( 5 )
memorandums.
The memorandums to the instrument and controls department head.
(Memos will be transmitted to the NRC Regional Office during the week of October 15).
i 1SSUE NO. 1 10/06/90Memof References (1) to John Becker. *PDT-111C Transmit er est'* Connection Repairs *
(2) 10/12/90 Memo to Jchn Becker, ' RCS F low 'Transmi tter nstallations'
[3) Quality bervice Surveillance Audit No. CS-274 dated 09/28/90 Topics Reactor Coolant Flow Transmitter instellatipn not as reflected en control discrems, and qpestior.s on the seismic Qualifications of the mounted transmitters Discussioqt_
was conducting reactor coolant system flow transmitter calibrations during the later part of September and early October.
The surveillence was controlled by procedurs SP-2402A and under work euthori:s ti on number M2-90-10874.
During the performance of the work activity [
1 identified the following discrepancies:
(1)
Isometric drawing 252O3-73512 was compared with the actual con 12guration *or the eight installed transmitters.
identified deficiencies such transmitter piping distances, and support mounting as orientettons.
A number of test connections were
_ missing swagelok port connectors and swagelok cep assemblies.
One the transmitter test connections was bent at the reducer location.05-274 audit observed that war k and spetifically documented problems with the test fittings.
Further inv:stigation identified the modification paper work PDCR 2-66-B3 did not have a seismic certification for the transmitter installation nor did the original purchase order (283-318) specify the correct isometric drawings applicable to reactor coolant system flow transmitter installation.
On October 6, 1990 the I/C department head responded to5ENE(
lllEEEUh He requested the I/C engineer research the seismic r -
t qualification question, and a 1/C first line supervisor respond to the QSD surveillance audit findings.
Ollecers Concernt identified another configuration control problem and as a result of research is questioning the seismic qualification of the transmitter installation.
Inspector Assessment:
This is not an allegation in that the seismic qualification is a question that NU needs to answer and resolve.
The control drawing errors and condition of swagelok fittings for the transmitters is subject of a 05D audit requiring IC department addressel and ubD approval.
The utility has the same information presented to the NRC i
inspector.
ISSUE ND. 2 References (1) 10/12/90 Memo to John Becker, 'bF-2402A RCS Flow Calibration' i
(2) 10/12/90 Memo.
to John Becker, ' Monthly Fu Testing" (3) 10/12/40 Memo to John Becker, ' Monthly Functional Testing of RCF Speed, and Turbine RPS trips
- Topics: Procedural De f i cif!qgj es wi th calibration pr2tedyre SP-RSO2A and Improper Functional Testino of RCE Flow. RCP speed. and Turbine Trio.
D3Ecossion:
During performance of RCS Flow calibration wort.
M identified deficiencies within the calibration procedure.
The deficiencies identified were static b
g alignment offset values, completion of a as-left alignment k
check after the transmitters have been statically aligned, gT'y Iand calculational errors for the reac or protection system bastable and input resistor values.
. recommends a complete rewrite / revision of the procedure in order to complete the calib' ration.
f
) believes the licensee has not properly f
eccomplished required monthly functional tests for RCS flow, j
RCF speed, and Turbine Trip.
supports his belief in that procedure SP-2402P, ' Safety-Related g
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Functional Test' accomplishes the surveillance at the Foxboro Spec. 200. cabinets for all RPS/ESF inputs.
SP-2402F does not include RCS Flow, RCP speed, and Turbine Trip f[
signals.
The monthly functional for RCS flow and RCP speed are identified in SP-2401G which directs test signal inputs to be provided in the back of the RPS cabinet instead of the 4
Foxboro Spec. 200 cabinet.
According to/ JEEEEEEEEE thin 1r resu'.ts in not fulfilling the technical specifacation 4
definition of
. injection of a simulated signal into g;1 the channel as close to the p-
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203 443 5893
,0CT li '90 13:37 NRC MILLSTOME OFFICE PO4
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primary sensor as practicable to verify operability.
The Spec. 200 cabinetc are closer to h
primary sensor than the back of the RF5 cabinet.
believes this failure to correctly surveil as provided 'in the definition t
of channel functional testing was not completed and therefore should be a LER or PIR.
In addition, i
believes the RF-S Turbine Trip function is not subj e cted to a monthly surveillance, believes the definition of monthly unctional survel ante has not been adhered to, nor has the turbine trip been subjected to a monthly sur ance.
The procedure deficiencies identified the questioned if the surveillance adequately demonstrated operability of the RCS flow in s t rumen t a ti on.
Incoector Assessment: As far as the identified procedural deficiencies with the RCS flow calibration, the inspector does not have enough information to ascertain if the operability has been affected, however, licensee management is awere of the deficiencies presented by MI the RPS functional tests for RCS flow and RCP speed appear to conform to the definition within the as not technical urecfications.
Notwithstanding, the affect of operabiltty tib l e l y on the location of test signals does not appear to be tignificant.
The turbine trip surveillances described in Technical Specification table 4.3-1 only requares a start up surveillance at greater than 15% power, (i.e. no specific nonthly, channel calibration, or channel check is required by teen specs.)
The licensee does have the required start up surveillance.
i The inspector's assessm nt is that issue No. 2 is not an s.11egation, since did not provide dissatisfaction with licensee response to; memo's.
The licensee has not finalized there investigation of the issues.
Recommend that if M is disatisfied with licensee response he provide this information to the NRC to l
discuss at a panel meeting.
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l MAY 141991 i
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This letter refers to allegations that you provided to us on October 12, 1990, alleging l
problems with both the drawings and seismic qualification of the reactor coolant flow transmitters, procedural deficiencies with SP-2402A, and problems with the functional testing of reactor coolant system flow, reactor coolant pump speed, and the RPS turbine trip; and on j
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December 7,1990, alleging inaccurate drawing updates associated with modifications on th i
main turbine electrohydraulic system.
J i
l 1
i We referred these issues to the licensee for their review and followup and their responses are i
attached for your information. The licensee review of these items found many of the l
l concerns to be valid; however, no programmatic deficiencies or problems requiring additional expenditure of manpower were identified. A number of the issues were not substantiated.
Please advise us if you wish to further pursue any of these matters.
l 1,
)
Thankyou for informing us of your concems.
i i
l Sincerely; i
l 0: mil.i.L SIGHED BY l
I EDWIJiD 0. WENZiNGER i
I l
Edward Wenzinger, Chief l
Reactor Projects Branch 4 Attachments: As stated i
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+c ALLEMTION RECEIPT REPORT
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7 !90 82/7 A11'egation No. [/- fd '-
ce (leavetblank)pa Name:
Address:
Phone:
City / State / Zip:.'
4" Coofidentiality:
^
Was it requested?
Yes
. No. X Vas it initially granted?
Yes No Was it finally granted by the allegation panel Yes
- No Does a confidentiality agreement need to be sent to alleger?
Yes No Has a confidentiality agreement been signed?
Yes No Memo documenting why it was granted is attached?
Yes No
/NE.()1/e[c4 Positton/Titie:
Facility:
//78 Docket No.:
50-336 P
(Allegation Summary (brief description of concern (s): [ d h2w65 be tw//ren U hc Scb3%&Y b e trceJ-c)esh n cA.nre N bn~ n %rx,r,ol<,9.
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PJ m Number of Concerns:
h Employee Receiving'A11egation:
b
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8 (first two thitials' and last name) b.,/_ Reactor (d)
Sa feguards :,
- Type of Regulated Activity a
Vendor (s) "_Other:
~
c
_ Materials (Specify)
Materials License No. (if applicable):
C' FunctionalAres(s): '
a Operations
_ e) Emergency Preparedness b Construction g)5 f Onsite Health and:5afety'.
c Safeguards e iteeHealth andesafety-d Transportation h
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(NRC Region I Form 207 e
Revised 10/89)
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i TELEPHONECONVERSIONWITH)
ON DECEMBER 07, 1990 INSPECTOR:
PETER J. HABIGHORST DATE:
LECEMBER 07, 1990
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TIME:
INACCURATE DRAWING UPDATES ASSOCIATED WITH MODIFICATION WORK TO THE MAIN TURBINE EHC SYSTEM j
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Based on information provide during training (week of 12/02)
M identified a problem with drawing control for the electro-hydraulic control (EHC) system on the main turbine.
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i discussed drawing control with the initial i
' pressure 1 iter (PT-4297A). The EHC electrical subsystem consists of a speed control unit, load control unit, and flow control unit. The load control unit consists of in part of a initial pressure limiter circuit. Within the initial pressare limiter circuit is pressure transmitter
( PT-4297A).
l According to M he is aware through training of a recent modification unich replaced PT-4297A transmitter.
According to M the new transmitter output is 4-20ma in comparison with the old transmitter of 10-50 ma.
l With the modification also believes a current / voltage converter was adthd. Initially, W'
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was not aware of any plant modif cation that replaced the transmitter, or the necessary control drawing updates.
J After initial discussions with the inspector, 6 )
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identified that replacement of the transraitter was accompMahed under PDCR 2-88-83 and the associated loop %
di 25203-28500 sheet 504 for PT-4297A was updated.
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confirmed, however that NUSCo drawing 25203-39077 sneet was not updated based on replacement of the i
transmitter.
verbally discussed this with his technical trainer George Beratein during the classroom discussions.
raised the question of how was it that technical
' training is' aware of modifications to the facility without the facility drawings updated to reflect a modification.
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55 Based on' discussions with other IC technicians i n
he presented to the in'spector another drawing error. NUSCo "t IP drawing 25203-39077 sheet 73E for the main turbine pressure L. P demodulator board identified a wrong part number based on actual field identification number. The part no. on NUSCo drawing 25203-39077 sheet 73E is 117L9988GE1 and based on field verification the part number is 117D9988GE3. The IC technicians involved are and' 3.
Daring a past modification for the main turbine (modification from pa*tial are to full arc) pointed out that the diode function control ard to process signals to the turbine control valves was not reflected in a NUSCo drawing change. The affected drawing is 25203-39077 sheet 73E.
Ineyr tre-Dev4pu
- 1. The inspector reviewed the material, equipment parts list (MEPL) did not reflect the transmitter replacement.
Specifically, the MEPL evaluated the 10-50 ma transmitter.
PT-4297A beifications (Old transmitter)
Rosemont (0-1000 psig)
Model 1104A7A2K Output 10-50 ma MEPL evaluation CD*618 In-service date 6/24/83 Non-QA Reenmmanintion-In addition to alleged drawing revisions, inspector review inital review concluded that the MEPL, and equipment history record may need to be updated.
g Turn over to the licensee. for PT-4237A. The revitw concluded that the MEPL Processing Time: 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> "y k N
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