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f This letter refers to allegations that you provided to us on January 16 and 31 and Febrf I
1991, alleging problems with:
I Sicam generator manuay studs. reactor protection block bistable for low steam l
generator pressure, and tagout of containment radiation monitor RM-8123; l
/
Backup flow indicator instrument for use when instruments were bung i
I calibrated, for the 10 CFR 50 Appendix R storage locker; ard.
l Agreement of radiation monitor 8123 A/B with cor. ainment air samp;es.
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We referred these issues to the hcensee for resiew and their responses are attached for your i
information. The licensee found many of the concerns to be salid; howeser, a number ]
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l issues were not substantiated. In the case of the radiation moniterlair sample issue, the licensee is evaluating improsements in sampling processes. Otherwise, no programmatic deficiencies were identified and no additional expenditure of NRC resources or manpower; planned. Please advise us if you wish to further pursue any of these matters.
i Thank you for informing us of your concerns.
f Sincerely;
,. Original Signed ey Edward Wenzinger. Chief Reactor Projects Branch.2 1
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l Attachments: As stated i
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Alle ation Files RI-A.C010. 0033 & 0036 l
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HUBBARD92-162 PDR i
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t May 6, 1991 Docket No. 50-336 f
A09449 Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I l
47$ Allendale Road King of Prussia, Pennsylvania 19406 i
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Dear Mr. Venzinger:
i Millstone Nuclear Power Station, Unit No. 2 l
RI-91-A-0010 Ve have completed our review of the identified issues concerning activities As Millstone Unit No.~2 (RI 01-A-0010).
letter, our response does not contain any personal privacy, proprietary, or.
at safeguards information. The. material contained in this response may be NRC Public Document Room at your released to the public and placed in the have received controlled and discretion.
The NRC letter and our response limited distribution on a 'neei to know" basis during the preparation of j
this response.
I Issue 1 are from the training sock-up.
Some of the steam generator manway studs vere no quality controls in place at the mock-up and the studs are A nonconformance There not suitable to use en the steam generator manvays.
of the studs, but the work order (NCR) was vritten concerning use was closed prior to disposition of the NCR. The sequence of events is l
report l
prohibited by administrative control procedures.
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Mr. Charles V. Behl, Director
' U. S. Nuclear Regulatory Commission i
A09449/Page 2 May 6, 1991
-l Please discuss the validity of the above assertions.
If an NCR was written, please provide a copy of the NCR for our review.
If any requirements vere violated, please discuss your corrective l
procedural actions and the significance to safety of the violation (s).
Response
the January 1991 steam generator (S/G) manvay leak outage, a total i
During had to be replaced.
Since only 20. spare studs. vere 26 manvay studs in the varehouse, six primary manvay studs were taken from the S/G l
of stocked All of the studs taken from the mock-up vere installed on mock-up.
manvay the No. I hotleg maraay under AVO M2-90-16146.
The studs taken frem the mock-up vere actual manvay studs procured as OA Category 1 components for use on the S/G steam generators.
At receipt-l
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inspection, the OA studs were engraved with a Millstone Point Serial Number the Material Receipt Inspection Repor t (MPSN) to provide traceability to (MRIR).
the studs vere not subjected to QA saterial a
Vhile installed in the mock-up, re-established using the MPSN vhich controls.
Bovever, traceability was a
provides material identification.
NCR 291-008 was originated by Hillstone Unit No. 2 Maintenance on January 4,
1991 to evaluate the adequacy of the mock-up studs.
Based on the
.I technical evaluation, the NCR vas dispositioned "Use-As-Is" and approved by l
the Unit Director on January 5,1991.
A preservice examination of the studs required by the ASME code was The studs were installed, and the S/G manvay performed on January 4, 1991.
The AV0, which included a copy of the tensioned on January 5,1991.
approved NCR, was returned to Operations on January 5, 1991.- The aanvay j
was leak tested on January 8, 1991, and the AVO vas closed on January 9, i
was 1991.
Contrary to the assertion, the vork order was not closed prior to the disposition of the NCR.
The assertion states that "the sequence of events is prohibited by i
l administrative control procedures."
Based on a review of applicable procedures, ACP-0A-2.02C, "Vork Orders".
-[
ACP-0A-5.01,
" Nonconforming Materials and Parts",
there vere no nor NCR 291-008.
l and procedural violations associated with AVO M2-90-16146 i
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.o-Mr. Charles V. Behl, Director l
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U. S. Nuclear Regulatory Commission A09449/Page_3 May 6, 1991 ACP-0A-5.01 includes a flovchart for nonconformance reports. The required NCR 291-008 are shovn i
and actual sequence followed in processing l
in the following table.
Step Number refers to NCR " block" number.
d sequence Step Actual Action Number Required Action NCR initiated'on January 4, 1991 l
Originator identifies nonconformance Logged in and NCR number assigned 2
OSD logs NCR January 4, 1991 3
Engineering reviews NCR dispositioned by engineer on and dispositions NCR January 4, 1991, approved by supervisor on January 5, 1991
[
4 Unit Director review Approved by Unit Director on January j
and approval 5, 1991 i
5 NCR implemented NCR dispositioned "Use-As-Is"; no.
l disposition action / implementation required 6
OSD Verification / Review NCR closed by OSD on January 8,1991 I
include any procedural requirements is noted that ACP-0A-5.01 does not It to sequence NCR process with the AVO vork control process.
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of ACP-0A-2.02C, "Vork Orders", associated with the NCR and Requirements All of the applicable requirements vork order processes are shovn below.
satisfied.
ACP-0A-2.02C pertaining to nonconformance reports were F
requires:
I 1.
An NCR be initiated when nonconforming conditions or events are encountered.
(The NCR vas initiated on January 4, 1991 when it was f
determined that the mock-up studs vere needed.)
2.
Hold points be established for OSD verification of work which implements NCR dispositions.
(Since NCR 291-008 vas dispositioned l
"Use-As-Is", no OSD hold points / verification was required.)
NCR implemertation dates be recorded on vork orders prior to close-out.
NCR atproval-date of January 5, 1991 was entered on the AVO prior j
3.
(The to returning :ke work package to Operations.)
f A copy of NCR 291-008 is provided as Attachment I to this letter.
)
Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Cor. mission A09449/Page 4 May 6, 1991 Issue 2 During a recent performance of SP-2402P, it was identified that the the reactor protection block bistable for lov steam generator pressure on does not function properly.
A modification is undervay to correct drift A number of other problems with the bistable have been adjustment.
identified but no corrective actions have been taken.
discuss the validity of the above assertions.
If problems with an bistable have been identified, please discuss the operability of that i
Please channel of the RPS. Please discuss why identified discrepant conditions, RPS addressed by management.
if any, associated with the RPS have not been
Background
The lov steam generator pressure trip block is manually initiated and l
automatically removed by a bistable located in the auxiliary logic drawer One is to The bistables currently have tso design functions.
of the RPS.
allow the block of the lov S/G pressure trip when S/G pressure is less than 780 psia. This allovs the RPS breakers to be closed with the plant in a cold shutdovn condition. This design feature vas originally intended to support lov power physics testing.
The second design feature is to automatically remove the block when pressure is raised above 780 psia.
Since Hillstone Unit No. 2 is restricted by technical specifications to not allow criticality vith RCS temperature below 515'F, the automatic removal of the block design feature is not relied upon. Technical specifications prohibit energizing Control Element Drive Mechanisms in Modes 3 (belov 500*P),
4, 5, and 6 unless RCS boron concentration is at least refuel concentration levels.
The block function has been used to accomplf:n element drive systes. cold rod checks prior to reactor operation controlthe RCS boron con;entration is at refuel levels. During the cold rod activity, Technis.al Specification 3.1.3.7 is complied with and RCS when At the completion of check concentration is maintained at refuel levels.
the testing, the block switches are restored to normal position. The boron technical specifications require that for the reactor to be taken critical, be greater than $15'F. This results in a S/G the RCS temperature mustNo other plant operation evolutions require the use of the block keys.
Current lov power physics tests do not involve l
pressure of 780 psia.
As reactor criticality is not allowed with operation of the block feature.
the trip blocked, the design feature of its automatic removal is never relied upon.
Due to these restrictions in the current operation of Millstone Unit No. 2, the block removal setpoint drif t noted to date is not considered a discrepancy of any safety significance.
The sensitivity of the bistable installed in RPS channel A vas first identified in 1986.
The bistable was monitored for drift until it was replaced in May 1987.
The condition of the bistable was monitored with increased awareness over the next two years.
Troubleshooting vas
[
to determine the cause of the accomplished in 1988 - 1989 in order to try I
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Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Commission A09449/Page 5 May 6, 1991 sensitivity.
The results of the investigation concluded that the components on the bistable circuit card vere causing the increased sensitivity and subsequent drifting due to age.
New circuit cards vere ordered as replacements and have not been received due to difficulty with finding replacements for obsolete parts.
An upgraded design of the circuit Monitoring of is being pursued using currently available components.
card the bistable condition vill continue until it can be replaced.
Response
The bistable continues to perform its function satisfactorily despite its sensitivity.
A review of Instrument Calibration Reviews (ICRs) written 1987 indicates that there vere four occasions when the bistable 'as since condition was outside of acceptance criteria in the high direction.
found" time this was documented by procedure (ICR) and the bistable adjusted Each back within tolerance prior to returning that channel to operable status.
There vere no instances where more than one channel of the RPS vas af fected at any one time. There are no other problems with the bistable that have been identified to date.
The condition is being properly addressed by management at a priority commensurate with its safety significance.
i Issue 3 M2-90-15362, used to upgrade the flov indication of the Vork order radiation monitor, RM-8123, was authorized and worked without a containment tagout.
r Please discuss the validity of the above assertion.
Vas there an administrative requirement to have a tagout in place to perform the work, and why was this requirement not followed?
Please discuss any generic implications.
Background
correction to the equipment "ID" as recorded on this issue is needed, as the referenced vork order M2-90-15362 was written to implement PDCE A
MP2-90-032 to upgrade the flow switch associated with RM-8262 and not The following information is developed based on the work order RM-8123 The work order M2-90-15362 (RM-8262) and not un the equipment ID supplied.
used to accomplish the flov switch upgrade on RM-8123 is M2-90-07692.
I A copy of completed work order M2-90-15362 vas reviewed.
This reviev yielded the following facts:
The tagging block had been changed f rom "N" to YES.
The department approval date was January 5, 1991.
and date:' January 11, Operations pre-approval signature, time of 0948 1991.
Tag clearance number recorded: 2-81A-91 with an Operations approval time of-1345 and date: January 11, 1991.
l
j Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Comaission A09449/Page 6 May 6, 1991 Review of the Tag Log Sheet indicates the' tags vere hung on January 14, 2 of the work order was 1991, and the " Tagging Verified By" block on Page 1991.
In addition, initialed by the responsible individual on January 14 copy of work order M2-90-07692 (RM-8123) vas reviewed and verified to ahave a tagging sheet attached, along with subsequent job supervisor verification initials.
Vith a flow switch upgrade of this type, there is preliminary work that can be done prior to actually requiring the equipment to be tagged out of service.
Tagging then vould be requested to support the safe performance of the installation activity as it becomes necessary. This confines the downtime of equipment to what is actually required to perform the task in a safe and efficient manner.
Response
l In the case of the RM-8262 flov switch upgrade, preliminary work vas accor.pli shed.
At a time the assigned Instrument Specialist deemed was requested,
- provided, and verified to be tagging necessary, The remaining vork vas then accomplished and the work order sa tis f ac to ry.
completed and signed of f on January 18, 1991.
work order was authorized with an initial tagging designation of "NO".
The Once the preliminary work vas accomplished, the installation activity vas then performed using tagging.
As indicated in ACP-0A-2.06A, Rev.
18 additional
" Station Tagging", the job supervisor is responsible to request and tagging if the tagging in place is felt to be inadequate.
switching vas no indication that a problem existed with the tagging or that at There any time the work environment was considered to be unsafe. All vork vas accomplished in accordance with approved procedures and no generic implication exists.
our reviev and evaluation, we find that none of these issues taken After either singularly or collectively present any indication of a compromise of nuclear safety. Ve appreciate the opportunity to respond and explain the basis for our actions. Please contact my staff if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANT Ad/
E. J.F 'czka' g
Senio Vice President ec:
V.
J. Raymond, Senior Resid :nt Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor Projects
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Docket No. 50-336 A09449 l
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ATTACIDGNT NO.1 MILLSTONE NUCLEAR POVER STATION, UNIT NO. 2 RI-91-A-0010 NCR 291-008 i
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NCR 291-008 1
Disposition This NCR concerns use of eight steam generator mock-up studs j
These studs were required for use in the il SG HL manways Six i
due to the lack of available replacement bolt material.
inspected under MRIR of the eight studs were receiptand the remaining two under MRIR
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289-209-1..-The i
studs were subsequently released for use in the steam 283-102-1 generator manway mock-up assembly.
i The use of the bolting for mock-up training of the steam j
generator manway tensioner has not adversely impacted boltSteam gener quality or fatigue loading.
and primary manway tensioning utilizes the same hydrau
.i skid.
I valve setting and the existing tensioning procedure. loading of the i 83-031-254GP rev 0 and Therefore, design evaluation (FUSCo calculationthe mock-up studs were tensioned 1).
In the unlikely event, to the maximum pump pressure of 25,000 psig, the resultantThis value is be stud stress would be 66 ksi.
Prior to stress of 130 ksi for the bolting material. installation in the Stea r
visually examined in accordance with Examination Procedure This inspection meets the requirements of preservice examination of ASME class 1 bolting and precludesA ASME s NU-VT-1.
l bolt damage prior to installation.
replacement plan will be generated for the boltingthis NCR shall be dispositionl installation.
As a result, r
as "use-as-is".
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L al 1/4/91 Prepared by:
Approved by:
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