ML20036B270
| ML20036B270 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/01/1991 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20036A053 | List:
|
| References | |
| FOIA-92-162 NUDOCS 9305180429 | |
| Download: ML20036B270 (13) | |
Text
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f UNITED STATES NUCLEAR REGULATORY COMMISSION l
g 8
REGloN I I
5 475 ALLENDALE ROAD
%...o /[
KING oF PRUSSIA. PENNSYLVANIA 1961415 i
JUL 01 El 1
)
Docket Nos. 50-336 File Number RI-91-A-0145 Northeast Nuclear Energy Company ATrN:
Mr. E. J. Mroczka Senior Vice President - Nuclear l
Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
i The U.S. Nuclear Regulatory Commission recently received information concermng acuvities l
at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and !
followup.
f We request that the results of your review and disposition of these matters be submitted to i
Region I within 30 days of the date of receipt of this letter. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such informatio shall be contained in a separate attachment which will be withheld from public disclosure.
l The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91-A-0145 when providing your response.
The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public Document room.
The response requested by this letter and the accompanying enclosure are not subject to i
clearance procedures of the Office of Management and Budget as required by the Paper l
Reduction Act of 1980, PL 96-511.
9305180429 930216 i
HUBBARD92-162 PDR 9
f i
i
9 Northeast Nuclear Energy Company 2
-Your cooperation with us is appreciated. We will gladly discuss any questions you have concerning this information.
Sincerely, ML F
Char s W. Heh, irector Division of Reactor Projects
Enclosure:
(10 CFR 2.790(a) Information) cc w/o encl:
Public Document Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut bec w.' enc 1:
W. Raymond, SRI, Millstone Allegation File, RI-91-A-0145 J. Stewart E. Kelly T. Shediosky l
l l
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D RIBUTIO -
T FOR PUBLIC l
i ENCLOSURE l
On June 12,1991, preventive maintenance action was authorized on an environmentally qualified component without the proper quality controls. A Non-QA-work order (two-page AWO) was used to perform work on the motor operator for the "B" Shutdown Cooling Heat Exchanger to "C" HPSI Pump Suction Valve (2-SI-662) in violation of Administrative Control Procedure ACP-QA-2.16. Specifically, the inspection governed by 2701J-7,2701J-10, and 2701J-11 may require the addition of grease or other consumables. The addition of grease or other consumables, if not properly controlled as would be done using QA work orders, disqualifies the equipment qualification.
Request Please discuss the validity of the above assertion. Were the EEQ boundaries affected by this preventive maintenance activity? If deficiencies are found in work control and/or procedures, please notify us of the corrective actions you have taken to prevent l
recurrence. Please provide us with an assessment of the significance with regard to safety of any identified deficiencies.
L -
DISTRIB T FOR PU LOSURE
\\
h SY 0l N
f 3s S hn a, 7.0 DRAWING CONTROL Tom Hunt Allegation Nos. RI-88-A-040-29.01 RI-91-A-052-01 RI-91-A-077 RI-91-A-082-01 RI-91-A-143-01, -02, -03, and -04 l
RI-91-A-163 t
implementation of drawing changes to electrical connection and schematic The drawings was reviewed to evaluate the effectiveness of the design changes controls.
Six concerns have been expressed to the NRC over the previous twenty-two (22) months regarding topic area for Unit 2.
Several of these issues are addressed in the licensee's letters to the NRC dated August 9, 1991 (two letters), August 16, and 30, and September 27, 1991.
7.1 Design Changes Are Not Incorporated Into Drawings Two concerns expressed in 1991 pertained to changes in equipment configuration i'
that wasn't reflected in the drawings at the plant.
One dealt with wiring l
changes in a breaker cubicle, the other with changes not shown on all applicable l
drawings for reactor coolant pump (RCP) temperature monitoring circuits.
3 l
Assessment The wiring concern involved modifications to a terminal strip in a high pressure safety injection system valve motor operator breaker.
Wires were attached on terminals marked as spares on the current revision of the drawing in the aperture card system. The Generation Records Information Tracking System (CRITS) showed the breaker's drawings had open drawing change requests (DCRs) against them. The design change packages (PA 84-063) and the drawings showed the " spare" tenninals in use. The DCR packages showed that GRITS had been updated in 1990 for both of e
the drawings to reflect the open DCRs. This change package is not yet complete, therefore the revisions will not be issued until af ter all modifications are completed and the system is turned over for operation. This modification is to provide a common totor control center alarm of a thermal overload condition. The licensee has lifted the power leads at the control room annunciators to remove the electrical voltage from the spare terminals.
The concern about the RCP RTD circuit involved replacing knife switches with Weidemuller test blocks, and then not making the change on all of the drawings i
that showed these components. Sheet No. 5 of drawing 25203-31069 was not updated at the time of the modification. GRITS has now been updated to show that this-l drawing had an open DCR against it in 1989. The change package was completed and submitted for drawing revisions and closeout in 1990.
The as built was modifications are reflected in this package and show the new test blocks on the t
drawing. There is currently no projected date for the new revision to be issued.
l Department instructions require that drawings be checked to ensure the latest revision is in-hand, prior to use for quality work. There does not appear to be any administrative control procedure requirements for this to be done however.
Training records showed the individuals expressing the concerns had been trained on using plant drawings. The demonstration of the current CRITS training showed a potential weakness regarding the need to check for open changes to a drawing and how this check is done.
The Desi n Document Screen uses a status code to indicate if a change exists E
against the current revision. Checking this only requires a single keystroke, but it is possible and perhaps likely that plant personnel may key on the current revision. If the revision agrees with the drawing in-hand, it is probable that rao further checking may be performed.
-Contributing to this problem is 14 i
t
/
l
/
J
The discrepancies included undocumented sub-components and incorrectly wired components.
These contributed to inadequate safety tagging of a radiation monitor in one instance and the inoperability of an automatic function in another.
A lifted lead prevented the automatic isolation and purge function of RM-8132.
Following the discovery, a plant incident report, PIR 91-65, was generated and Engineering " red-lined" (reviewed the as-built status of the monitors with respect to the drawings) the drawings for the RM-8132 and RM-8168 monitors.
Several discrepancies were noted. These were either corrected, in the case of the lif ted lead and miss wired sample fan control; or, had a DCR (Reference DCR M2-P-081-91) submitted to correct the drawing to reflect as-built status.
Additionally, the surveillance procedure for RM-8168 has been changed to test the automatic isolation and purge function.
The other three monitors had differences in the viring of a terminal board from that shown on their respective power flow drawings.
Review of these drawings showed a change was made and was not reflected on all of the drawing associated with each monitor. The conne:: tion and block diagram drawings for the instruments showed this change, but the power flow drawing did not.
An inspection of RM-8434B confirmed the as-built status of this instrument confirmed the concern expressed to the NRC. I&C engineering is now aware of the discrepancy and is submitting changes to the power flow diagram reflecting the as-built status.
Conclusion The inspector concluca cLt, based on these employee concerns, plant personnel are not consistently u;f r.g the drawing control system to validate drawings prior to their use. Additions 1 instruction may be necessary to insure that all workers are properly using this system. Also, there are weakness in coordinating vendor information into controlled drawings.
P 16
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.i RECORD OF ALLEGATION PANEL DECISIONS 1
SITE:
/h s c sroa E 2.-
PANEL ATTENDEES:
f ALLEGATION NO.:
R1 - 9 /- A - 01 +/
Chairman - o/ i 6 s uv.s DATE: 6 -M-9 /
(Mtg.@2345)
Branch Chief -
~
PRICRITY:
High Mecium @
Section Chief ( AOC) - K6LLEy/(A ENus i
SAFETY SIGNIFICANCE: Yes No Others - mATA (,5 E A s uc K j
DD h SC s h a a_ r v 4 A uc_ R gymosD.
CONCURRENCE TO CLCSEOUT:
g CCNFIDENTIALITY GRANTED: Yes @
S 9E o c o s & /s A e ih nog s-r-i f
(See Allegati:n Receipt Report) i
- I 1
IS THEIR A 00L FINDING:
es No 9
l 1
IS : HILLING EFFEC ~.ETTER WARRANTED:
Yes No l
HAS CHILLINF ::FECT LETTER EEEN SENT:
Yes No HAS L' :NSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No l
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RECORD OF ALLEGATION PANEL DECISIONS SITE: j%cc 3 raq L_.-
PANEL ATTENDEES:
l
.l ALLEGATION NO.:
82 r - 9 / - A - D I'44' Chairman -
W/(.6'e I i
i DATE: (.;> - / 9 - 9/
(Mtg.@2345)
Branch Chief -
j PRICRITY:
Hign Mecium h Section Chief (AOC) - <dt.cr y SAFETY SIGNIFICANCE: Yes No Others - A A %C s 's, EArt ic.,<
l 2
CONCURRENCE TO CLOSEOUT: DD @ SC
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Anest : /oymoe CONFIDENTIALITY GRANTED: Yes Ssto4_ea y s <3,'c s otrer-(See Allegation Receipt Report) h c
j j
i 15 THEIR A 00L FINDING-Yes No l
f IS : HILLING EFFhi LETTER WARRANTED:
Yes No i
HAS CHILLY EFFECT Lt its et:N SENT:
Yes No j
i i
HAS L ENSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No i
i
- l ACTION
l I) T/O Z M
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4) 5)
NOTES:
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$8 Mr. E. C. Venzinger, Chief U. S. Nuclear Regulatory Commission i
A09163/Page 4 December 21, 1990 of a routing sheet by the PMMS planner as a means to coordinate revision development. The current routing sheets being issued by the PMMS planner include a flovpath of possible desired reviewers.
It is up to the PMMS planner to indicate what scope and the number of reviews necessary for any l
l given revision.
1 The concept of each procedure having a procedure ovner was implemented in 1988 to make the procedure review and revision process more effective and efficient. Previously, procedures vere not assigned individual responsibility 1
below the department head level. This concept has proven effective in allowing the procedure ovner to be the focal point for resolving issues associated with the procedure.
4 The refueling outage vide range nuclear instrumentation vork activities were assigned primarily to one I&C specialist. This specialist was assigned to dayshift throughout the outage. During the work activity, he found the 4
existing procedure deficient and prepared the necessary revision. The PMMS planner, with the department head's concurrence, deleted the normal practice of having one of the reviews done by the procedure owner. The basis for this change in the normal department practice was the availability of other and better qualified reviewers. The procedure "ovner" was on nightshift during this time frame and vas involved in other important issues of his ovn.
Response
Revision 3 of IC-2417H vas not reviewed by the procedure "ovner".
Adequate review in lieu of the procedure "ovner" did occur. This issue was raised by the procedure "ovner" and vas addressed by the department head.
RI-90-A-0202 Issue 1 Authorized Vork Order M2-90-00579 is a one-page AVO for annual preventive maintenance (PM) on various limitorque operators. A note on the AVO says that the performance of the PM vill not affect EE0 boundaries.
However, ACP-2.16, Page 21, Item D states that all maintenance work or EE0 examinations be documented on three-page AV0s.
Vas the one-page AVO appropriate for this maintenance item? Vere there a.
proper EQ revievs't
Response
In 1986, Unit 2 Maintenance reviewed PMs involving EE0 equipment in order to determine which PMs did not affect EE0 boundaries. As a result of this evaluation, AV0s for PMs that do not affect EE0 boundaries contain the statement, " NOTE: The performance of this FM will not affect the EE0 boundaries per R. Bonner 3/31/86".
Based on a request from Unit 2, a p
k
Mr. E. C. Venzinger, Chief U. S. Nuclear Regulatory Commission A09163/Page 5 December 21, 1990 letter of clarification to NEO Procedure 2.21 vill be issued by the Director of Generation Engineering and Design to clarify that inspection:
and PMs of EEQ equipment that do not impact any EQ attributes may be performed on non-QA work orders.
b.
Vere single page AV0s appropriate in the past to ensure EQ requirements were satisfied? (If a review of single page AV0s is conducted, please discuss the sample size and effort to ensure that the sample is representative).
Response
Unit 2 Maintenance and Unit 2 Engineering conducted a review of all one-page AV0s (152 AV0s) that had been written for EEQ equipment. The result of the review indicated that none of the AV0s vere actually used to direct any EEQ activities, and therefore, no challenges to EQ requirements were created by the use of one-page AV0s on the associated equipment.
c.
ACP-0A-2.16 was revised on September 11, 1990 to require that maintenance on EE0 equipment be documented on three-page AVos (Reference MM-90-214, dated November 5, 1990). Why was this revision required?
Response
The revision to ACP-0A-2.16 was part of :he periodic review of procedures.
The paragraph specifying the use of QA AV0s was primarily revised to address E0 equipment replacements (Section III.d, paragraph 2).
The vord changes to paragraph 1 of Section III.d *.ere not meant to change the intent.. As stated in the response to Item 1 above, a clarification to this concern vill be issued.
d.
Are motor-operated valve cover gaskets replaced or are torque switch settings changed when using single page AV0s? If so, is this satisfactory to ensure EE0 requirements?
Response
As stated in the response to Item 2 above, Unit 2 Maintenance reviewed all one-page AV0s that had been written for EEQ equipment. There were no one-page AV0s written, nor vere there any descriptions of actual work performed to change torque switch settings or replace motor-operated valve cover gaskets.
Issue 2 Authorized Vork Order AVO M2-90-12648 required electrical re-termination of valve 2-MS-190B.
How and for how long was the termination that needed to be redone a.
incorrect?
4 i
Mr. E. C. Venzinger, Chief U. S. Nuclear Regulatory Commission A09163/Page 6 December 21, 1990
Response
The solenoid valve for 2-MS-190B vas inadvertently de-terminated during testing by ILC (AVO M2-90-08571) on August 14, 1990. AVO M2-90-08697 vas written to re-terminate the SOV vith Raychem on August 15, 1990, and the job vas completed on August 17, 1990. The termination was removed for inspection by AVO M2-90-12648 on October 30, 1990 and re-terminated the same day.
Vas there a safety impact due to the original deficient termination?
b.
Response
An er.gineering evaluation of the safety impact was performed by Unit 2 Engineering as part of the response to Plant Incident Report 90-143.
termination.
There was no safety impact due to the original deficient What were the circumstances that caused the AVO to be prepared?
(i.e.,
Hov was the deficiency discovered? What was the cause of the deficiency?)
c.
Response
Based on discussions with the OC inspector and other electricians, a Unit 2 electrician expressed a concern that the termination for 2-MS-190B was not done properly. The electrician discussed his concern with the Unit 2 the Maintenance Manager who directed the electrician to inspectAVO M2-90-12648 termination and to re-terminate the connection correctly.
The AVO vas written to inspect and re-terminate the solenoid connections.
included the re-terminating task because the termination could not be thoroughly inspected without destroying the splice.
Vas there a OC hold point or similar reviev that should have prevented the d.
deficiency in the original termination.
Response
The deficiency with the original termination was that there was unqualified braided material that was covered by the Raychem splice which An in turn caused the splice to be unqualified from an EE0 standpofnt.
inspection plan with a specific inspection sheet for this type of Raychem The splice was included in the AVO for the original termination.
there be, "1.
No inspection sheet specified under cable preparation that This attribute was signed braided jacket or non-qualified material...".
off satisfactorily with no open items by a OC inspector.
j l
l Additional Discussion of Issue 2 t
As stated previously, a Unit 2 electrician expressed a concern that the I
i Since solenoid valve for 2-MS-190B may not have been terminated correctly.
l l
Mr. E. C. Venzinger, Chief U. S. Nuclear Regulatory Commission A09163/Page 7 December 21, 1990 2-MS-190B is on our EOML, the electrician was directed to remove and investigate the existing termination and re-terminate the solenoid valve correctly.
The "as found" termination was inspected by two Unit 2 electricians and a OC All agreed that the braided material on the solenoid valve leads inspector.
appeared to be under the Raychem sealing leg of the breakout which is not acceptable for an EO termination. The termination was removed and replaced.
The termination that was removed vas given to a Maintenance engineer for The termination was partially cut open, and it was destructive examination.
that the braided material had not been removed from the solenoid valve evident leads.
An NCR (290-362) vas generated to document the non-conforming termination and the associated rework. A PIR (90-143) was initiated to address reportability of the incident. The PIR vas dispositioned as not The partially opened termination and a copy of the inspection reportable.
for the original termination vere turned over to the Quality Services sheet so their involvement with the original termination could be Department The Electrical Supervisor had a discussion with the Job investigated.
Supervisor concerning the problem with the original termination and the importance of following procedures.
After our review and evaluation, ve find that none of these issues taken 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 members of my staff if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMP.WY
.M)
E. J.jftfr'oczka v Senior Vice President V. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 ec:
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51 RECORD OF ALLEGATION FANEL DECISIONS SITE:
/h sut svoa N 2- -
PANEL ATTENDEES:
ALLEGATION NO.:
R 'E Cf /- A - 014[
Chairman - w i 6 s m.s j
DATE: G -N-9 /
(Mtg.(1)2345)
Branch Chief -
PRIORITY:
High Mecium @
Section Chief ( AOC1 - KEs LE y No Q Others - M ATA (,'.s E A s uc.<
j SAFETY SIGNIFICANCE: Yes CONCURRENCE TO CLOSEOUT: DD SC s ha r._f ve's h e g e R p ym o s p; CONFIDENTIALITY GRANTED: Yes @
s # E o c o I W 9 A 6 [6 9 og sT~
(See Allegation Receipt Report) l i
IS THEIR A DOL FINDING:
es No l
I IS CHILLING EFFEC ~ ETTER WARRANTED:
Yes No j
HAS CHILLIN cFFECT LETTER EEEN SENT:
Yes No i
HAS L' :NSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No i
ACTION.
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August 16, 1991 Docket No. 50-336 A09661 RE: Employee Concerns Mr. Charles V. Behl. Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I l
475 Allendale Road King of Prussia, Pennsylvania 19406 i
Dear Mr. Behl:
Millstone Nuclear Pover Station, Unit No. 2 RI-91-A-0145 i
have completed our reviev of identified issues concerning activities at VeHillstone Station. As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information.
The material contained in this response may be released to the public and placed in the NRC Public Document Room at your discretion.
The NRC letter and our response have received controlled and limited distribution on a "need to knov" basis during the preparation of this response.
ISSUE:
On June 12, 1991, preventive maintenance action was authorized on an A
environmentally qualified component without the proper quality controls.
Non-0A vork order (two page AVO) vas used to perform work on the motor operator for the "B" Shutdown Cooling Heat Exchanger to "C" EPSI Pump Suction Valve (2-SI-662) in violation of Administrative Control Procedure Specifically, the inspection governed by 2701J-7, 2701J-10 ACP-0A-2.16.
The and 2701J-11 may require the addition of grease or other consumables.
addition of grease or other consumables, if not properly controlled as vould be done using OA vork orders, disqualifies the equipment qualification.
Please discuss the validity of the above assertion.
Vere the EE0 affected by this preventive maintenance activity?
If boundaries are found in vork control and/or procedures, please notify us deficiencies you have taken to prevent recurrence.
Please the corrective actions of us with an assessment of the significance vith regard to safety of provide any identified deficiencies.
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Mr. Charlas V. B;hl, Director U. S. Nuclear Regulatory Commissicn A09661/Page 2 August 16, 1991
. Response:
~ Tha Automated Vork Order (AVO) in question was M2-90-06370.
The AVO vas issued as a non-0A AVO in accordance with the clarification to the Environmental Qualification Program provided via a meno from the Generation Engineering Department relating to preventive maintenance on EE0 components.
Based on the concerns of the Job Supervisor and the Quality Services Department (OSD) regarding vork on EE0 components without a OA vork order, the work vas not performed. Since no work was performed, no EE0 boundaries were affected and the assertion stated in the above issue is not valid.
to this job, NNECO has re-evaluated its guidance on the conduct Subsequent of EE0 Maintenance and has elected to withdraw the guidance memo referenced above.
Therefore, all maintenance performed on EE0 equipment vill be performed on OA or three-page work orders.
The QA Lubrications Program is currently being incorporated into applicable administrative procedures for Millstone Station. When the revisions to these procedures have been completed and approved, NFICO vill review the Maintenance Forms associated with the Preventive Maintenance Program and revise these forms as necessary.
After our review and evaluation, we find that this issue did not present indication of a compromise of nuclear safety. We vere avare of this any concern as a result of the Job Supervisor bringing the issue to management's attention.
Actions were taken to address the issue and maintain appropriate control over EE0 boundaries. Ve recognize the need to strive for a higher level of performance while performing EE0 Maintenance and we are aggressively vorking towards this objective. Ve appreciate the opportunity to respond and explain the basis of our actions. Please contact my staff if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Mroczka Senior Vice President O
BY:
V. D. Romberg Vice President cc:
V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2,,
and 3 E.
C. Venzinger, Chief. Projects Branch No.
4, Division of Reactor Projects E. M. Kelly, Chief, Reactor Projects Section 4A i
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