ML20128L108
| ML20128L108 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/12/1985 |
| From: | Mccabe E, Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20128L096 | List: |
| References | |
| 50-213-85-15, NUDOCS 8507240302 | |
| Download: ML20128L108 (6) | |
See also: IR 05000213/1985015
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-213/85-15
Docket No.
50-213
License No.
Licensee:
Connecticut Yankte Atomic Power Company
P. O. Box 270
Hartford, CT 06101
Facility Name: Haddam Neck Plant, Haddam, Connecticut
Inspection at: Haddam, Connecticut
Inspection conducted:
_ June 14-26, 1985
Inspector:
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Paul D. Swetland, Senior Resident Inspector
Date
Approved by:
f% AO
7 h2 /H
E. C. McCabe, Chief, Reactor Projects Section 3B
Date
Inspection Summary: Special onsite inspection to review the licensee's design
change / modification control activities related to the plant process computer re-
placement project; and a licensee identified degradation of control room fire pro-
tection equips.ent during these modifications on May 29, 1985.
The inspection in-
volved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> by the senior resident inspector.
The inspection identified violations of licensee design review and safety evalu-
ation procedures and of onsite review committee activities (Detail 5.1).
Weak-
nesses were also identified with regard to licensee implementation of prompt and
effective corrective action (Detail 5.2 and 5.3).
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DETAILS
1.
Persons Contacted
- J.
E. Beauchamp
Quality Assurance Supervisor
- G. H. Bouchard
Station Services Superintendent
- T. J. Bransfield
Fire Protection Engineer
- J.
L. DeLawrence
Acting Engineering Supervisor
- L. S. Ferenchik
Betterment Construction
- J. H. Ferguson
Unit Superintendent
- R. H. Graves
Station Superintendent
- G. L. Johnson
Director, Generation Engineering & Design
J. Lewis
Betterment Construction
- P. F. L'Heureux
Assistant Engineering Supervisor (Mechanical)
- R. F. Lucas
Generation Construction
J. M. Mietliki
Betterment Construction
- E. M. Mroczka
Vice President, Nuclear Operations
- J. J. Roncaioli
Fire Protection Engineering
- G.
J. Silberquit
Associate Engineer
- G.
H. Tylinski
Assistant Engineering Supervisor (Electrical)
- G.
P. VanNoordennen
Licensing
- Denotes those present at exit interview.
2.
Description
During the implementation of an approved plant modification on May 22-23, 1985,
the licensee identified a problem in the scope of the approved work.
Three
control room smoke detectors were to be removed as part of facility modifica-
tiens supporting the plant process computer replacement project.
However,
these detectors are required to remain operable by Technical Specifications
(TS), and no relief or amendment to this requirement had been sought.
For-
tuitously, the detectors had not yet been removed, but their performance had
been degraded by the removal of the suspended ceiling in which the detectors
were installed.
The licensee took action on May 24, 1985, to delay detector
removal until the TS change process could be completed.
Action to restore
full operability to the detectors was initiated on May 29.
The details of
the occurrence, its cause, and the adequacy of licensee's corrective action
are listed below.
3.
Background
The plant process computer replacement project has been ongoing since 1980.
This project involves procurement and installation of hardware and software
components to support a significant upgrade in process computer capability.
The new computer hardware will be installed and tested in place prior to
swap-over, during a refueling outage, of plant computer functions from the
present hardware.
In order to support the new hardware installation, facility
modifications were planned including new air-conditioning, power supplies,
input interface devices, and fire protection systems.
These modifications
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were. located in the rear of the control room complex where the existing com-
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puter room and operations office are located.
This area is presently pro-
tected from fire.by three of ten smoke detectors from the control room fire
detection system.
Plant TS 3.22 requires 8 out of 10 of these detectors to
remain operable.' Otherwise, compensatory fire patrols must be established.
The facility modifications supporting the computer replacement work were in-
itiated_and in progress during May
June 1985.
The approved scope of work
for.this project included the removal of the three control room smoke detec-
tors located.in the plant computer area. The project will ultimately install
a Halon fire suppression system in this area.
Licensee corrective actions for 1983-84 design change control problems in-
cluded a major review and revision of design change control procedures.
Staff
retraining in this area was conducted during the period November 1984 - Feb-
ruary 1985 with particular emphasis on the licensee's " Nuclear Safety Ethic"
which stresses correct performance of jobs'the first time.
An NRC crdered
independent review of the design change control process is currently underway.
4.
Sequence of Events-
The project specifications and plant design change request (PDCR) for the
first phase of the computer replacement project were developed in early 1985.
Both documents clearly specified the removal of the three smoke detectors in
the rear of the control room as part of the approved work scope.
During the
design change review process in March-April 1985, the PDCR package was inde-
perdently reviewed by several individuals in the corporate engineering or-
ganization.
These reviews were conducted in accordance with approved quality
assurance procedures, and certified the acceptability of the project with re-
gard to the provisions of 10 CFR 50.59.
On May 1-8, 1985, the PDCR received
further review by the site engineering staff.
PDCR 713 was reviewed by the
Plant Operations Review Committee (PORC) and approved for implementation.by
the Station Superintendent on May 9, 1985.
None of the review processes cited
above identified that the removal of control room fire detectors would require
NRC approval of a TS change prior to implementation of this work item.
A work order initiating the facility changes (air conditioning and structural
modifications only) was approved on May 13, 1985.
During the removal of the
suspended ceiling structure holding the 3 smoke detectors, the need to remove.
the interfering detectors was identified by the betterment construction or-
ganization on May 22, 1985.
Upon-requests to the plant and corporate engi-
neering staffs as to the appropriate means for removal of the detectors, the
fact that the detectors could not be removed without TS action was identified.
On May 23, the plant engineering supervisor issued a memorandum to construc-
tion indicating that the detectors would not be removed. The detectors re-
mained energized and suspended at their normal location, however the ceiling
was no longer there to act as a collector for the detectors. The overhead
ceiling was 6-8 feet above the detectors.
A memorandum from fire prote: tion
engineering to construction on May 24, 1985 proposed alternatives regarding
-the TS requirements for these detectors.
These alternatives included sta-
tioning a permanent fire watch or relocating the detectors. Another memoran-
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dum from plant engineering to the corporate project engineer on May 24 indi-
cated that the original design change package was inadequate because the TS
change required to remove the existing smoke detectors was not identified in
PDCR 713.
A revision to the PDCR was recommended.
On May 28, 1985 a fire protection engineer observed the condition of the
modified smoke detector arrangement in the work area.
He concluded that the
removal of the ceiling around the detectors degraded the effectiveness of the
detectors and notified construction that the detectors were not fully operable
in the present configuration.
Construction personnel notified plant engineering of the degraded condition
of the 3 smoke detectors on May 29, 1985. The plant declared the detectors
inoperable and initiated a roving fire patrol in accordance with TS 3.22.E.1.
The licensee used a conservative criterion to verify detector operability.
The detectors were required to be within 12 inches of the ceiling to be oper-
able. On May 29, the detectors were moved closer to the ceiling, however the
12 inch criteria was not clearly specified or achieved.
A plant engineering
memorandum to Operations dated May 29, 1985 lifted the requirement for the
compensatory fire watch because the detectors had been relocated to within
12 inches of the ceiling.
No physical verificat. ion was pe? formed to justify
this conclusion, but the fire watch was terminated on May
.9, 1985.
The plant engineering department initiated a Plant Informatlon Report (PIR
85-81) on May 29, describing the violation of TS 3.22 which existed from May
22 - 29 because the 3 smoke detectors had been rendered inoperable without
establishing a compensatory fire watch.
Immediate corrective actions based
on this PIR were limited to the engineering memoranda documented above, re-
stricting the removal of the detectors and requesting action to initiate a
TS change request.
On June 13, 1985 during routine followup of PIR 85-81, the inspector identi-
fied that the smoke detectors were not actually located within 12 inches of
the ceiling.
This condition was brought to the licensee's attention and the
detectors were raised from their positions about 18 - 30 inches below the
ceiling to within the 12 inch specification.
During a meeting with plant management on June 14, 1985, the inspector related
NRC concerns regarding this event including continued design change review
failures, potential violations of TS 3.22 and 10 CFR 50.59, and ineffective
corrective action to prevent recurrence of such failures.
The licensee indi-
cated that that the problems had been self-identified, that action had been
taken to correct the inoperable detectors and prevent their removal, and that
any further corrective action would result from later reviews of the incident.
.On June 18, 1985, the Senior Vice President, Nuclear Engineering and Opera-
tions, issued a summary of the problems related to PDCR 713 to all supervisory
personnel and reminded them that increased diligence and attention to detail
is necessary to insure that jobs are done correctly.
Assignments to review
the event and develop corrective action were initiated at the corporate level.
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During a subsequent PORC review of this event, the committee adopted guide-
lines to improve their PDCR review process.
These included review of.PDCRs
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'at special meetings exclusive of routine business and with enhanced quorum /
attendance rules.
Consideration of " walk-in" PDCR review requests was limited
to abnormal / emergency situations.
5.
Findings-
5.1 PDCR'713 was generated, reviewed and approved authorizing the removal
of TS required fire detectors.
Personnel involved with the design re-
view, safety evaluation and PORC review of this modification all missed
the TS relationship.of_these detectors and the interface aspect of the
.specified work' scope to existing. plant requirements.
The omission was
identified _ prior to removal of the detectors, and final operations de-
.partment. release of the detectors had not yet been requested or granted.
Nevertheless, the ongoing project work resulted in an unreviewed degrad-
ation of the performance of the 3. smoke detectors when the ceiling was
removed around them.
TS 6.8 and 10 CFR 50, Appendix B, Criterion V re-
quire. quality-related activities including design change control to be
- conducted in accordance with approved procedures.
The generation, review
and safety. evaluation of-proposed design changes are prescribed by Ad-
ministrative Control Procedures ACP 1.0-3.1 (NEO 3.03), Preparation, Re-
view and Disposition of Plant Design Change Requests, and NEO 3.12,
-Safety Evaluations.
These p'rocedures require in Steps 6.5 and 6.2.4,
respectively, that the impact of proposed design changes on plant TS be
determined.
The licensee's failure to correctly identify the TS re-
quirement.for the 3 control room smoke detectors during the required
reviews constitutes a violation of these procedural requirements (213/
85-15-01).
TS 6.5.1 requires the PORC to advise the Station Superintendent on all
proposed changes or modifications to plant systems that affect nuclear
safety.
The PORC review of PDCR 713 on May 9, 1985 failed to identify
that the removal of 3 smoke detectors detailed in the work scope would
exceed the Limiting Conditions for Operation for the control room fire
detection system specified in TS 3.22, Fire Protection.
This is a vio-
lation (213/85-15-02).
5.2 The TS problem with the approved work scope of PDCR 713 was identified
.on May 22-23 1985.
The licensee took action to stop the removal of the
required smoke detectors and to start administrative action to change
the TS requirements and to revise the PDCR package.
The purpose of lic-
ensee procedure NE0 2.18, Corrective Action, is to identify and correct
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quality-related problems efficiently.
NE0 2.18 provides one of several
means by which corrective actions are identified and followed.
None of
the corrective action procedures cited in NEO 2.18 were initiated for
the PDCR_713 design review problems.
Although action to prevent removal
of the detectors was taken, as was some action that increased detector
system sensitivity, no formal recognition, documentation or initiation
of action to prevent recurrence of these design review errors was iden-
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tified until the June 18, 1985 initiation of action by the Senior Vice
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President. -The timeliness and effectiveness of corrective actions for
the design change review inadequacies which caused this will remain un-
resolved pending completion of the licensee's corrective action program
(UNR 213/85-15-03).
5.3 On May 29, 1985, the licensee documented a violation of TS 3.22.E.1, in
that 3 out of 10 control room fire detectors had been rendered inoperable
(8 of 10 detectors must be operable) because.the ceiling above the de-
tectors had been removed; A detailed evaluation of the control room fire
detection system would later reveal that the detectors had been degraded
-by the removal of the ceiling, but the detectors and the system remained
During the period May 28 - June 14, 1985, however, the licen-
see conducted corrective actions using a conservative criterion which
assumed that the detectors must be within 12 inches of the ceiling to
be operable.
The inspector reviewed the implementation of licensee cor-
rective actions for the reported TS violation which was first identified
onsite by a fire protection engineer on May 28, 1985;
The licensee's corrective actions in this case were not timely because
a delay in reporting the identified degradation in control room fire
protection to plant personnel resulted in extending the period of ap-
parent violation of a TS Limiting Condition for Operation for several
hours.
Neither were the corrective actions effective because the iden-
tified discrepancy (detectors not within 12 inches of the ceiling) was-
not corrected, in that the detectors'were only raised to within about
18 - 30 inches of the ceiling. This failure resulted in a further ap-
parent violation of TS 3.22 from May 29 when the compensatory fire watch
was terminated without verification of the actual location of the detec-
tors until June 13, 1985 when the NRC inspector identified the discre-
pancy in detector location.
Since NRC review of:the subsequent re-
evaluation of the smoke detector operability criterion has confirmed that-
the detectors remained operable throughout this period, no actual TS
violation occurred.
Nevertheless, the implementation of the licensee's
corrective action program based on the apparent violation was flawed.
The timeliness and effectiveness of corrective actions for the reported
TS violation will remain unresolved pending NRC review of the licensee
evaluation and response to these discrepancies (UNR 213/85-15-04).
6 .~
Unresolved Items
Unresolved items are matters.about which more information is required in order
to determine whether they are acceptable items or violations.
Unresolved
items identified during this inspection are discussed in Paragraph 5.
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7.
Exit Interview
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- The inspector met with-licensee representatives (listed in Paragraph 1) on
June 26, 1985.
The scope of the inspection and the findings were summarized.
No proprietary information related to this inspection was identified.
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