ML20128Q777
| ML20128Q777 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/08/1996 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigenbaum T, Harpster T NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9610210165 | |
| Download: ML20128Q777 (2) | |
See also: IR 05000245/1996004
Text
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October 8,1996
.
Mr. Ted C. Feigenbaum
Executive Vice President - Nuclear
Northeast Nuclear Energy Company
c/o Mr. Terry L. Harpster
P. O. Box 128
Waterford, Connecticut 06385
SUBJECT:
INSPECTION NOS. 50-245/96-04;50
34; 50-423/96-04
Dear Mr. Feigenbaum:
'
This letter refers to your letter dated July 17,1996, in response to our
June 6,1996 letter.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program.
Sincerely,
Original Signed Wy:
Jacque P. Durr, Chief
Reactor Projects Branch No. 6
Division of Reactor Projects
Docket Nos. 50-245;50-336; 50-423
cc w/ encl:
.
,
P. Richardson, Nuclear Unit 2 Director
M. Brothers, Nuclear Unit 3 Director
L. Cuoco, Esquire
Senior Vice President, Nuclear Safety and Oversight
W. Riffer, Nuclear Unit 1 Director
Vice President, Reengineering
Vice President, Nuclear Technical Services
F. Rothen, Vice President, Maintenance Services
I
cc w/cv of Licensee's Resoonse Letter:
V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Control
S. B. Comley, We The People
State of Connecticut SLO Designee
9610210165 961008
"
ADOCK 05000245
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Mr. Ted C. Feigenbaum
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Distribution w/ encl:
Region i Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
D. Screnci, PAO
C. O'Daniell, DRP
Distribution w/enci (VIA E-MAIL):
J. Andersen, NRR
W. Dean, OEDO
P. McKee, NRR/PD l-4
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M. Davis, NRR
Inspection Program Branch (IPAS)
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DOCUMENT NAME: P:\\9538RPL2.AUG
To receive a copy of this document. Indicate in the boa:
"C' = Copy without attachment / enclosure
"E' = Copy with attachment / enclosure
- N' = No copy
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OFFICE
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NAME
RUrban
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JDurr M
DATE
08/1/96
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OFFICIAL RECORD COPY
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Northeasi
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Utilities System
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sorth t vino semce comroy
P.O. Box 270
Hartford, cT 06141-0270
(203) 665 5000
July 17, 1996
Docket Nos. 50-336
B15783
Re:
U.S. Nuclear Regulatory Commission
Attention:
Document Control Desk
Washington, DC 20555
Millstone Nuclear Power Station, Unit No. 2
Reply to a Notice of Violation
NRC Combined Inspection 50-245/96-04
In a letter dated June
6,
1996,* the NRC Staff transmitted a
Notice of Violation (NOV) relating to NRC Inspection Report Nos.
50-245/96-04;
50-336/96-04;
and ,50-423/96-04.
The
report
discussed the results of the safety inspection conducted on March
19, 1996 through May 6,
1996, at the Millstone Station.
Based on
the results of the Staf f's inspection, one violation was cited at
Millstone Unit No.
2,
for an inadequate retest of a safety
injection
system
solenoid
valve
following
its
replacement,
thereby failing to reveal that the valve was inoperable due to a
missing part.
The Staff requested that Northeast Nuclear Energy Company (NNECO)
respond within 30 days of receipt of the letter transmitting the
NOV.
Accordingly, Attachment 1 to this letter provides NNECO's
reply to the NOV, on behalf of Millstone Unit No. 2,
pursuant to
the provisions of 10CFR2.201.
The following are NNECO's commitments made within this letter.
All other statements are for information only.
l
.
W.
D.
Lanning letter to
T.
C.
Feigenbaum,
"NRC Combined
,
'
Inspection
50-245/96-04;
50-336/96-04;
50-423/96-04
and
Notice of Violation," dated June 6,
1996.
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U.
S. Nuclear Regulatory Commission
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B1S783/Page 2
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Unit 2 - Violation
B15783-1
Surveillance Procedure SP 2604P,
" Engineered Safety
Features Equipment Response Time
Testing",
will be
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changed to require verifying that 2-SI-610, 2-SI-628,
2-SI-638, and 2-SI-648 close to satisfy the Technical
,
Specification Table 3.3.5 time requirements. This is
scheduled to be completed by August 31, 1996.
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B15783-2
An appropriate statement prohibiting disassembly of the
1
Solenoid Operated Valve
(SOV) will be placed in the
" Caution Note"
section
of
PMMS
for
the
94
safety
)
related Air Operated Valves (AOV).
This is scheduled
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to be completed by October 31, 1996.
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B15783-3
A site wide ef fort is in progress to upgrade the Post
3
Maintenance Testing procedure guidelines provided in
CWPC 3. This is scheduled to be completed by December
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31, 1996.
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If you have any questions regarding information contained herein,
3
please contact Mr. M.
D. Ehredt at (860) 440-2142.
very truly yours
,
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NORTHEAST NUCLEAR ENERGY COMPANY
,
FOR:
T. C.
Feigenbaum
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Executive Vice President and
,
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Chief Nuclear Officer
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By:
t
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E. A.
DeBarba
Vice President
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cc:
T.
T. Martin, Region I Administrator
D. G. Mcdonald Jr.,
NRC Project Manager, Millstone Unit
No. 2
P.
D.
Swetland,
Senior Resident Inspector, Millstone
Unit No. 2
Subscribed and sworn to before me
this
/7d day of
L/v
1996
,
c 4/ n FLnJL
Date Commission Expires:
/2/3g/97
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Docket No. 50-336
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B15783
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Attachment 1
Millstone Nuclear Power Station, Unit No. 2
Reply to a Notice of Violation
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Inspection 50-336/96-04
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July 1996
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U. S. Nuclear Regulatory Commission
B15783/ Attachment 1/Page 1
Restatement of Violation A
Part 50 of Title 10 of the Code of Federal Regulations, Appendix
B,
Criterion XI,
" Test Control," requires that a test program
shall be established to assure that all
testing required to
demonstrate that structures, systems, and components will perform
satisfactorily
in
service
is
identified
and
performed
in
accordance with written test procedures
that incorporate the
requirements and acceptance limits contained in applicable design
documents.
Contrary to the above, the retest of the 2-SI-618 solenoid valve,
following its replacement on February 14, 1989, was inadequate in
that it failed to demonstrate that the valve would perform as
designed.
The failure of valve 2-SI-618 to promptly close in a
response to a safety injection actuation signal is of concern
because a portion of a safety injection flow to the reactor
coolant system would have been diverted.
This is a severity Level IV Violation (Supplement I)against DN
50-336.
Reason For Violation
The reason for the violation was a combination of personnel
error, specifically, poor work practices, and inadequate retest
criteria.
Poor Work Practices:
On February 28, 1996, at 1505 hours0.0174 days <br />0.418 hours <br />0.00249 weeks <br />5.726525e-4 months <br />, with the plant in Mode 5 at
0% power, the Loop 1A Check Leakoff Drain Stop Valve, 2-SI-618,
failed its Operational Readiness Test per Surveillance Procedure
SP21136.
This valve is one of four Safety Injection System (SIS)
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air
operated
valves
(AOV)
that
receive
a
Safety
Injection
,
Actuation Signal (SIAS) to close in order to prevent the bypass
of safety injection flow to the Safety Injection Tank
(SIT)
recirculation header.
These AOVs have a controller / positioner
that modulates valve position and a solenoid operated valve that
is located in the air line between the controller / positioner and
the valve operator.
During normal operation, the solenoid valve
is energized in a position which allows the controller / positioner
to modulate control air to the AOV and thereby position the
,
valve.
When the SOV is deenergized (the accident condition), the
control air from the controller / positioner is shut off and the
AOV air pressure is vented which causes the AOV to fail closed
(the required accident condition).
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U. S. Nuclear Regulatory Commission
B15783/ Attachment 1/Page 2
The solenoid valve associated with 2-SI-618,
was replaced on
February 14,
1989 under work order M2-88-13141.
Because this
solenoid valve is Environmental Equipment Qualified (EEQ), it is
required to be vertically mounted so that the weight of the de-
energized core, acting through the valve lever and the lower disk
stem, will position the exhaust port on the solenoid valve to the
open position thereby venting the A0V and failing it to the
closed position.
Because a "close" 90 degree elbow was used to
connect the air tubing, it was necessary to remove the exhaust
valve disc guide cap on the solenoid during valve replacement.
When the exhaust valve disc guide cap is removed, the following
parts come out of the solenoid valve exhaust port: 1) the lower
spring, 2) the lower valve disk, and 3) the lower disk stem.
It
in postulated that the lower disk stem on 2-SI-618 was lost
during
the
solenoid replacement on February 14,
1989.
The
missing lower disk stem did not affect the operation of the upper
valve port, when the SOV was energized, remaining open to provide
a path for modulated air from the valve positioner to open and
close
the
2-SI-618
valve.
The
" fast vent" portion of
the
solenoid
operation
did
not
function
when
the
was
de-
energized.
The
additional work performed during the
replacement of
the
solenoid valve in 1989, was outside of the approved job scope.
Also,
supervision was not informed of the additional actions
necessary to replace the solenoid valve.
Inadequate Retest Requirements:
The
Inservice
Testing
Program
(IST),
required
by
Technical Specification 4.0.5,
contains testing requirements for " Fail Safe
Valves" per ASME Section XI, IWV-3415.
Per IWV-3415, testing is
performed every 3 months during cold shutdown. IWV-3415 states:
"When practical, valves with fail-safe actuators shall be tested
by observing the operation of the valves upon loss of actuator
power."
Prior to June 12, 1995, the fail-safe feature of valve
2-SI-618 was tested by disconnecting the air supply and verifying
that the valve went to its fail-safe position.
This testing met
all existing code requirements.
The " Integrated Test of Facility 1(2) Components", SP SP2613G(H),
verified that 2-SI-618, 2-SI-628, 2-SI-638, and 2-SI-648 closed
,
following a SIAS signal,
but the procedures did not require
'
timing
of
the
valve
closure.
Previous
testing
using
this
procedure indicated that 2-SI-618 did close at some time within a
50 second period.
(If the valve had not
closed within 50
seconds,
an annunciator on Main Control Board C01 would have
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actuated.
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U. S. Nuclear Regulatory Commission
B15783/ Attachment 1/Page 3
Corrective Steps That Have Been Taken and Results Achieved
Poor Work Practices
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The following corrective actions have been taken:
Corrective Action:
Prior to the discovery of the 2-SI-618 problem,
Station
-
Procedure WC-1, " Work Control Process", had been modified so
that pre-job briefings would take place in accordance with
the requirements of 29 CFR 1910.269(c), Subpart R.
The pre-
job briefings ensure that the workers understand the job
scope
prior
to
beginning
the
work
including
the
work
procedures involved.
In addition, step 1.7 of WC-1 states
the conditions under which performance of a Work Order is
required to be stopped.
This includes intent changes to the
job description or changes to the work boundary.
Results Achieved:
Changes to the Work Control Process, both procedural and
cultural, have resulted in improved job control conditions
over
that
which
existed
in
1989
when
the
initial
installation
problem
occurred.
Evidence
of
this
was
illustrated
during
the
March
1996
replacement
of
the
solenoid valve for 2-SI-618, after its failed Operational
Readiness Test.
The mechanic replacing the solenoid valve,
upon discovering that the air line elbow adapter interfered
with the lower disk guide cap on the valve,
immediately
stopped work and informed supervision.
This was the basis
for determining the original timeframe of the event and
cause of the missing lower disk stem.
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Inadequate Retest Requirements
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Corrective Action:
On June 12,
1995, prior to the discovery of the 2-SI-618
c
. problem, Surveillance Procedure SP 21136,
Rev.'
9,
" Safety
Injection And Containment Spray System Valve Operational
Readiness Test",
was changed to require
that,
based on
enginering
judgement,
power
must
be
removed
from
the
solenoid valves for 2-SI-618, 2-SI-628, 2 - S I - 6.' 9 , and 2-SI-
648 in order to adequately test the fail-closed aspects of
these valves.
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U. S. Nuclear Regulatory Commission
B15783/ Attachment 1/Page 4
Results Achieved:
On February 28,
1996,
when 2-SI-618 was undergoing
its
normally scheduled surveillance test,
per SP 21136,
the
valve
failed
to
close
rapidly when
the
fuses
for
the
associated solenoid were removed.
This is the event which
precipitated the repair activities for 2-SI-618.
The change
in
the
surveillance
procedure
would now
reveal
a
non-
conforming condition.
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Corrective Action:
In June of 1995, prior to the discovery of the 2-SI-618
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problem, Plant Incident Report 2-94-016 prompted a review of
all dual function AOVs.
A list was completed that indicated
that there are 94 air operated valves that receive safety
related
signals.
The
identified
valves
fell
into
two
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categories:
single-function
and
dual-function.
Single
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function valves (81) are those that operate the associated
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AOV by either energizing or de-energizing.
The associated
A0V does not have a modulation function.
Dual function
valves
(13)
are those for which the associated AOVs are
modulated in addition to receiving a safety actuation.
A
'
review of
the
Inservice Test Requirements
for
the dual
function valves completed on June
9,
1995, indicated that
the test requirements for 4 of the valves were not adequate.
These valves were 2-SI-618, 2-SI-628, 2-SI-638, and 2-SI-
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648.
The
procedure
governing
the
surveillance
testing
requirements, SP21136 for 2-SI-618, 2-SI-628, 2-SI-638, and
2-SI-648, was revised to require that power be removed from
the associated solenoids for testing.
On June 20, 1996, the
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original list of valves was verified to be complete.
It was
also verified that all 4 of the valves in question had
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passed the revised surveillance tests.
Results Achieved:
All 4 of the affected valves have satisfactorily passed the
new surveillance tests.
Corrective Steps That Will Be Taken To Avoid Further violations
Corrective Action:
Surveillance
procedures
SP2613G(H),
" Integrated
Test
of
Facility 1(2) Components, currently verify that 2-SI-618, 2-
SI-628,
2-SI-638,
and
2-SI-648
close
following
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U. S. Nuclear Regulatory Commission
B15783/ Attachment 1/Page 5
signal, but the procedures do not time the valve closure
times
to
verify
that
they
satisfy
the
requirements of
Technical
specification
Table
3.3.5,
" Engineered
Safety
Features
Response
Times".
To
correct
this
condition,
Surveillance Procedure SP 2604P, " Engineered' Safety Features
Equipment Response Time Testing", will be changed to require
verifying that 2-SI-618,
2-SI-628,
2-SI-638, and 2-SI-648
close to satisfy the Technical Specification Table
3.3.5
time requirements.
This is scheduled to be completed by
August 31, 1996.
Corrective Action:
An
appropriate
statement
prohibiting disassembly of
the
Solenoid Operated Valve (SOV) will be placed in the " Caution
Note" section of PMMS for the 94 safety related Air Operated
Valves -(AOV) .
This is scheduled to be completed by October
i
31, 1996.
Corrective Action:
A review of Post Maintenance Test problems has identified a
large number of items in this area.
A site wide effort is
in
progress
to
upgrade
the
Post
Maintenance
Testing
procedure,
CWPC
3.
This is scheduled to be completed by
December 31, 1996.
Date When Full Compliance Will Be Achieved
Full compliance with all retest requirements for the affected
valves
was
met
on March
3,
1996,
when
the
solenoid
valve
associated with 2-SI-618 was replaced and successfully tested
inaccordance with SP 21136, Rev. 9.
Requested Additional Information
The NRC Staff also requested NNECO to address (1) removing the
solenoid exhaust valve disk guide was outside the scope of-the
work
order
that
replaced
the
solenoid
and,
(2)
Routine
surveillance tests were inadequate
in that
they collectively
failed to verify the ability of valve 2-SI-618 to perform its
intended safety function.
These items are addressed in the preceding discussions concerning
corrective actions.