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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/96-04, 50-336/96-04 & 50-423/96-04
	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)
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October 8,1996

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Mr. Ted C. Feigenbaum

Executive Vice President - Nuclear

Northeast Nuclear Energy Company I

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:

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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,

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Original Signed Wy:

Jacque P. Durr, Chief

Reactor Projects Branch No. 6

Division of Reactor Projects l

Docket Nos. 50-245;50-336; 50-423

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cc w/ encl: ,

P. Richardson, Nuclear Unit 2 Director l

M. Brothers, Nuclear Unit 3 Director

L. Cuoco, Esquire l

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 "

PDR ADOCK 05000245

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Mr. Ted C. Feigenbaum 2

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 l

Distribution w/enci (VIA E-MAIL): I

J. Andersen, NRR

W. Dean, OEDO

P. McKee, NRR/PD l-4

V. Rooney, PM, NRR

D. Mcdonald, PM, NRR j

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

i OFFICE Rl/DRP 1 f) Rl/DRP _

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NAME RUrban l3

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JDurr M

DATE 08/1/96 JWl/gj96

OFFICIAL RECORD COPY

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P.O. Box 270

Hartford, cT 06141-0270

(203) 665 5000

July 17, 1996

Docket Nos. 50-336

B15783

Re: 10CFR2.201

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 i

reply to the NOV, on behalf of Millstone Unit No. 2, pursuant to l

the provisions of 10CFR2.201.

The following are NNECO's commitments made within this letter.

All other statements are for information only.

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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

Unit 2 - Violation

B15783-1 Surveillance Procedure SP 2604P, " Engineered Safety

Features Equipment Response Time Testing", will be

i changed to require verifying that 2-SI-610, 2-SI-628,

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2-SI-638, and 2-SI-648 close to satisfy the Technical l

Specification Table 3.3.5 time requirements. This is

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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

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related Air Operated Valves (AOV). This is scheduled i

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to be completed by October 31, 1996. 1

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B15783-3 A site wide ef fort is in progress to upgrade the Post

Maintenance Testing procedure guidelines provided in l

CWPC 3. This is scheduled to be completed by December l

31, 1996. '

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If you have any questions regarding information contained herein, 1

3 please contact Mr. M. D. Ehredt at (860) 440-2142.

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very truly yours

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NORTHEAST NUCLEAR ENERGY COMPANY

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FOR: T. C. Feigenbaum ;

, Executive Vice President and

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Chief Nuclear Officer i

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By: t x _,

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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

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Subscribed and sworn to before me

this /7d day of L/v , 1996

c 4/ n FLnJL

Date Commission Expires: /2/3g/97 i

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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

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Reply to a Notice of Violation l

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Inspection 50-336/96-04 I

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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) '

air operated valves (AOV) that receive a Safety Injection ,

Actuation Signal (SIAS) to close in order to prevent the bypass l

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

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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 SOV 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 '

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 i

The following corrective actions have been taken:

Corrective Action:

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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:

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On June 12, 1995, prior to the discovery of the 2-SI-618

. 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

l 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

l categories: single-function and dual-function. Single

l 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

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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.

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These valves were 2-SI-618, 2-SI-628, 2-SI-638, and 2-SI-

648. The procedure governing the surveillance testing

requirements, SP21136 for 2-SI-618, 2-SI-628, 2-SI-638, and

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2-SI-648, was revised to require that power be removed from

the associated solenoids for testing. On June 20, 1996, the

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 a SIAS

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U. S. Nuclear Regulatory Commission

B15783/ Attachment 1/Page 5

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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:

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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.

ML20128Q777

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