05000336/LER-1997-018-02, :on 970421,instrumentation Loop Components Did Not Meet Regulatory Guide 1.97 Category 1 Recommendations. Caused by Ineffective Implementation of Program Controls. Complete RG 1.97 Rev 2 Compliance Review

:on 970421,instrumentation Loop Components Did Not Meet Regulatory Guide 1.97 Category 1 Recommendations. Caused by Ineffective Implementation of Program Controls. Complete RG 1.97 Rev 2 Compliance Review

ML20141K267
Person / Time
Site:	Millstone
Issue date:	05/21/1997
From:	Joshi R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20141K255	List: 05000336/LER-1997-018, Forwards LER 97-018-00 Which Documents an Event That Occurred at Mnps,Unit 2 on 970421.Commitments Made within Ltr,Submitted 05000336/LER-1997-018-02, :on 970421,instrumentation Loop Components Did Not Meet Regulatory Guide 1.97 Category 1 Recommendations. Caused by Ineffective Implementation of Program Controls. Complete RG 1.97 Rev 2 Compliance Review
References
RTR-REGGD-01.097, RTR-REGGD-1.097 LER-97-018-02, LER-97-18-2, NUDOCS 9705280415
Download: ML20141K267 (3)

LER-1997-018, on 970421,instrumentation Loop Components Did Not Meet Regulatory Guide 1.97 Category 1 Recommendations. Caused by Ineffective Implementation of Program Controls. Complete RG 1.97 Rev 2 Compliance Review

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition
3361997018R02 - NRC Website

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Millstone Nuclear Power Station Unit 2 05000336 1OF3 l

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Instrumentationloop Components Do Not Meet Regulatory Guide 1.97 C' tegory 1 Recommendations a

i EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FACILITIES INVOLVED (8)

SE AL RE N

MONTH DAY YEAR YEAR MONTH DAY YEAR NU R

04 21 97 97

-- 018 00 05 21 97 oPERATINo THis REPORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 10 CFR S: (Check one or more) (11)

MODE (9)

N 20.2201(b) 20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i)

X 50.73(a)(2)(ii) 50.73(a)(2)(x) j LEVEL (10) 000 20.2203(a)(2stil 20.2203(a)(3)(n) 50.73(a)(2)(iii) 73.71 20.2203(aH2)(ii) 20.2203(a)(4)

So.73(a)(2)(iv) oTHER 20.2203(a)(2)(iii)

So.36(c)(1) 50.73(aH2)(v)

Specify in Abstract below l

20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER ilnclude Area Code)

R. G. Joshi, MP2 Nuclear Licensing (860)440-2080 COMPLETE ONE LINE FoR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) 1

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CAUSE

SYSTEM COMPONENT MANUFACTURER

CAUSE

SYSTEM COMPONENT MANUFACTURER PR PRDS

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l SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR I

YES SUBMISSloN X No DATE (16) l (if yes, complete EXPECTED Submission DATE).

ABSTRACT (Limit to 1400 spaces,i.e., approximately 15 single spacedtypewrittenlines) (16) l On November 6,1996, while performing a review of the plant compliance with the recommendations of Regulatory Guide (RG) 1.97, Rev. 2, it was discovered that discrepancies existed between current plant commitments and the i

actual installation for certain Type A, Type B, and Type D instrumentation. These instruments, although reported to

. the NRC as Category 1, do not meet the Category 1 requirements. Northeast Nuclear Energy Company had stated that these instruments were in compliance with RG 1.97, Rev. 2 recommendations. This condition was first identified on November 6,1996, the evaluation to determine the details and extent of the condition was completed on Aoril 21, j

1997, and a prompt report of the condition was made on that date At the time of discovery the plant was defueled.

l The cause of this condition is the ineffective implementation of program controls used to comply with RG 1.97.

l The following actions will be taken to correct this condition: Complete the RG 1.97 Rev. 2 compliance review including NNECO committnents and resubmit the results to the NRC before entering MODE 4 from the current outage.

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NRC Ft')RM 366A U.s. NUCLEAR REGULATORY CoMM!ssioM I

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LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISloN YEAR NUMBER NUMBER 2OF3 Millstone Nuclear Power Station Unit 2 05000336 97

- 018 -

00 TEXT tif more space is reqwred. use additionalcopses of NRC Form 366A) (17) 1.

Description of Event

l On November 6,1996, while performing a review of the unit's compliance with the recommendations of Regulatory l

Guida (RG) 1.97, Rev. 2, it was discovered that discrepancies existed between current unit commitments end the actualinstallation for certain Type A. Type B, and Type D instrumentation. These instruments are used in the following systems: High Pressure Safety injection (B0], Flux Monitoring (IG), Containment Monitoring (IK], Steam

. Generator Level Control (JB], Reactor Protection (JC], and Condensate Storage & Transfer (KA). Although j

reported to the NRC as Category 1, these instruments do not meet the requirements for Category 1(Cat 1) instruments. Northeast Nuclear Energy Company (NNECO) had stated that these instruments were in compliance with RG 1.97, Rev. 2, recommendations. This condition was first discovered on November 6,1996.

The evaluation to determine the details and extent of the condition was completed on April 21,1997, and a prompt report of the condition was made on April 21,1997 at 15:51 hours in accordance with 10 CFR 50.72 (b)(2)(iii). At the time of discovery the unit was defueled.

Subsequent review determined that a more applicable reporting rule is 10 CFR 50.73(a)(2)(ii)(B), a condition that l

is outside the design basis of the plant.

II.

Cause of Event

l l

- The cause of this condition is the ineffective implementation of program controls used to comply with RG 1.97.

Ill. Analysis of Event The original plant design basis considered the control room panelindicators as non-safety related. As a result, these QA listed instruments were not identified as failing to meet the Cat i recommendations of RG 1.97, and no design changes were initiated to make the instruments ccnform with the recommendations.

On June 15,1987 and March 2,1992, NNECO submitted a RG 1.97, Rev. 2 compliance matrix for Millstone Unit No. 2 to the NRC. On January 30,1995 the NRC issued a Notice of Violation (NOV) which identified errors in the information provided in the compliance matrix. In response to the NOV, NNECO committed to perform a review of the plant design basis and actual installation, including compliance with the recommendations of RG 1.97, Rev. 2.

During the review, it was discovered that instruments which were previously listed as QA had been downgraded to i

non-QA during several material, equipment, and parts list evaluations. The instruments were downgraded l

because some do not meet separation criteria, and others were not electrically isolated from non-QA portions of l

the instrument loop. The indicators are installed in the control room, a mild environment, and do not have Environmental Qualification requirements. The indicators, although listed as non-OA, were purchased as nuclear qualified indicators. The indicators are isolated from reactor trip and safeguard actuation functions, so that any failure of the indicator loop would not prevent any safety system from performing its safety function. Based on the redundancy of the instruments involved, other indicators could provide the operator with the information needed in the event of a failure of an indicator or its instrument loop. However these instruments do not meet the Category 1 requirements.

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/, HRC PoRM 366A U.s. NUCLEAR REGULATORY COMMISSloN LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL Revision YEAR NUMBER NUMBER 3OF3 Millstone Nuclear Power Station Unit 2 05000336 97

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00 l

TEXT (If more space is requwed. use additionalcopies of NRC Form 366A) (11)

. Type A instruments are instruments which provide primary information needed for the operator to perform manually controlled actions, for which no automatic control is provided, that are required for safety systems to accomplish their safety function for design basis accident events. The following are the Type A Instruments which lack qualification and the associated operator actions for accident mitigation:

i TYPE A INSTRUMENTS INSTRUMENTATION

OPERATOR ACTIONS

Pressurizer pressure Tripping Reactor Coolant Pumps (RCP) on low pressure Steam Generator (SG)

SG isolation on excess steam demand Pressure l

SG Level Verification of SG level for heat removal - Critical Safety Function (CSF) l Reactor Water Storage Switch valves SI-659 & SI-660 to Operate (SI Min-flow isolation)

Tank (RWST) Level j

Hot Leg & Cold Leg SG isolation on excess steam demand Temperatures Cooldown rate monitoring i

l Considering the above information this condition is of low safety significance.

l

IV. Corrective Action

Complete the RG 1.97 Rev. 2 compliance review including NNECO commitments and resubmit the results to the NRC before entering MODE 4 from the current outage.

V.

Additional Information

Similar Events 1

l LER 96-019.

Certain solenoid operated valve electncal connections in the containment do not meet environmental qualification requirements The original assumption was that the valves were j

required to operate for containment isolation only. Subsequent review found the valves must be 1

reopened post accident, and were not qualified for this function Energy Industry Identification System (Ells) codes are identified in the text as [XX).

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