ML20155H651

Insp Rept 50-423/88-15 on 880816-0926.No Violations Noted. Major Areas Inspected:Plant Operations,Previous Insp Findings,Allegation on Storage of QA Resin & Emergency Diesel Generator a Output Breaker Trip While Loading

ML20155H651
Person / Time
Site:	Millstone
Issue date:	10/12/1988
From:	Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155H653	List: IR 05000423/1988015 ML20155H651
References
50-423-88-15, NUDOCS 8810210576
Download: ML20155H651 (12)

See also: IR 05000423/1988015

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U.S. NUCLEAR REGULATORY COMMISSION

RFGION I

Report No. 50-423/88-15

Docket No. 50-423

License No. NPF-49

Licensee: Northeast Nuclear Energy Company

).0. Box 270

Hartford, CT 06101-0270

Facility Name: Millstone Nuclear Power Station, Unit 3

Inspection At: Waterford, ConnecticM

Inspection Conducted: August 16 - September 26, 1988

Reporting Inspector G. S. Barber, Resident Inspector

Inspectors: W. J. Raymond, Senior Resident Inspector

G. S. Barber, Resident Inspector

Approved by: b O. M ,)w /s /n/oS

G . McCabe, Chief, Reactor Projects Section 18 Date

Inspection Summary: Inspection on 8/16/88 - 9/26/88

Areas Inspected: Routine onsite inspection of Plant Operations, previous inspection

findings, an aR egation on storage of QA resin, "A" Emergency Diesel Generator

Output Breaker Trip While Loading, sticking "B" Main Feedwater Regulating Valve,

Licensee Event Reports, naintenance, surveillance, and committee activities.

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Results: No unsafe plant conditions were identified. Two violations (NC4 88-02-01

and ifC4 88-05-01) cited in previous reports were closed. An alleger described the

storage of resin in the condensate polishing facility as unsatisfactory. This

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allegation was unsubstantiated. However, shelf life and in-transit controls are 1

an unresolved item (UNR 88-15-01).

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8810210576 881012

PDR ADOCK 05000423

O PDC

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TABLE OF CONTENT

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1.0 Persons Contacted.................................................... I

2.0 Summa ry o f Fa c i l i ty Ac t i v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

3.0 Previous Inspection Findings......................................... 1

3.1 (Closed) NC4 88-02-01: One of Two Required Charging Pump was

Inoperable During Entry into Mode 3........................... 1

3.2 (Closed) NC4 88-05-01: AFV Suction Valve Impropsrly Locked...... 2

4.0 Plant Operational Status Reviews (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

5.0 Allegation Follow-up - Storage of QA Resin (RI-A-88-0087) (92701).... 3

6.0 "A" Emergency Diesel Generator Output Breaker Trip While Loading

(71707) (62703).................................................... 5

7.0 Sticking B Main Feedwater Regulating Valve (71707). . . . . . . . . . . . . . . . . . . 6

8.0 Licensee Event Reports (90712)....................................... 8

9.0 Maintenance (62703).................................................. 9

10.0 Surveillance (61726)................................................. 9

11.0 Committee Activities (40700)......................................... 9

12.0 Hanagement Meetings (30703).......................................... 10

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i 1.0 Persons Contacted

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l Inspection findings wcre discussed perioritcally with the supervisory and man-

agement personnel identified below, f

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S. Scace, Station Superintendent i

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C. Clement, Unit Superintendent, Unit 3  !

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M. Gentry. Operations Supervisor  ;

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R. Rothgeb, Maintenance Supervisor ,

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K. Burton, Staff Assistant to Unit Superintendent  ;

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J. Harris, Engineering Supervisor .

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D. McDaniel, Reactor Engineer  !

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R. Satchatello, Health Physics Supervisor

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M. Pearson, Operations Assistant I

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R. Griswold, Stores Supervisor l

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R. Asafaylo, /uality Services Supervisor j

2.0 Summary of Facility Activities

l The plant operated at full power throughout the inspection period except for ,

l minor power reductions for surveillance testing. [

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3.0 Previous Inspection Findings i

3.1 (Closed) NCR4 88-02-01: One of Two Required Charging Pumps was Inoperable f

During Entry into Mode 3 l

The licensee discovered at 8:20 a.m., January 30, 1988, while in Mode

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3, that only one of two required charging pumps was operable. The "A"  !

charging pump was declared inoperable when cooling water inlet and valves i

l for its lubricating oil heat exchanger were found closed. Technical  ;

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Specification (TS) 3.5.2 requires that two independent charging pumps  !

be operable in Mode 3 and TS 3.0.4 requires that all applicable Limiting i

Conditions for Operation (LCO) be met without reliance on action state-

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ments prior to increasing Modes. Since Mode 3 was entered at 5

42 p.m.,  ;

January 29, this was a violation.

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The licensee attributed the root cause of the violation to procedure in-

adequacy since procedures did not require a *.est run of the charging pump  :

prior to entry into Mode 3. The inspector concurred that procedure '

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changes and other corrective action should prevent recurrenct of this <

l violation. However, the licensee's root cause determination indicated )

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procedure inadequacy as the sole problem. Along with the procedures,

) operators share the responsibility of ensuring that necessary support

j equipment / valve lineups are available to ensure successful pump starts.

OP-3260, Conduct of Operatior.s. states this requirement. The need for

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operator attentiveness during such evolutions was communicated to licen-

see management. The licensee reemphasized to operators the need to en- l

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sure lineups and support systems are available and adequate for the }

evolution in progress.  ;

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The licensee has completed a procedure change to OP3201, Plant Heatup, r

to require a test run of the charging pumps prior to exceeding 350 de- t

grees F. OP3304, Charging and Letdown, was changed to danger tag any. i

charging pump not aligned for service. These procedure changes should l

! preclude further starts without the requisite support system. This item ,

is c'osed.  :

3.2 (Closed) NC4 88-05-01: AFV Suction Valve Improperly Locked

During routine inspection in the Engineered Safety Features (ESF) Butid-

ing at 3:30 p.m., March 4, the inspector found the demineralized water

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storage tank (DWST) Suction Valve for the "A" Motor-Driven Auxiliary i

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Feedwater Pump (MDAFW) (3FWA-V2) optn as required, but not properly

i locked. The lock had been closed on one link at one end of the chain L

, but not at the other end. The chain could be pulled free of the hand- '

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i wheel and the valve could be operated. This violated the administrative l

1 controls for locked valves.  ;

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The inspector reported the improper locking to the Shif t Supervisor (SS),

who dispatched a Senior Control Operator (SCO) on relief shift to the i

1 ESF building. The SCO properly secured the lock and accompanied the  !

inspector during walkdown of other accessible locked major flowpath l

valves for the AFV and Safety Injection (SI) systems. No other inade- '

quacies were identified. The inspector questioned whether there might  !

. be other valves without their locks properly attached. The licensee  :

agreed to check all locked valves outside of containment.

The licensee completed checking all locked valves on safety systems out-

side of containment. In addition to checking the valves themselves, the

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licensee compared valve position on controlled drawings to those speci-

j fied in the valve lineup. Locked valve lineup checks were performed on .

the following systems. '

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MB Auxiliary Feedwater. ,

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MB High Pressure Safety Injection, t

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MB Recirculation Spray System. i

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MB Quench Spray System.  :

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MB Residual Heat Removal. I

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MB Charging Pump Conling. l

-- MB Boric Acid, i

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MB Diesel Fuel Oil and Lube 011. I

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MB Service Water.  !

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During review of completed PIR 51-88, which documented the completed

locked valve checks, the inspector noted errors in the date recorded for '

the diesel fuel and lube oil valve lineups (listed as 2/5/88). The lic-

ensee contacted the cperator and verified he had recorded the wrong date.

The dates were corrected. In addition to the locked valve lineup checks

performed, the licensee reminded all operators to ensure that locks are

properly secured through their respective valve handwheels. The inspec-

tor routinely checks this item on plant tours and has identified no fur-

ther inadequacies. This item is closed.

4.0 Plant Operational Status Reviews (71707)

The inspector reviewed plant operations from the control room and reviewed

i the operational status of plant safety systems to verify safe operation of

the plant in accordance with the requirements of the Technical Specifications -

and plant operating procedures. Actions taken to meet Technical Specification

requirements when equipment was inoperable were reviewed to verify the limit-

ing conditions for operations were met. Plant logs and control room indica-

tors were reviewed to identify changes in plant operational status since the

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last review and to verify that changes in the status of plant equipment was

properly communicated in the logs and recorcs. Control room instruments were

observed for correlation between channels, proper functioning, and conformance

with Technical Specifications. Alarm conditions in effect were reviewed with

control room operators to verify proper response to off-normal conditions and

to verify operators were knowledgeable of plant status. Operators were found

to be cognizant of control room indications and plant status. Control room

manning and shift staffing were reviewed and compared to Technical Specifica-  :

tion requirements. No inadequacies were identified.

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59 a legation Follow-up - Storage of QA Resin (92701)

An ancsymous letter received at the NRC Resident Office on September 7, 1988 i

stated t, st QA Category 1 resin was improperly stored at the condensate

polishing facility (CPF) and should be in a "Level 1" storage area. The in-

! spector discussed resin procurement with stores and QC personnel, reviewed

administrative requirements for procurement, receipt, and storage as specified

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in licensee procedures ACP-QA-4.028 and 4.04 and ANSI Standard N45.2.2-1972

(as committed to in Appendix 0 of the Northeast Utilities Quality Assurance

i Program Topical Report). Inspector review determined that the CPF was a pro-

per storage area for resin. The basis for this determination and other in- i

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spector findings are summarized below. '

Inspector tours on September 7 determined that about 600 barrels (141.5 cu.

ft. each) were stored on two floors of the CPF. The resins were marked with j

NU QC Acceptance Tags which provided the following identifying information:

Klenzoid ion exchange anion and cation resin procured under Purchase Order l

(PO) 911632 as QA "Category 1" material for use in undensate, radwaste and i

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cleanup process systems; the resins were receipt inspected on site in the

April - May 1988 period per material receipt inspection report (MRIR) 287-289;

and a Class "C" storage level was assigned.

The CPF houses polishing systems for MP-2 and MP-3, functions as a warehouse

and provides office space for Nuclear Records, Unit 2 I&C and the calibration

laboratory. The CPF and other warehouse facilities onsite and at Great Neck

Road (an offsite Northeast Utilities warehouse location) meet the requirements

for a Level B storage area. The CPF is an enclosed, clean and dry structure

with provisions for temperature control to maintain ambient temperature well

within the 40 to 140 degree F range required for a Level B area. Based on

discussions with station chemistry personnel, the appropriate temperature

storage range for resins is about 40 to 120 degrees F, to guard against

freezing or excessive heat which could affect the physical integrity of the

beads. The inspector concluded that the CPF is a proper storage area for

Category 1 resins. The concern that GA category 1 resin was improperly stored

was not subst 1tiated. The discrepancies discussed below were identified

during inspector follow-up of the allegation.

5.1 Improper PO Specifications

Purchase Order No. 911632 dated 1/12/88 (repeat requisition) stipulates

that the resins be handled, shipped and stored per MSI N45.2.2 Level

D controls, which is improper since this would allow outdoor storege and

not provide adequate protection from the environment or temperature con-

trol. This matter was discussed with stores personnel who stated actions

would be taken to correct the purchase specification.

The QC inspector who performed the receipt inspection for the shipment

assigned a Level C storage area (even though no Level C storage facili-

ties' exist onsite) since Level D was specified in the PO and storage

under conditions at or better than the specification is acceptable per

the standards. Level C was also specified to allow for outdoor trans-

port of the resins from the Great Neck F.oad facility. The NRC inspector

stated that Level C storage would not be acceptable for resins during

cold winter months if stored outside while in transit. The licensee

acknowledged the inspector's comments,

5.2 Shelf Life Controls

ACP 4.06B, Degradable Material Control Program, specifies on page 7 of

Figure 7.1 that resins are degradable materials that require the appli-

cation of shelf life controls. The inspector noted that shelf life con-

trols were not applied to resins procured under PO 911632, in that no

shelf life specifications were included in the procuring documents, and

no tagging per ACP 4.068 was provided upon receipt of the materials.

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Review of this finding with stores personnel indicated that the shelf j

life control program, initiated in mid-1987, should have been applied i

to the February 88 purchase order. Failure to do so indicated that re- i

view failed to apply the required controls when the PO was processed, l

and at receipt inspection when the materials were received on site. l

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Inspector interviews with procurement personnel and the QC inspector i

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responsible for the receipt inspections found that they were familiar ,

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with the shelf life program, but that the requirements were not applied

) in this case due to an oversight. A contributing factor to the oversight  !

i was the receipt of the resina at the point of storage (CPF or Great Neck I

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facility) instead of at the normal off load area in the main warehouse. ,

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This matter was discussed wfth stores personnel who stated the vendor  !

l would be contacted to obtain a cure date for the resin and that the ma-

terials would be tagged to apply shelf life controls. The inspector  !

j noted that resin shelf life is typically two years or longer under proper  :

i storage conditions.

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The inspector concluded that a programmatic concern may exist but is not ,

shown by a sample of one purchase order. Inspector concerns were discussed

i with stores supervisory personnel and the Quality Services Supervisor. The  ;

licensee acknowledged the inspector's concerns and stated that consideration l

, would be given to an audit of the degradable materials program. This item i

! is unresolved pending determination of the shelf life of the resin in question,

j completion of other licensee actions (including in-transit controls), and

j further NKC review of the shelf life control program (UNR 88-15-01). l

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l 6.0 "A" Emergency Diesel Generator Output Breaker Trip While Loadinq  !

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Gn September 6, at 6:23 a.m., the "A" Emergency Diesel Generator (EDG) output l

breaker trippe' during an attempt to load the engine. The "A" EDG was in-  !

l Itially paralleled to the system at 6:12 a.m. The operator attempted to in- '

crease load in a controlled manner, but had trouble adjusting to the large j

swings in load that occurred each time the speed / load switch was operated.  !

Within approximately 1 minute from the time the output breaker was closed,  ;

and subsequent to adjusting the speed / load changer to compensate for a sudden  ;

large power increase, the output breaker tripped and the engine shut down on j

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Unit / Parallel Relay (UpR) de-energized while the EDG was operated in i

, parallel with site power.

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Malfunction of the electrical governor, including the motor-operated l'

) potentiometer (MOP) that determines the electric governor load / speed

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A mechanical or electrical disruption in an external component that pro-

vides an input to the mechanical or electrical governor.

The licensee identified the UPR relay and its associated circuit as the most

, likely cause. Changing load significantly with minor atLjustments to the MOP

was symptomatic of the "Unit mode of speed / load control while in parallel

with the site electrical system (grid). The control switch was confirmed to +

be in "Parallel" and an ele:trical check of the UPR circuit was performed.

No circuit malfunction was discovered. The "A" EDG was then started and

paralleled to the site electrical system. Governor response to the load / speed I

changer was satisf actory. The EDG was operated at full load in accordance

with the surveillance procedure without any indication of governor control

problems. At 11:48 a.m., on September 6, the "A" EDG was returned to an

operable status.

Further investigation was conducted. A review was made of all maintenance  !

performed on "A" EOG during the month prior to its failure (August 1988).

Operators, mechanics, and electricians associated with either the failure or c

maintenance performed prior to the failure were interviewed by the licensee.

Also, a manufacturer's representative from Colt Industries was consulted. ,

No definitive cause was identified. A second test run of "A" EDG was per-

formed on September 7 with the Governor responding correctly to all load / speed  ;

j change demands.

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Based on the investigation to date, the licensee concluded that the most

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likely cause was intermittent sticking contacts or relays associated with the

UPR circuit. Other malfunctions would have been expected to cause permanent

railures. An air bubble in the mechanical governor oil system could cause

an intermittent problem, but the licensee concluded this was unlikely since .

it has been at least nine months since the governor oil has been changed (the L

most likely time that air bubbles would form). The fact that the governor

i responded in the correct direction (increase in load for an increase in signal e

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i and vice-versa), albeit too rapidly to prevent a reverse power trip, was fur- l

ther indication the UPR circuit was at fault. Subsequent starts will be i

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videotaped to attempt to determine the cause of any unusual power swings.

, The inspector had no further questions at this time. ,

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7.0 Sticking "B" Main Feedwater Regulating Valve

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The licensee placed the "B" main feedwater regulating valve (FRV) (3FWS*FCV520, j

COPES-VULCAN Model 12" 900LB) in Manual on August 17 to mitigate a sticking

problem. The "B" main feed water regulating bypass valve (BV) was placed in

automatic to compensate for Steam Generator (SG) level oscillation of +/- 2's

over the past month.

1 The "B" FRV was first discovered stuck (on August 8) about 0.5 inches below

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its 100*. power position during stroking of the "B" bypass valve. Since the

"B" FRV was not responding smoothly to the demand signal, the bypass valve

I was being stroked open in manual to exercise the "B" FRV in automatic. Over

j a fif teen minute period the bypass valve was moved froia C's to 100*; open. As

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the bypass valve was being opened, the "B" FRV demand signal went from about

80% open to 20% open (with a normally functioning valve, the demand signal

would have been expected to decrease from 80% to about 70%) and the valve stem

moved in the closed direction about 0.5". Steam generator level increased >

slightly during testing but remained under control. After the "B" bypass was

fully open, the operator started to manually close it. The "B" FRV did not

move and SG water level started to decrease forcing the operator to restore

level. When the demand signal reached 80% open the "B" FRV became "unstuck" i

and jerked open. The operator manually shut the bypass valve and stabilized

"B" SG 1evel before returning the "B" FRV to automatic. The "B" FRV has

live-load packing and inspection of the "B" FRV stem showed a worn area that

will require replacement during the next plant shutdown. The "B" FRV remained

in automatic and the licensee has decided that the "B" bypass valve will no

longer be stroked for preventive maintenance.

The licensee contacted the Westinghouse Site Services Manager (WSSM) to dis-

cuss the ramifications of continued operation. The WSSM proposed that the

licensee implement one of two options. The first was to place the "B" bypass l

valve in automatic and shut the "C" FRV in manual to the point where the by- l

pass valve is 60-70% open and controlling in automatic. This option equired i

the gain setting for the nuclear instrumentation (NI) feed forward signal to

be set to zero. The bypass valve could cope with a 5 to 10% power t'ansient ,

without operator action. Larger power transients would require operator ac-  ;

tion to prevent a plant trip. The second option required adjusting the "B" i

FRV Moore booster relay to make it more responsive to the control signal from

the positioner. This adjustment is made by using an internal bypass valve.

If the air signal from the positioner can bypass the booster relay's diaphra u

without building up a differential pressure, the booster will never actuate.

For small signals the air will bypass around the booster and for larger sig-

nals the booster will function to pass a large volume of air. By screwing

the needle bypass adjustment screw in 1/9 of a turn (CW) the bypass flow path

will become slightly more restricted and the booster relay will actuate on '

a smaller input signal.

The booster relay will not give a higher final pressure, but will insure the i

final demand pressure is reached quicker, i.e. it is a volume booster, not l

a pressure booster. If the "B" FRV is sticking, this added volume may assist l

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it in more rapidly un-sticking. This option was less desirable because of  !

its effect on SG level. l

The licensee implemented optien one on August 17 by placing the "B" FRV in

manual and the "B" bypass valve in automatic. The inspector reviewed the lic-

ensee's implementation of option one under bypass / jumper No. 388-58. The

inspector noted that the bypass / jumper removed the NI feed forward signal to

the "B" bypass valve (3FWS*LV560). This jumper also requires the resetting '

the NI gain to 4.8% valve lift per % power prior to low power operation. The

bypass jumper signal also documented the resolution of the following: 1) NI l

signal isolation such that gain adjustments will not affect the Solid State I

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Protection System (SSPS); 2) the ability to isolate feedwater on a feedwater

isolatf or. (FWI) signal; 3) operator awareness of B bypass valve control limita-

tions as listed by the WSSM.

The licensee satisfactorily addresud the concerns as follows: 1) the reset-

ting of the gain will not affect the SSPS because this control circuitry is

isolated from the protection circuitry; 2) FWI will be provided by automatic

closure of the feedwater containment isolation valve (3FWS*CTV418) and by main

feedwater pump trip independent of either "B" bypass or "B" FRV closure;

3) Operators have been briefed on the need to take action on a large power

transient and will attempt to control SG level in the normal band. The in-

spector had no further questions in this area. '

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8.0 Licensee Event ReNrts (90712)

Licensee Event Reports (LERs) submitted during the report period vere reviewed

to assess LER accuracy, the adequac/ of corrective actions, compliance with

10 CFR 50.73 reporting requirements and to determine if there were gcneric

implications or if further information was required. Selected corrective

actions were reviewed for implementation and thoroughness. The LERs review 9d

were:

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LER_88-19-00 Unexpected Control Building Isolation Due to Personnel

Error

At 12:15 a.m. on June 11, a component in the "A" Train control building

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ventilation !niet radiation monitor failed. As part of the restoration,

the radiation monitor setpoints were entered at the control room console.

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While reading the setpoints from a table, a control room operator inad-

vertently read the high radiation rate trip setroint value from an ad-

jacent line in the table and entered it as the Radiation Engineering

Conversion Factor (RECF). Entry of the incorrect RECF caused the indi-

cated radiation level to exceed the alarm setpoint, initiating the CBI. i

Control building ventilation was immediatelv placed in filtered recircu-

lation and the correct RECF was installed. The licensee verified inlet

radiation was at normal background levels using the "B" Train radiation

monitor and all monitor setpoints were checked. To prevent recurrence,

the licensee will momentarily disable and restore Engineered Safety

Features while radiation monitor setpoints are entered. Engineered

Safety Features will be verified re-enabled following setpoint entry.

The inspactor had no further questions on this LER. '

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LER 88-20-00, Improper Bypass Breaker Surveillance Oue to Administrative

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E~rror (NV4 88-15-01)

At 10:00 a.m. on July 18, the licensee identified that the reactor trip

bypass breaker Technical Specification (TS) surveillance test frequency

was inadequate. On May 14, the "A" train bypass breaker was placed in

service without verification of shunt trip operability within the pre-

ceding 31 days as required by Plant Technical Specifications. No imme*

j diate actions were required of plant operators since redundant equipment

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in the opposite train provided plant protection. The cause of the event l

was inadequate administrative review of the trip actuating device opera-

tional test frequency portion of Plant Technical Specifications. The

Preventive Maintenance Surveillance schedule for reactor trip bypass

breaker local manual shunt trip operability has been updated to reflect

the proper frequency.

This licensee-identified item was evaluated as being of low safety sig-

nificance, aporopriately reported and corrected, and not a result of

inadequate corrective action on a prior violation. Therefore, no Notice ,

! of Violation was issued. t

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9.0 Maintenance (62703)

The inspector observed and reviewed selected portions of preventive and cor- .

rectiva maintenance to verify compliance with regulations, use of administra-  !

tive and maintenance procedures, compliance with codes and standards, proper i

QA/QC involvement, use of bypass , jumpers and safety tags, personnel protection,

and equipment alignment and rete:,t. The following activity was included: [

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Repair of Flux Map System, on 9/22/88  !

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Repair of the A Emergency OG, on 9/6/88.

No inadequacies were identified.

10.0 Surveillance (61726) f

The inspector cbserved portions of surveillance tests to assess performance

in accordance with approved procedures and Limiting Conditions of Operation,  !

removal and restoration of equipment, and deficiency review and resolution. l

The following test was reviewed:  !

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Flux May, dated 9/22/88

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No inadequacies were noted.

11.0 C_ommittee Activities t

The inspector reviewed the minutes for Plant Operations Review Committee  ;

(PORC) meetings 3-87-205 dated 12/14/87, 3-88-46 dated 2/11/88, 3-88-99 dated  !

5/10/88, 3-88-103 dated 5/19/88, 3-88-104 dated 5/23/88 and 3-88-109 dated )

6/2/88. The inspector noted from the written records that committee admini-

strative requirements were met for the meetings and that the committees dis- l

charged their functions in accordance with r.tgulatory requirements. No in-

adequacies were identified.

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10

12.0 Management Meetings

Periodic meetings were held with station management to discuss inspection

findings during the inspection period. A summary of findings was also dis-

cussed at the conclusic, of the inspection. No proprietary information was

covered within the scope of the inspection. No written material was given

to the licensee during the inspection period.

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