ML20210V363

Insp Rept 50-213/87-01 on 870106-09.Violations Noted: Inadequate Procedural Control & Lack of Supervisory or Technical Review & Documentation of Change &/Or Substitution in Test Method

ML20210V363
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/06/1987
From:	Chaudhary S, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210V356	List: ML20210V351 ML20210V358 ML20210V363
References
50-213-87-01, NUDOCS 8702190006
Download: ML20210V363 (7)

See also: IR 05000213/1987001

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/87-01

Docket No. 50-213

License No. DPR-61

Licensee: Connecticut Yankee Atomic Power Company

P. O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck Plant

Inspection At: East Haddam, Connecticut

Inspection Conducted: January 6-9, 19_8_7

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Inspectors: [.[ M IMM

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S.K.ChaudfarY,LeadReactorEngineer

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Approved by: hm G.

J. R. Johnson,' Chief, Operational date

Programs Section, 08, DRS

Inspection Summary: Routine, unannounced inspection on January 6-9, 1987

(Inspection Report No. 50-213/87-01)

Areas Inspected: Surveillance and calibration program for installed plant

instrumentation covered by Technical Specifications.

Results: One violation was identified: inadequate procedural control over

change and/or substitution in test method, and lack of supervisory or technical

! review and documentation of such changes, paragraph 3.

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PDR ADOCK 05000213

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DETAILS

I.0 Persons Contacted

Connecticut Yankee Atomic Power Company

• D. B. Miller, Jr. , Station Superintendent

• B. R. Danielson, Instrumentation and Control Supervisor

• J. E. Beauchamp, QA/QC Supervisor

K. Baumgart, I&C Specialist

R. Kenefick, I&C Specialist

R. Curtis, I&C Specialist

In addition to the above, the inspector met and held discussions with

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other managers, engineers, planners, technicians, and control room

personnel during the course of this inspection.

U.S. Nuclear Regulatory Commission

• P. Swetland, SRI

S. Pindale, RI

2.0 Calibration Control Program for Plant Instrumentation

The inspector reviewed the licensee's program for calibration of installed

plant instrumentation to determine if the management control system

established was in conformance with license requirements, technical

specifications (TS), licensee commitments, and industry guides and

standards.

To determine the adequacy of the program, the inspector reviewed

procedures for their technical content and procedural controls for

establishing and tracking of calibration and test frequencies; creating

and maintaining adequate documentation for completed calibration and/or

tests; and resolution of non-conformances or any other problems identified

during tests. The inspector also held discussions with cognizant

personnel to assess their knowledge and the understanding of the program

requirements.

Based on the above review, discussions, and observations, the inspector

determined that:

The program is based on a computer system called " Preventive

Maintenance Management System (PMMS), which is a company wide program

implemented by the Northeast Utilities Corporate office.

The program is divided in two distinct categories; one covers plant

instrumentation covered by TS, and the other for the balance of

instrumentation.

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TS covered instrumentation are covered by procedures called

" Surveillance Procedures." The procedure designations are prefixed

with initial "SUR".

The balance of the instrumentation is covered by " Preventive

Maintenance Procedures" prefixed with initial "PMP".

The surveillance procedures, with few exceptions are implemented by

the plant instrumentation and control (I&C) department, and PMP

procedures, in majority, are implemented by the maintenance

department.

The inspector determined that the department planners issue a weekly

schedule of calibration and tests for the department personnel to

implement each week, and the results of the calibration and/or tests are

fed back into the computer for further tracking. Access to the data base

is restricted to the department planner and one senior technician to

prevent inadvertent or unauthorized manipulation. The data base display

is accessible to all plant personnel.

The program appeared to be adequate in providing controls in this area.

No violations or deviations were identified.

3.0 Test Witnessing by the Inspector

The inspector witnessed a calibration check of the Auxiliary Feedwater

System (AFW). This test was covered by procedure SUR 5.2-65, Rev. 9,"

Safety Grade Automatic Initiation of Auxiliary Feedwater Check."

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During the test set-up, the inspector noted that the test equipment

installed for the test did not have a calibrated resistor placed in series

with the test potentiometer (variable resistor).

In response to the inspector's question regarding this omission, the test

personnel indicated that, although the test procedure [SUR 5.2-65, Rev. 9,

paragraph 6.1.4] required a calibrated resistor, it had been the practice

for almost one year to omit the resistor because the milliampere (ma)

scale on the multimeter was being read directly for steam generator set

points which were specified in m.a. The inspector noted that the

procedural step detailing the calibrated resistor and checking set points

on the data sheet in paragraph 6.1.4 of the test procedure had been

checked-off and initia11ed by the technician; whereas, the resistor was in

fact not even available at the test location. The inspector informed the

test personnel that implementation of procedural steps was a requirement

of the quality assurance program. 10 CFR 50, Appendix B, Criterion V

requires that activities affecting quality be accomplished in accordance

with approved procedures, instructions and/or drawings. Not complying

with the requirements of a Plant Operations Review Committee (PORC)

approved procedure appeared to be violation of this requirement.

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The test personnel then brought a calibrated resistor and setup the

equipment as described in the test procedure and completed the test.

The inspector informed the plant management of this apparent procedural

violation by the I&C staff. The inspector then was referred to another

PORC approved administrative procedure ACP 1.2-6.4, Rev. 18, " Temporary

Procedure Change," which in paragraph 6.4.2.2 stated"... Temporary or

substitute instrumentation may be used in place of those specified..."

The inspector, questioned the licensee whether substitution of equipment

permitted by the administrative procedure allows the change of data

acquisition and resulting calculation, i.e., use of a milliamp display vs.

installing a calibrated resistor and reading a millivolt scale for

calculating milliamps.

The inspector also stated that the test documentation in question did not

reflect the change in the technique; therefore, signing-off the procedural

step (SUR 5.2-64; 6.1.4) without any remark or noted exception appeared to

be misleading. In addition, controls established by ACP 1.2-6.4. Rev.18

were not adequate to assure proper performance of the test, and review of

test data, in that technicians and management interpreted that the

procedure permitted technicians to change data acquisition techniques in

addition to equipment hardware without any supervisory or higher technical

review. The above examples of inadequate procedural control are a

violation of Criterion V of Appendix 8 to 10 CFR 50 (87-01-01).

The inspector noted that although the differences discussed above did not

affect results in this particular test, the major concern was inadequate

management control which could create a potential for affecting test

results in more complex test and surveillances. Test results may be

affected by methods of test and inappropriate documentation would hamper

any subsequent technical review of data for validity.

No other unacceptable items were identified.

4.0 Program Implementation Procedures and Documentation of Completed Tests

The inspector selected a sample of SUR and PMP procedures for detailed

review. Procedures selected were from I&C and maintenance departments for

surveillance / calibration and preventive maintenance.

The inspector reviewed procedures to determine if they were technically

adequate, clearly written, included acceptance criteria, and required

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sufficient documentation for subsequent review and interpretation of

list / calibration data. The inspector also examined the selected

procedures for evidence of management review and PORC approval, and their

availability to personnel in I&C department. Procedures selected were

i from the following areas:

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reactor protection

emergency core cooling

reactivity control

plant auxiliary, and

reactor coolant systems.

Based on the above review and discussions with cognizant personnel,

the inspector determined that procedures were:

reviewed and approved by management and PORC as appropriate

clearly written and contained adequate technical details and

instructions, and

contained adequate documentation requirements and acceptance

criteria.

The inspector selected a sample of completed test documentation to

determine the adequacy of test / calibration, clarity and legibility of

recorded data, approval of the procedure and review of test data, and if

the acceptance criteria had been met. The test documentation was for the

systems mentioned above. >

Except where noted above in paragraph 3, the inspector determined that:

test instruments used met the accuracy required by TS

correct conversion factors were used

instruments used were identified by unique numbers / names

proper controls were placed and fulfilled for removal of components

and systems from service and their return to service

! test data showed as-found and as-left conditions, and

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i test prerequisites were satisfied.

Documents reviewed are listed in paragraph 6.0 below. The inspector.had

no further question in this regard. No additional violations were

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identified.

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5.0 Licensee Actions on Previous Open Items

(Closed) Violation 86-19-01: This violation refers to lack of appropriate

review in upgrading spare parts to a category I level and failure to

initiate a supplemental automated work-order when the scope of the

original work-order was expanded. The inspector reviewed the licensees

response and the corrective actions implemented. The problem basically

was oversight by personnel. The inspector determined by discussions with

cognizant personnel that the importance of observing procedural

requirements had been re-emphasized the management and personnel had been

made aware of potential disciplinary action. This item is closed.

(Closed) Inspector Follow-up Item, 85-21-04: This item pertains to lack

of classification of replacement parts on Material Issue / Return List. The

licensee has expanded the scope of his training program to emphasize

procedural conformance and proper documentation. This item is closed.

(Closed) Violation 85-21-07: This item is related to misclassification

of a spare part on a Material Issue List. The corrective actions

implemented for the above item equally apply to this item. This item is

closed.

6.0' Documents Reviewed-Test / Calibration Procedures

SUR 5.2-2 Rev. 9 Pressurizer Level Channel Calibration 08/07/86

SUR 5.2-3 Rev. 11 Reactor Coolant Flow Trip Test 08/26/86

SUR 5.2-4 Rev. 12 Pressurizer Pressure Set Points 10/01/86

(6 Week Surveillance Test)

SUR 5.2-10 Rev. 5 Refueling Water Storage Tank Level 07/10/85

Test

SUR 5.2-11 Rev. 9 Steam Generator Steam Flow and Feed 07/06/86

Water Flow Channel Calibration and

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Checkout of Assoc. Trips, Alarms and

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SUR 5.2-14 Rev. 5 Reactor Containment Pressure Channel 08/29/85

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Calibration

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i SUR 5.2-15 Rev. 6 Reactor Coolant Temperature RTD Test 04/28/86

(Isothermal)

SUR 5.2-18 Rev. 4 Refueling Water Storage Tank Level 01/07/87

Calibration

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SUR 5.2-19 Rev. 9 Reactor Coolant Loop Valve Interlock 08/14/86

Test

SUR 5.2-33 Rev. 7 Reactor Protection Instrumentation 08/14/86

System Calibration

SUR 5.2-57 Rev. 3 Calibration of Auxiliary Feed Flow 03/28/86

Channels

SUR 5.2-68 Rev. 3 Refueling Water Storage Tank Level 04/15/86

Instrumentation Calibration

PMP 9.2-0 Rev. 3 Preventive Maintenance Program 11/21/85

PMP 9.2-30 Rev. 2 Calibration Procedure for Transmitter 12/17/85

Model 1080

PMP 9.2-69 Original Waste Decay Tank Inlet Header 12/20/85

Pressure Channel

PMP 9.2-70 Rev. 1 Waste Decay Tank Pressure 01/17/86

Channel Calibration

ACP 1.2-6.4 Rev. 18 Temporary Procedure Change 10/01/86

Plant Technical Specifications 7.0 Exit Interview ,

At the conclusion of this inspection, the inspector met with licensee

management (identified in paragraph 1.0 with an *) at which time the

inspector summarized the purpose, scope, and the findings of this

inspection.

At no time during this inspection did the inspector provide written

material to the licensee.

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