ML20210V363
| 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: |
| References | |
| 50-213-87-01, NUDOCS 8702190006 | |
| Download: ML20210V363 (7) | |
See also: IR 05000213/1987001
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-213/87-01
Docket No.
50-213
License No.
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
Inspectors: [.[
M
IMM
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S.K.ChaudfarY,LeadReactorEngineer
d(te
Approved by:
hm G.
2.l 6 l &7
,
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
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review and documentation of such changes, paragraph 3.
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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
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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3
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."
P
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
sufficient documentation for subsequent review and interpretation of
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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
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from the following areas:
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reactor protection
emergency core cooling
reactivity control
plant auxiliary, and
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
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test data showed as-found and as-left conditions, and
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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
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
Checkout of Assoc. Trips, Alarms and
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Controls
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SUR 5.2-14
Rev.
5
Reactor Containment Pressure Channel
08/29/85
Calibration
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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
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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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