ML20073C334: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
Line 1: Line 1:
{{Adams
#REDIRECT [[A09163, Submits Results of Review of Allegations R1-90-A-0180 & RI-90-A-0202 Re Inoperability of wide-range Instruments & Annual Preventive Maint on Various Limitorque Operators]]
| number = ML20073C334
| issue date = 12/21/1990
| title = Submits Results of Review of Allegations R1-90-A-0180 & RI-90-A-0202 Re Inoperability of wide-range Instruments & Annual Preventive Maint on Various Limitorque Operators
| author name = Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Wenzinger E
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| docket = 05000336
| license number =
| contact person =
| document report number = A09163, A9163, NUDOCS 9104250185
| package number = ML20073C307
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 7
}}
 
=Text=
{{#Wiki_filter:-
On-ep        4 s.,c. , ,,,,, . ,,,,,,. ,,,,,,, La menrmaast uriLmus                                                    o ,,, ,, o ..                .
TT                  :::::'=                                                        El55;o~a=== a/4 a<LE:EEEiiif=
December 21, 1990 Docket No. 50-336 A09163 Hr. E. C. Venzinger, Chief Projects Branch No. 4 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
 
==Dear Hr. Venzinger:==
 
Millstone Huelear Power Station, Unit No. 2 RI-90-A-0180 and__RI 90-A-0202 Ve have completed our rev'ev of an allegation concerning                              activities As requested        at in your Millstone Unit 2 (RI-90-A-0180 and RI-90-A-0202).our response does not contain any transmitta) letter dated November 26, 1990,                                          The material personal privacy, proprietary, or safeguards information.                                        in the NRC
                                                        . contained in this response may be releasedThe                to the  public NRC    letterand and placed our response have Public Document Room at your discretion.
received controlled and limited distribution on a "need to know" basis during the preparation of this response.
RI-90-A-0180 t r. t d LC S 06, I s s u e 1. a _._
Vide range InWDA9MrtMMMvere not operable on October 9,1990 as required to support refueling operations because:
: 1)      "A"          channel spikes periodically. This is a long standing problem that has not been resolved, the I6C technicians have " banged on" the channel to stop the spiking.
r$ck42501659104174 DOCK 05000336 P
i
'                                                                                                POR
                                                        ~ w.      arv m
  - - - - - - - - - - - - - ~ _ _ _ _ _ _ _ _ _ _ __                                    __                                      ---m
 
  ~      .                      .        .-                                                        .
c    . '.          -
    .=,.
Mr'. E. C. Vensinger, Chief
              -  U. S. Nuclear Regulatory Commission A09163/Page 2 December 21, 1990
 
===Background===
Millstone Unit No. 2 Technical Specifications require that two of the four vide range flux monitor channels be operable during shutdown and core alterations. On October 9, 1990, vide range channels A, B and D vere operable and being used to satisfy the Technical Specifications requirement. Intermittent spiking of the dravar indication has been a long standing problem. Over the past two years, six AV0s have been implemented to troubleshoot and resolve this problem. Efforts to determine the exact cause in the past have been inconclusive because the spiking is not repeatable on demand. Recent efforts to isolate the fault included interchanging the A draver into the C cabinet. This has proven successful in isolating the prt,blem to that draver as opposed to the rest of the channel's components. Current plans for resolving this problem include preparation of a spare drawer to allow one for one replacement and evaluating the need to upgrade the system to one of a design easier to maintain and more resistant to EMI.
 
===Response===
It is not an acceptable practice to " bang on" electronic equipment to resolve a problem. As the spiking problem with this draver is an intermittei , one, poor electrical connections are a possible cause.
Movement of the draver and the components within it has been attempted in an effort to determine a causal relationship.                              No repeatable response has been established.
: 2)    "C" channel cable has been damaged and this damage has affected readings on the channel. The channel has "lov IR" readings on the cable.
 
===Response===
Vhile replacing the channel "C" cabling, the cable outer conductor was                                  6 damaged. NCR 290-110 documented this damaged condition and described the repair in the disposition details. Subsequent testing of the cable was performed under AVO M2-90-ll450 and shoved the repair to be satisfactory and the "IR* to be within the specification limit.
: 3) A PDCR to change out the channels continues to be open and until closed and signed off, the channels cannot be operable.
 
===Background===
PDCR MP2-90-072 vas written to address the replacement.of vide range cable pull boxes and junction boxes. The equipment was accepted by Operations on November 2, 1990 after satisfactory retest. The PDCR vas closed on November 9, 1990.
i-i
                    . _ - - . _ . . . _._.r.. . - . . ~ . . . - . .. _ , . _ . . . . . . ,
 
9 Mr.' E. C. Vensinger, Chief a    U. S. Nuclear Regulatory Commission A09163/Page 3 December 21, 1990
 
===Response===
i The                  i The implementation of a PDCR is controlled by a vork order (AVO).
activity is authorized by Operations, performed by the appropriate work group, tested, reviewed by the appropriate engineer, and then accepted by Operations. Operations then determines the operability of the system based on the overall system status. The closeout of the PDCR document Its status, after the AVO is follows the closeout of the AVO document.
accepted by Operations, does not affect the operabil'ty of the system.
Issue 1.b._
i The I&C technicians have been under pressure to allow the_ (above) discrepant conditions to continue to exist with the channel considered operable to allow fuel alterations to occur.
 
===Response===
The intermittent spiking of the "A" vide range dravu has been a f rustrating problem for I&C technicians to deal with. During refueling activities, the appropriate _ conservative action has been taken when a problem such as EMI interference has caused any of the operable channels to be of suspect status.
These: include Steps 5.5 and 5.6 of Engineering Procedure gN-21008.
During the refueling activities of the 1990 refueling outage, technical specification requirements for flux monitoring vere met. No situations associated with the vide range nuclear instruments during core alterations occurred that required specific determination of operability by PORC.
Maintenance and surveillance testing was done in accordance with PORC approved procedures. The detector, junction box, and cable replacement activities vere accomplished to correct EE0 deficiencies. PORC has reviewed and anoroved an operability evaluation of the vide range nuclear instrumentation on December 12, 1990, PORC 42-90-192. This evaluation addressed the environmental qualification of the system.as required by 10CFR50.49 Issue 2 The "ovner" of the vide range nuclear instrument procedure, SP-2417H, was not consulted for a recent procedure change processed to support outege activities. This is contrary to I&C Department policy.
 
===Background===
ACP-0A-3.02 contains the station requirements for the reviev and approval of procedures. Procedure    Unit revisions are required to be reviewed by the department 2    I&C has a department specific instruction (3.01) on head and by PORC, department procedures to ensure that consistent, high quality procedures result from the department's efforts. Department instruction 3.01 currently includes guidance on the development of revisions. It also discusses the use
 
  ...w        . . . :. . .    . ..
s Mr'. E. C. Vensinger, Chief U. S. Nuclear Regulatory Commission A09163/Page 4 December 21, 1990 of a routing sheet by the PMMS planner as a means to coordinate revision                                '
development. The current routing sheets being issuedIt by    is the PNMS plar.ner up to the PMHS include a flovpath of possible desired reviewers.
planner to indicate what scope and the number of reviews necessary for any given revision.
The concept of each procedure having a procedure owner was implemented in 1988 to make the procedure review and revision process more offective and efficient.        Previously, procedures were not assigned individual responsibility below the department head level. This concept has proven effective in allowing the procedure owner to be the focal point for resolving issues associated with the procedure.
The refueling outage vide range nuclear instrumentation work activities were assigned primarily to one 160 specialist. This specialist was assigned to dayshift-throughout the outage. During the work activity, he foundThe          the PMMS existing procedure deficient and prepared the necessary revision.
planner, with the department head's concurrence, deleted the normal practice of having one of the reviews done by the procedure owner. The basis for this change in the normal department practice was the availability of other and better qualified reviewers. The procedure 'ovner" vas on nightshift during this time frame and was involved in other important issues of his ovn.
 
===Response===
Adequate Revision 3 of 1C-2417H vas not revieved by the procedure      "ovner".
This issue  was raised by review in lieu of the procedure "ovner" did occur.
the procedure "ovner" and was addressed by the department head.
RI-90-A-0202 Issue 1-Authorized Vork Order M2-90-00579 is a one-page AVO      for annual A note    on thepreventive AVO says that maintenance (PM) on various limitorque operators.                                                ,
the performance of the FM vill not affect EE0 boundaries. However, ACP-2.16, t
Page 21, Item D states that all maintenance work or EE0 examinations be                          ,
documented on three-page AV0s.
l                                a. Was the one-page AVO appropriate for this maintenance item? Vere there proper EQ revievs?-
L-
 
===Response===
In 1986, Unit 2 Maintenance reviewed PMs involving EEQ equipment in order L                                                                                                As a result of this              .
L                                      to determino which PMs did not affect EE0 boundaries.
I                                      evaluation, AV0s for PMs that do not affeet EE0 boundaries contain-the statement, " NOTE: The performance of this PH vill not affect the EE0 boundaries per R. Bonner 3/31/86". Based on a request from Unit 2, a P
        , _ ..              _._..        ,  ,  .  . . , , -  .-        ~    .,      .                    . . -          ,.
 
Hr.' E. C. Vensinger, Chief
* U. S. Nuclear Regulatory Conrission A09163/Page 5 December 21, 1990 letter of clarification to NEO Procedure 2.21 vill be issued by the Director of Generation Engineering and Design to clarify that inspections and PHs of EE0 equipment that do not impact any E3 attributes may be performed on non-0A vork orders.
: b. Vere single page AV0s appropriate in the prst to ensure E0 requirements were satisfied? (If a reviev of single pago AV0s is conducted, please discuss the sample size and effort to ensure that the sample is representative).
 
===Response===
Unit 2 Maintenance and Unit 2 Engineering conducted a review of allThe one-page AV0s (152 AV0s) that had been written for EE0 equipment.
result of the review indicated that none of the AV0s were actually used to direct any EE0 activitien, and therefore, ne challenges to EQ requirements were created by the use of one-page AV0s on the associated equipment.
: c.      ACP-0A-2.16 van revised on September 11, 1990 to require that maintenance on EE0 equipment be documented on three-page AV0s (Reference HH-90-214, dated November 5,1990). Vhy was this revision required?
 
===Response===
The revision to ACP-0A-2.16 was part of the periodic review of procedures.
The paragraph specifying the use of QA AV0s was primarily revisedThe        to word address EQ equipment replacements (Section III.d. paragraph 2).
changes to paragraph 1 of Section III.d were not meant to change the intent. As stated in the response to Item 1 above, a clarification to this concern vill be issued.
: d.      Are motor-operated valve cover gaskets replaced or are torque switch settings changed when using single page AV0s? If so, is this satisfactory to ensure EE0 requirements?
 
===Response===
As stated in the response to Item 2 above, Unit 2 Maintenance revieved all one-page AV0s that had been written for EE0 equipment. There vere no one-page AV0s written, nor vere there any descriptions of actual work performed to change torque switch settings or replace motor-operated valve cover gaskets.
Issue 2_
Authorized Vork Order AVO H2-90-12648 required electrical re-term ration of valve 2-MS-190B.
: a.      How and for hov long was the termination that needed to be rebne incorrect?
I
 
Mr. 'E. C. Vensinger, Chief U. S. Nuclear Regulatory Commission A09163/Page 6 December 21, 1990
 
===Response===
l The solenoid valve for 2-MS-1908 was inadvertently de-terminated during testing by I6C (AVO M2-90-08571) on August 14, 1990. AVO M2-90-08697 vas                                              l written to re-terminate the 50V with Raychem on August 15, 1990, and the                                              ;
job was completed on August 17, 1990. The termination was removed for                                                  '
inspection by AVO M2-90-12648 on October 30, 1990 and re-terminated the same day.
b .-
Vas there a saf.ety impact due to the original deficient termination?
 
===Response===
An engineering evaluation of the safety impact was performed by Unit 2                                              l Engineering as part of the response to Plant Incident Report 90-143.                                                ;
1 There was no safety impact due to the original deficient termination.
                                                                                                                        -(i.e.,                              ;
: c.          What were the circumstances that caused the AVO to be prepared?                                                    '
How was the deficiency discovered? What was the cause of the deficiency?)
c
 
===Response===
                                        -Based on discussions with the OC inspector and other electricians, a Unit 2_ electrician expressed a concern that the termination for 2-MS-1908 was not done properly. The electrician discussed his concern with the Unit 2                                          ;
                                          . Maintenance Manager who directed the electrician to inspectAVO  the M2-90-12648                                  '
termination and to re-terminate the connection correctly.
was written,to inspect and re-terminate the solenoid connections. The AVO r
included the re-terminating task because the termination could not be thoroughly inspected without destroying the splice.
p                                                                                                                                                            i l
: d. 'Was there a QC hold point or similar reviev 'that should have prevented the deficiency in the original termination.                                                                          r t,
 
===Response===
The deficiency with the' original termination vas.that there was unquallfled braided material that was covered by the Raychem splice An                which in turn caused the spilce-to be unqualified from an R80 standpoint.
E inspection plan with a specific inspection sheet for this type of Raychem
                                          -splice vas included in the AVO for the original' termination.-. The '1. No inspection sheet specified under cable preparation that there be,                                                .
braided Jacket or non-qualifled material . ..''. This _at tribute was signed                                    ,
off satisfactorily vith-no open items by a OC inspector.
,=                                    Additional' Discussion of Issue 2-jAs stated previously, a Unit 2 electrician expressed a concern that theSince solenoid valve for 2-MS-190B may not have been terminated correctly.
y mm -      l ,'. J  . . , - _./....        ,,,_e.  ~,, ..      ,.,__u.,4.,,_..'.,_4-.,.m,...,_...  ,      , , , ,    ,._-_-r v. m , .- n,,A,,,-r--ym,-y
 
O'                  ,
Mr.*E. C. Vensinger, Chief
                ' U. S. Nuclear Regulatory Commission A09163/Page 7 December 21,.1990 2-MS-1908 is on our E0HL, the electrician was directed to remove and investigate the existing terminatton and re-terminate the solenoid valve correctly.
The "as found" termination was inspected by two Unit 2 electricians and a OC inspector. All agreed that the braided material on the solenoid valve leads appeared to be under the Raychem sealing leg of the breakout which is not acceptable for an E0 termination. The termination was removed and replaced.
The termination that was removed was given to a Maintenance engineer for The termination was partially cut open, and it was destru:tive examination.
evident that the braided material had not been removed from the solenoid valve leads. An NCR (290-362) was generated to document the non-conforming termination and the associated rework. A PIR (90-143) was initiated to address reportability of the incident. The PIR vas dispositioned as not reportable. The partially opened termination and a copy of the inspection sheet for the original termination vere turned over to the Quality Services Department so their involvement with the original termination could be investigated. The Electrical Supervisor had a discussion with the Job Supervisor concerning the problem with the original termination and the importance of following procedures.
Atter our review and evaluation, we find that none of these issues taken either singularly or collectively present any indication of-a compromise of nuclear safety. Ve appreciate the opportunity to respond and explair. the basis for our actions. Please contact-members of my staff if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY E.J.gfoczka v Senior Vice President cci    V. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 l
l
_                                      ' ' * '  ">rw-r+- --m,my 7 , _ __}}

Latest revision as of 17:25, 27 September 2022

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML20073C334&oldid=3515459"