ML20073C348

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Submits Results of Review of Allegations R1-90-A-0204 Re Cabling Work Activity.Events Caused by Procedural Noncompliance.Appropriate Personnel Counseled
ML20073C348
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/21/1990
From: Mroczka E
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Wenzinger E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20073C307 List:
References
A09166, A9166, NUDOCS 9104250189
Download: ML20073C348 (9)
v • d • e


Text

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.......==='"" HARTFOnD CONNECTICUT 061410270 L L J O',*s"',07s*02.',70~, (?MN50M /g December 21, 1990 Docket No. 50-336 A09166 Mr. E. C. Venzinger, Chief Projects Dranch No. 4 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406

Dear Mr. Venzinger:

Millstone Nuclear Pover Station, Unit No. 2 RI-90-A-0204 and "' ^^ ' """^--

Ve have completed our review of an allegation concerning activities at As requested in your transmittal letter, Hillstone Unit No. 2 (RI-90-A-0204).

our response does not contain any personal privacy, proprietary, or safeguards information. The material contained in this response may be released to the The NRC public and placed in the NRC Public Document room at your discretion.

le'.ter and our response have received controlled and limited distribution on a "need to know" basis during the preparation of this tesponse. Based upon our request on December 20, 1990, Region I personnel extended the due date for RI-90-A-0208 to January 21, 1991. Additional time vas needed to resolve technical issues in order to provide a complete response.

RI-90-A-0204 Issue 1

Background

These same issues vere raised by an instrument specialist during the head cabling vork activity. There is a close correlation of the questions posed by the memo and response. This documentation is available for your staff's review.

9104250189 910417 FDR ADOCK 05000336 F PDR o$)42/ REV 4 88

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Mr E. C. Vensinger, Chief

, Lt . S. Nuclear Regulatory Commission A09166/Page 2 December 21, 1990 The following problems exist with IC 24210

1. Step 5.5.6.1 calls for visually inspecting the connector assemblies on each cable for signs of degradation or damage. Problems have been identitled with Z-1, f4, 47, and Z-2, 18. The cables were put together anyva). Please explain. Further, the step calls for visually inspecting the Grafoil gasket at the 1.itton-Veam connector, but no information Are I6C is provided about these connectors or the Grafoil gaskets.Does tne procedure require upgrad technicians trained on these items?

to explain what the technician is looking f9r in this step? No figure is provided with the procedure to identify the connectors, and Howit are is the impossible to read the etched numbers on the connectors.

connectors to be identified on the job?

Response

The activity of reassembling the HJTC connectors was begun on a Sunday vith an upgraded specialist serving as the first line supervisor and no During the work activity, several engineering support readily available. The following day, Honday, these questions vere raised and documented.

questions were investigated and resolved by more knowledgeable I&C and Engineering personnel.

Connector training performed to date has not included the specific knowledge needed to perform this task. Training requirements for this task are being reviewed for addition to the 160 technical training program.

As written, the procedure makes the assumption the I&C technician using it has the knowledge necessary to determine the gasket location and condition. As a result of this experience, the procedure owner has been instructed to revise the procedure to include the necessary information.

The connections are ide:41 tied by a small stenciled number. They are also staggered and are in the order of Il being the highest and 68 being the lovest. As lighting is limited and access is dif ficult, the normal method for connector identification has been its order of elevation.

2. The caution on page 14 is impossible to achieve as only about a 45-degree turn is possible. Is this technically satisfactory? Does this indicate Has there been procedural non-compliance during past performanew?

repeated connection damage in complying with this step

Response

On the following Honday, additional technical information was obtained from the responsible vendor. Procedure changes were implemented to allow an alternative method of torquing the connector. This method was used to ensure the proper assembly of the connectors. No significant connector damage has occurred.

m__,------ _

Mr. E. C. Vensinger, Chief

. U. S. Nucleer Regulatory Commission A09166/Page 3 December 21, 1990

3. Dust cover caps are shovn in figures in IC-24210 and 10-24190. These caps are not being used. Are dust covers needed? Why are they not used if shown in the figure?

Response

The use of dust covers is not delineated by the procedure. Dust covers only appear in the figure. The need for their use is currently being evaluated. The existing figure has been replicated from a vendor drawing that shova the "as supplied" IlJTC probe. The figure was not intended to dictate the use of dust caps in the field. The figure also has shortcomings in not supplying the necessary detail needed for inspection and assembly of the connectors.

4. Step 5.6.4 calls for the verification of the HJTC probes per IC-2419C.

Why is this not done prior to the connection of the detector cables?

Response

This HJTC probe had been previously used. There was no need to perform the verification of the known good probe. The retest of the overall system response verifies the condition of the probe, as well as the entire system. The step has since been removed from the procedure.

5. Are any generic problems with procedural non-compliance or laxity with Please regards to procedural adherence evidenced by these problems?

explain.

Response

There are no generic problems with procedure non-compliance as evidenced by these problems. Note that this procedure has not been upgraded as part of the station procedure upgrade program. Veaknesses in such procedures like this ont have previously been discussed with the NRC staff. This example serves to demonstrate that with the proper attention to detail by the technicians involved and with the proper response and direction f rom Where their supervision that a proper quality activity results.

appropriate, the necessary NCRs and procedure changes were implemented, and the noted need for procedure enhancements took place.

Issue 2 Instrument Calibration Review ICR 90-113 vas vr!' ten on November 2,1990.

Please provide the resolution documentation for the ICR.

Response

A copy of the Instrument Calibration Review ICR 90-113 is attached.

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Mr.' E. C. Vensinger, Chief U. S. Nuclear Regulatory Commission A09166/Page 4 December 21, 1990 Iseue_3 Recently, an ICR vas generated concerningPlease out-of-specification test voltages provide the resolution found during the performance of SP-24040.

documentation for the ICR. Historically, the reference voltages have been out of specification:

March 9, 1990 AVO H2-90-02559 May 5, 1990 AVO H2-90-02736 May 5, 1990 AVO H2-90-05237 May 5, 1990 AVO H2-90-05400 August 30, 1990 Surveillance, SP-2401P, and SP-2401B Please discuss the operability of Channel "C" of the RPS with the historic out-of-specification test voltages. Note, Oravings 25203-39069, sheet 40, and 25203-25193, sheet 6, supposedly identify the ref erence test voltage applications.

Response

There is no I&C procedure SP-2404C. Therefore, it is not possible to supply any information concerning an ICR generated while performing this procedure.

"C" Reactor Protection The AV0s referenced vere written against RPS channelThere are no test voltages System Calibration and Indication Panel However, (RPSCIP).the RPSCIP digital volt meter generated in this instrument draver.

(DVH) is used to monitor the core protection calculator A review of surveillance (CPC) andlogic power equipment supp1v output voltage (+/-10vde).

history shows that following replacement of a different pover supply (+5vde) in May 1989 by PDCR HP2-89-028, the RPSCIP DVH indicated a .003vde offset ftom the actual +/-10vde power supply output. Investigationrevealed during the 1990 a difference in refueling shutdown, while performing PDCR HP2-89-068, This caused the RPSCIP DVH ground potential between the RPSCIP and the CPC.

to indicate incorrectly by .003ved. This is at the limit of the tolerance applied to the DVH indication (+/ .003vde). A design change notice (DON

  1. DH2-P-022-00) was written against PDCR HP2-89-068 and implemented to correct the problem. As can be seen by reviewing the referenced AV0s, the problem vas identified shortly af ter the +5vde modification and determined to be limited to the DVH indication only. An AVO to investigate the problem was written at that time and scheduled for the refuel.

Also referenced are two surveillance procedures for August 30, 1990. One surveillance concerns the CPC, SP-2401F, the RPS high power trip test, which is performed monthly. It documents the above DVH indication problem and shovs The the high power trip function of the CPC to be operable at this time.

other referenced surveillance SP-2401B, concerns the vide range flux monitor functional. This procedure is performed veekly while shut dovn. Since Hillstone Unit No. 2 vas not shut down during the referenced time, it is difficult to determine how this is related to the issue.

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Mr.'E. C. Vensinger, Chief

- U. S. Nuclear Regulatory Commission A09166/Page 5 December 21, 1990 Two drawings are referenced which asupposedly identify the reference test voltage applications". The first drawing, 25203-39069, It shows the power supplies sheet connection 40, is an to electrical schematic of the CPC.

the circuit but makes no reference to the application of the voltage with It has no connection to the vide range flux respect to absolute values.

monitor circuit. The second draving referenced, 25203-25193, sheet 6, does not exist in the NUSCO drawing system.

More specific information vill be required to resolve this issue.

Issue 4 The tag A red tag vas improperly hung by Operations on the back of C05/C06.500(*) knows th was hung on TDE but should have been hung on TDD.

.Please explain the tagout problem and actions taken to both correct the problem and to prevent recurrence.

(*) - identity may be obtained from the SRI.

Response

The pins for Veldmuller Block TDD, on the back of C05/C06, were properly removed and placed in their correct storsga Thelocation red tagatwas theproperly time of tagging, filled out under the guidance of an I&C technician.The tagging discrepancy was that the red tag wa for Veidmuller Block TDD.

not attached directly to Veldmuller Block TDD but to a cable directly beside This tagging discrepancy vas noticed by an TDD which was labeled TDE. The opere. tot then moved the operator who consulted with an I&C technician. 1,ong-term actions to tag from the cable to the pins for Veidmuller Block TDD.

prevent recurrence is to formally distribute to all Unit 2 Operations personnel a standardized method for tagging Veldmuller Blocks.

Issue 5 A recent annunciator vindow change C04(CRDR) was apparently not reviewed and completed properly as procedures SP-24018, 2401F, and 2401J had to be changed Please during the performance to accommodate the annunciator vindow changes.

discuss the accuracy of the statement and any actions that you have taken or may take to rectify any identified problems.

Background

As part of the CRDR improvements, several annunciator vindows were relocated.

This. activity took place over the course of the 1990 refueling outage.

Changes to IEC procedures were appropriate as the-procedures Changes to SP-2401B and contained its data the.

detail of the annunciator vindov location.

sheet and SP-2401J vere processed at Itthe time the procedures is necessary were for procedure implemented.

changes No changes were required to SP-2401F.

required by a modification to be approved prior to the impicmentation of the procedure. This was done-in this case.

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'Mr., 5. C. Vensinger, Chief U. S. Nuclear Regulatory Commission A09166/Page 6 December 21, 1990 Res pons _e.

Alt. hough several changes were required, no problems requiring corrective action exist. All modification-related procedure changes can not be made in advance of the task being assigned.

Issue 6 On November 5,1990, upon completion of the CVP portion of SP-2401J, (the CRDR change was done as a non-intent change on this date), Channel C T0-7 was left bypassed by technicians after the surveillance was turned in, and the l technicians had to be called by the SS and the channel unbypassed by the SCO. I Please discuss the procedural compliance aspects of this statement.

Response

SP-2401J requires This event is an example of procedural noncompliance.

restoration of the bypass key. This was not done prior to turning in the i surveillance. The appropriate personnel have been counseled with respect to i

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this issue.- >

Af ter our review and evaluation, ve find that none of these issues taken either_ singularly or co11 actively present any indication of a compromise of '

nucler.r safety. We appreciate the opportunity to respond and explain 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.Jr"oczka #

Senior Vice President cci V. J. Raymond, Senior Resident Inspector, Millstone Unit Noc. 1, 2, and 3 i

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  • ATTACHMENT 1 INSTRUMENT CALIBRATION REVIEV FORM 90-113 ISSUE NO. 2 December 1 0

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'i(b2NADATE $-8"7)b MTG.NO, N70-66 NORM APPh0VED J O INSTRUMENT CAUBRATION REVIEW FORM Part 1 To be completed by person performing work.

ICR Number @-//J _ AWO# idd clo- /~9;;375~ Date t clo Time M ! M NameM@>cMina p. h%tpe, instrument or Device Alfected 10# N-100L4 O v Procedure Number:3D4415tc _

Title:

Men ,o gapwg Tic /rxtape[(hb/ek Description of Event or Calibration Results h Nobj. uultfd2.' CAM -t(e f04%

$0 4de _ IM Drehtl? o . il dI /)A LeM 07%( QIUL.

Phuuts %7tp- PT nto4 rAn* QvuA tbein6A b- Presmm

[ ] instrument Drift ( ) Unknown Cause: (l! Facts are Knov n)

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y Other Explain: '

i Would the Instrument or Control System have performed its function as required by Tech Specs?

Yes ( ) ' No h N/A ( )

Basis: Mlfr[.S -

Wes tbc.ln:trumcnt or Contrc' Gystem (Ajarm. Djstable Trin 6tc..) found in a conwiv ::v- ini.;;;:. a Yes [ ] No M N/A[ } ,g Basis: 'IScLak b is a PlR recommended? Yesb/) No [ ] ,

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~ ~ Technician / Specialist I&C Supervisor Part 2 ,To be completed by SS or SCO.

Mode 3 Power o% Temp. Soo*F Press. 400+

Pn written (dNo_( _] Nes.(ll yes, reference ICR 'on PlR & attach copy of PIR) PIR#

T Concurred with:

12/M/p Completed b/ - - -

uuty Officbr W SS/SCO {j

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Part 3 To be completed by l&C Manager / Designee ,

Cause of problem: "[ as n,c m [ n o t~ cmWM tR f)4/#L//hEUO 6L4A u. wrc. ch ed/m huA.-a la 4 aoow,$s.can'a kno,aw a e-P k u anu4: vOvec kocach r Corrective Action (il required): d/ff, W (0C y i PI(ccy do T Q /r3 d -/

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r Long Term reliability concern's ( )YES [ dNO Action to address concerns: t/ M -

Effect on previous surveillances [ ]YES [ vf NO Action Required: RoyC I&C Open item ( )YES [ d NO IfYes,#

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' Human Performance Enhancement System (HPES) review required?

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[ ]YES [ d NO Date forwarded Completed By: _ _

Approved By:

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I&C Manager

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