ML20073C315

Submits Chronological Summary of Events Leading to Allegation RI-90-A-136 Re in-place Testing Process & Work on Flow Control Valve.Significant Discrepancies Noted Between Allegations & Util Documentation

ML20073C315
Person / Time
Site:	Millstone
Issue date:	12/03/1990
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20073C307	List: A09066, Submits Chronological Summary of Events Leading to Allegation RI-90-A-136 Re in-place Testing Process & Work on Flow Control Valve.Significant Discrepancies Noted Between Allegations & Util Documentation A09076, Submits Results of Review of Allegation RI-90-A-144 Re Steam Jet Air Ejector Radiation Monitor RM 5099 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 A09166, Submits Results of Review of Allegation R1-90-A-0208 Re Maint/Weld Repairs on Moisture Separator Reheaters.No Procedural Violations Occurred During Repair Process A09187, Submits Results of Review of Allegation R1-90-A-0205 Re Oil Not Removed from Motor Prior to Removing Motor or Disconnecting Motor Leads.Procedure MP-272OC5 Will Be Clarified A09188, Submits Results of Review of Allegation R1-90-A-0206 Re Low Flow Setpoint on Standby Pump.Caused by Procedural Noncompliance.Valve Setpoint Change Processed ML20073C348
References
A09066, A9066, NUDOCS 9104250179
Download: ML20073C315 (1)

Text

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1 December 3, 1990 Docket No. 50-336 A0VbR Hr. E. C. Venzinger, Chief Projects Branch No. 4 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 478 Allendale Road King of Prussin, Pennsylvania 19406

Dear Hr. Venringer:

Millstone Nuclear Power Station, Unit No. 2 RI-90-A-136 Ve have completed our review of an allegation concerning activities at H111 stone Unit 2 (RI-90-A-136). As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information. The material contained it, this response may be released to the public and placed in the NRC Public Document Room at your discretion. The NRC letter and our response have received controlled and limited distribution on a "need to knov" basis during the preparation of this response. Based upon our request on October 25, 1990, Region I personnel extended the due date for this response to December 3, 1990. The basis for our extension request was the competing demands for time on personnel involved in these matters and the then ongoing refueling outage.

In order to place this issue in perspective, the following chronological summary may be helpful.

On April 18, 1990, troubleshooting activities under AVO H2-90-4154 identified a problem associated with proper operation of the flov control valve (FCV) of the RM 8262 system. During this activity, it was noted that the stem of the FCV vas loose and that the FCV needed replacement. AVO H2-90-04311 was written to replace the FCV assembly.

At this time, bypass jumper 2-90-17 vas installed to allow manual flow control, and the radiation monitor 8262 was restored to service.

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DEC1I9012:07 NRC MILLSTONE OFFICE

' Mr. E. C. Vensinger, Chief 4

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- U. S. Nuclear Regulatory Commission A09066/Page 2 December 3, 1990 During the in-place testing process associated with the replacement activity for the new PCV, leakage was noted at the threaded connection on the valve body. The new valve was then removed from the system, and the old valve vas reinstalled. It was then determined that the threads on the replacement valve had been inadequately tapped during the time of manufacture. The threads vere j then fully tapped and the valve leak tested on the bench. The activity of tapping the threads and subsequent bench testing was not documented in AVO 4 a M2-90-14311.

The second in-cycle outage occurred and activities on this vork order vere delayed.

The valve was then reinstalled in the system on June 28, 1990, and the system was returned to service. This was done without the completion of a leak test required by the AVO inspection plan. The supervisor and the individual assigned to this work order then vent on vacation. During subsequent activities, it was noted that this work order was still open and the inspection plan incomplete. The leak test was performed satisfactorily on August 8,1990, and the AVO accepted by Operations.

During the period of June 29, 1990 through July 18, 1990, poor flow performance of the RH 8262 system was investigated by 1&c and Maintenance.

These activities were unrelated to the flow control valve.

Allegations

-Numerous vork orders and design changes have been performed on radiation monitors RM 8262 and RH 8123 during the period June through August 1990. The following items have been identified:

Item 1

n. Vork on the flov control valve, including replacement, commercial grade dedication, and retesting was conducted under AVO H2-90-04311 while the AVO only authorized work on the system bypass valves.

Response

AVO H2-90-04311 was clearly written to replace the flow control valve.

.The statement that it only authorized work on the bypass valve is inaccurate.

b. The flow control valve failed an initial 60 psi leak check, but this l

failure was not dispositioned.

Response

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.The dispositiun of the initial failure of the leak test was performed but not properly documented. This van caused by ineffective communications between the specialist conducting the work' and his supervisor. The leak test performed as part of the acceptance of the replacement valve during l? vork order close out is properly documented on the AVO.

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. 11. S. Nuclear Regulatory Commission A09066/Page 3 -

December 3, 1990

c. There was not adequate communication between Maintenance and Operations to ensure that proper actions were conducted when the monitors were inoperable.

1) From July 23, 1990 to August 4, 1990, neither monitor was operable, and compensatory actions were not taken. (The inoperability was due to in-progress systen design change work).

Response

The statement that neither RM vas operable during the period of time between July 23, 1990 to August 4, 1990 is not accurate. A review of operator rounds indicates that RH 8123 van out of service July 27, July 30, and August 2 to August 4, 1990 to upgrade the type of flov indicating avitch. RM 8262 vas operable during this time.

2) On July 26, 1990, RM 8262 was out of service to change filters and RM 8123 vas out of service due to a failed low flov alarm, but no Technical Specification Action Statement was logged, and no compensatory measures were taken. (Please address separately from 1).

Response

On July 26, 1990, both radiation monitors 8123 and 8262 vere in service. A normal particulate filter change took place at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />.

This process was done in series. It was also done with prior communication with and authorization from Operations. This activity does not require any entry into Technical Specification Action Statements.: therefore, none vere logged into, and no compensatory actions were taken.

d. Dravings have not been updated as a result of the above design change work.

Response

PDCR MP2-90-032 was written to modify the flov indicating switches for seven radiation monitors by replacing the Magnahelic flov indicating svitch vith a Photchelic flow indicating svitch. Only one of these monitors, RM 8123, has had the modification mode. No DCR has been processed at this time. The need to process DCRs at the time the system was returned to service vns discussed with plant engineering management.

As no operations critical draving was affected, no immediate changes vere deemed appropriate at that time.

Item 2 AVO H2-90-08033 installed a bypass jue;er (jumper card #3) vithout documentation. (No bypass jumper log entry and no PDCE). The tag was cleared on August 31, 1990.

• deb'18'9012:08 HRC MILLSTONE OFFICE P06 l ,~ .

Mr. E. C. Venzinger, Chief U. S. Nuclear Regulatory Commission A09066/Page 4 December 3, 1990

Response

[ Background - AVO H2-90 08033 vas written to correct a repert problem with the Metrascope position indication for CEA 18. During the work activities associated with the AVO, a broken edge connector was identified at pin location il on circuit card 43. The el pin connector was repaired by adding a piece of vire. It was identified later that the il pin connection was not used by the circuit. The edge connector was cleaned and indication was restored.1 No specific questions vere posed by this item. The addition of the small length of vire as a repair to the broken pin connector is not considered a plant modification. The use of a bypass jumper or design change administrative control was not considered necessary.

Ve observe that there are some rather significant discrepancies between the allegations described above and the facts as ve understand them, as substantiated by the documentation which exists at the Millstone site. This situation results in resources being expended on matters that have limited, if any, significance to them. Our reviev and evaluation have concluded that when

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taken either singularly or collectively, the allegations present no indication of a compromise of nuclear safety. Please contact my staff if there are any other questions on these matters.

Very truly yours, NORTilEAST NUCLEAR ENERGY COMPANY E. J. Mp6czka V Senior Tice Prcsident cci V. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 1

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