A09453, Submits Response to Review of RI-91-A-0033 Issues Concerning Plant Activities
| ML20078N740 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/06/1991 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20078N620 | List: |
| References | |
| FOIA-92-162 A09453, A9453, NUDOCS 9412090048 | |
| Download: ML20078N740 (3) | |
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May 6, 1991 Docket No. 50-336
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A09653 Mr. Charles V. Rehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission i
l Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Behl:
Millstone Nuclear Power Station, Unit No. 2 f
RI-91-A-0033 have completed our review of identified issues concerning activities a Millstone Unit No.
2 (RI-91-A-0033).
As requested in your transmittal Ve letter, our response does not contain any personal privacy, proprietary, information. The saterial contained in this response say be NRC Public Document Room at your safeguardsto the public and placed in the have received controlled and released The NRC letter and our responseto know" basis during the preparation of discretion.
limited distribution on a "need this response.
Issue for the 10CFR50 Appendix R are no backup flov indicator instrumentsWhen the instruments are r There storage locker.
no controls in place to locate or otherwise provide There is no RBCCV total flow instrument, no 21199),
there are are no procedures in place to backup.{needed. Additionally, there i
instrumentation, install the instruments if required by AOP 2579AA. (This issue was gauge, no Keenan (Millstone Unit 2) on February 1, 1991 in a to Mr.
J.
telephone conference with Mr. D. Baverkamp (NRC)).
provided Please discuss the validity of the assertions.
Please discuss the availability and controls in place to install the flov indicators if removed from the
- needed, including occasions when the instruments are storage locker for calibration.
in the original letter received from statement was not included the NRC but was revised by the NRC during subsequent telephone 1.
This conversations.
h 2O g g 931207 HUBBARD92-162 ppR
Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Commission A09453/page 2 May 6, 1991 Ites 1 for the 10CTR50 Appendix a are no backup flov indicator instruments for calibration (under EN There locker when the instruments are removed 21199) and there are no controls in place to locate or otherwise provide storage instrumentation if needed.
Response
EN 21199 does not exist; however, EN 21199A, Rev. O, ef fective July 8,1987 The flov indicators which consist of ITT Barton gauges are an does exist. to the Appendix R program and are not required to be installed enhancement to meet the requirements of Appendix R.
The Appendix R program depends on the manual alignment of pump discharge valves to preclude the possibility of pump runout or loss of suction The operators agreed with this operating philosophy, however, they asked if gauges could be installed to verify flov and pressure.
pressure.
Millstone Unit No. 2 Engineering agreed and the operating procedure AOP 2579AA vas revised to install the gauges in place of the existing transmitters which the fire destroyed.
The Appendix R storage locker The gauges in surveillance was revised to add the local gauses.
WInstalled until backfeed power was established which inventory qtru t ha J u uv.
would be four hours into the fire, therefore, accessibility into the area where the gauges are to be installed is not a concern.
Shutdown storage locker which are The Appendix R storage cage and the Bot
))DT' I each located in a dif ferent fire area and are not af fected by the same fire 7j33S have duplicate sets of gauges which can be used.
summary, the gauges in question are not required for an Appendix R fire 1
are not taken credit for in the Appendix R analysis. They were added In the operating procedure and stocked in the Appendix R storage locker as and enhancement for operations. Therefore, the removal of the gauges for to an calibration has no affect on the Appendix R progras.
Item 2 There is no RBCCV flov instrument, no gauge, nor backup.
Response
The Millstone Unit No. 2 Appendix R safe shutdown analysis does not require availability of RBCCV flov instrumentation to athieve shutdown af ter a the fire.
Manual repositioning of RBCCV valves will assure proper system and acceptable flow rates. NNECO Operations recently requested the option to install a local RBCCV flov gauge be provided to enhance alignment The Appendix R procedures vill be updatgd that the post-fire shutdown process.
an r.ffect the ins t all_a t inn _ af t hI g="ger and twa new yang== will be added, to the Appendix R storage lockeMvo additional gauges will also be added WBot snutcovn ranel storage locker for the RBCCV system.
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O Mr. Charles V. Behl, Director i
U. 5. Nuclear Regulatory Consission A09453/Page 3 May 6, 1991 I
Ites 3 are no procedures in place to install the instruments if required by There A0P 2579AA.
i
Response
of pressure Appendix R procedure A0r 2579AA directs the installat The end pressures.
to verify flow and pump discharge after backfeed power is established which is four hours into the ability fire.
Due to the fire, the control room would be evacuated which would installed plan calling all on-call personnel to report to Instrumentation and Control personnel vould be part activate the emergency of the reporting team which would be directed to install the associated their assigned areas.
1 gauges.
The installation of the local instrumentation gauges is well within the A procedure for 7
capabilities of an Instrumentation and Control technician.
l this task is not warranted.
I After our review and evaluation, ve find that none of these items taken either singularly or collectively present any indication of a compromise of I
nuclear safety. Ve appreciate the opportunity to respond and explain the basis for our actions. Please contact my staff if there are any further questions on any of these matters.
i Very truly yours.
NORTHEAST NUC1. EAR ENERGY COMPANT l
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- t. J. My6c Ea ~ p Senior Vice President cci V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief. Projects Branch No.
4, Division of Reactor Projects
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Docket No. 50-336 A09447 Mr. Charles V. Behl Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region !
475 Allendale Road King of Prussia, Pennsylvania 19406 Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0036 f
have. completed our review of the identified issue concerning activities Ve Hillstone Unit No. 2 (RI-91-A-0036). As requested in your transmittal atletter, our response does not contain any personal privacy, proprietary, or safeguards information. The material contained in 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 know" basis during the preparation of this response.
Issue On February 6,1991, a Bealth Physics Technician sampled the containment by both grab sample and at the inlet to radiation monitor RM-8123A/B.
air samples resulted in about 50 cpe at the radiation monitor and 2300 cpa The from the grab sample. The radiation monitor may have been isolated from the containment.
Recently, the hydrogen monitor was determined to be isolated f rom the containment as documented in plant incident report, PIR 91-16.
discuss the operability of radiation monitor RM-8123A/B on February Please procedural problem that caused the two samples to 6,
1991. Vas there a differ?
Please discuss the possibility of a valve *antrol probles discussed in the PIR and [vhether itl may have caused the sampling problem.
If any weaknesses in either procedural compliance or valve control are determined, please discuss actions that you have talen or vill.tste to correct the probles.
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a Mr. Charles V. flehl, Director
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U. 5. Nuclear Regulatory Cossission A09447/Page 2 May 6, 1991
Response
ff The sample station located next to M-8123A/S takes a sample by tapp of the lines that supply the M-8123 A/B skid. The sample is taken in parallel with the M-8123A/S skid (see Attachment 1, Sketch it).
on our review of this configuration, there is no operability, l
Band procedural, or valve control problem associated with M-8123A/S.
f The discrepancy between the samples is most likely due to the samp i
j station being partially or totally isolated when the sample in quest on wa the February 6, 1991 M-8123A/B strip chart for I
A review of the not isolated. The gaseous in question indicates that M-8123A/S waschart were representative of the f
taken.
date particulate count rates on the strip expected values and did not show any deviation that would have experienced if M-8123A/B had been isolated. M-8123A/S was fun and relationship between this issue during this period. There is no properly and the event addressed by FIR 91-16.
The results of the sample taken on February 6, 1991 is typical for the The sample pump used for sampling is a positive displacement pump that has an automatic bypass feature.
If building atmosphere.
enclosure isolated, it would draw from the surrounding atmosphere. The ' samp isolated partially when the sample was taken. No l
station may have been conclusive reason for the low sample value has been identified.
local sample results has received l
remote and Current Bealth Physics requirements for The relationship between significant management attention.
to be taken to eliminate any question of sampling require local samples accuracy.
NNECO recognizes the need to evaluate enhance procedures addressing remote sampling in saapilng processes and vill leprovements 30, 1991.
sampling techniques by August find that this issue did not present any indication of a compromise of nuclear safety. Ve appreciate l
our review and evaluation, we After opportunity to respond and explain the basis for our actions. Plea l
further questions on any of these l
contact my staff if there are any i
matters.
Very truly yours, NORTHEAST NUC1. EAR ENERGY COMPANY I
- t. Jgitroczka /
Senior Vice President J. Raymond, Senior Resident Inspector, Millstone Unit pos.
1, 2, cc:
V.
4 Division of Reactor and 3 3.
C. Vensinger, Chief. Projects Branch No.
Projects
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i ATTACIDQDff N0.1 KII.LSTONE NUC1JLAR FOWER STATION, UNIT N0. 2 RI-91-A-0036 RM-4123A/B - SKRTCE 91 l
4 May 1991
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S AIMGATION RECEIFT REf0RT Date/ Time Received: July 1, 1991 1200 Allegation No.
]
Name:-
Specifically[
]allegedthat:
- 1) An issue which concerned a problem with the low steam generator pressure bistable block was discussed as Issue No. 2 (RI-91-A-0010) in an NU letter dated 11ay 6,1991 (serial A09449). On page number four under " Background" the letter in question states that "The sensitivity of. the bistable installed in RPS channel A was first identified in May 1986". L jetatedthathe has infomation concerning the earlier problems, which have Seen known of since 1971 2)
Issue No. I of the same letter addressed the use of nonconfoming steam generator man-way stude. It was{
position that the reactor coolant system should not have been filled until b nonconformance was dispositioned. Allowing the system to become operational in this manner was prohibited by step 5.7 of the corporate Nuclear Engineering and Operations (NE&O) procedure 3.05.
'lhe NU 1 tter (serial A09449) failed to address the requirements of this procedure.
jused training material fras I&C Department training given on 22, 1989 as the basis for his determination that the use of the steam generators to support a reactor coolant system fill was inappropriate due to the open nonconformance.
- 3) Issue No. 2 of the same letter addressed a work order (H2-90-15362) used to upgrade the conta at radiation monitor which was authorized without safety tags listed.
]statedthatwhenhewasgiventheauthorized work package by his supervisor, there were no personnel safety tage identi-fled. He researched the scope for tage which were issued. It is his opinion that this was the responsibility of his supervisor.
- 4) Another let.ter, dated May 6,1991 (serial A09463) addresned an issue concerning backup flow indicating instruments to measure RBCCM flow in certain scenarios required by 10 CFR 50, Appendix R (RJ-91-A-0033). Under &
" Response" section of Iten No. I the letter states that '"the Appendix R storage cage and the Hot Shutdown storage locker....have duplicate sets of i
gauges which can be used". (
' stated that he discovered that backup i
flow instruments were missing from storrge lockers; and, that he also discov-ered that the replacement gauges were of an incorrect range. This was not addressed in the NU letter.
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'e gg,cPJ ALLEGATION RECEIPT REIWT Received: July 1, 1991 1200 Allegation No.
Date/ rime Address:
Name:
]
City /St./ Zip:[
Ehone:
Confidentiality:
Was it requested? No Position /
Title:
NECO Alleger's Employer:
Docket No.: 50-336 Facility: Hillstone Unit 2 NRC by Northeast Inaccurate infonnation supplied to th
)yNRC Utilitica in their Hay 6,1991 letters which were forwarded to Allegation Summary:
low steam generator This included concerna of: way studa with open letter dated June 24, 1991.
preneure bistable censitivity; une of steam generator itches; and, lack of backup flow indicator instruments.
I with several sub-parts Number of Concerns:
P. J. Habignorst & J. T. ShediosP.y Employee receiving allegation:
Reactor Type of regulated activity:
Functional Area (s): Operations
[
') called the office and spoke with i from 1230 until Detailed Description of Allegation:
the inspectora frun approximately noon until 1215 and then aga nhis lie was very concerned with the Northeast Utilities 1345.
24, 1991.
6,1991 which were forwarded to(
]by letter dated June previous allegations.
provided to the NRC by information an appropriate appraisal of the Overall,(
) alleged that the inadequate to make In Northeast Utilities wasIlowever, the specifica were very difficult to follow. rom o licenace perforwux:e.
/ rambled the course of the lengthy conversation il lie e llenged individual another, generally without making a apoci ic anaert on hi tire contents.
d ce; they The recurring theme was that NU was not forthright in their corresp have been did not credit him with discovery of many of the leauen which mayth d
partially acted upon at the date of their letter; an,tion.
position without considering cocalated enforcement ac Inf m m m N m,ra
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k' AIMGATION RECEIPf RE130RT Date/ Time Received: July 1, 1991 1200 Allegation No.
Name:(
']
Specifically(
~) alleged h t:
- 1) An inaue which concerned a problem with the low steam generator pressure blatable block was discussed as Issue No. 2 (RI-91-A-0010) in an IRI letter dated May 6,1991 (aerial A09449). On page number four under " Background" the letter in question states that "The senaltivity of the bistable installed in RPS channel A was first identified in May 1986". C
]atatedthathe has information concerning the earlier problema, which have IFeen knowu of since 1977
- 2) Isaue No. I of the same lettgr addressed tp use of nonconforming steam coolant ayaten abould not have be,n filled until the no % t the reactor generator man-way stude.
it was
/ position e
nconformance was dispositioned. Allowing the ayates to become operational in this manner was prohibited by step 5.7 of the corporate Nuclear Engineering and Operations The NU l tter (aerial A09449) failed to addrena W (NE&O) procedure 3.05.
requirementa of this procedure.I
'used training material from I&C Departament training given on Marcli 22, 1989 as the haals for ble determination that the use of the steam generators to suppont a reactor coolant system fill was inappropriate due to the open nonconformance.
- 3) Issue No. 2 of W same letter addressed a work order (H2-90-15362) used to upgrade the containment radiation monitor which was authorized without work package by his { supervisor, there were no personnel safety tags identi-l safety taga listed.
fled. He researched the scope for tage which were inaued.
It la his opinion that this was the responsibility of his supervisor.
- 4) Another letter, dated May 6,1991 (serial A09453) addressed an inaue concerning backup flow indicating instruments to measure RBOCW flow in certain scenarios required by 10 CFR 50, Appendix R (RI-91-A-0033). Under the "Responne" section of Item No. I the letter states that "The Appendix R locker....have duplicate meta of storage cage and the Hot Shutdown storap' stated that he discovered that backup gaugen which can be used". ( from atorage lockers; and, that he also discov-flow instruments were missing ered that the replacement gaugen were of an incorrect range. This was not addressed in the NU letter.
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