A09559, Submits Response to Review of RI-91-A-0052 Issues Concerning Plant Activities
Text
_
NORTHEAST UTILITIES o.n r.i On.c... s m.n so..i. e.n.n. Conn.eiu Us,'. C $ $.Ys N U.~.
' P,O DOx270
.e.*w mata waa' HARTFORD. CONNECTICUT 061410270 J Z[Y,3%."w'"-
(203) 665-5000 L
L August 9,*1991 w
Docket No. 50-336 A09559 Mr. Charles V. Behl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Hehl:
Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0052 Ve: have completed our reviev of identified issues concerning activities at Hillstone Station.
As requested in your transmittal letter, 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 iur response have received controlled and limited distribution on a "ne(d to know" basis during the preparation of this response.
ISSUE 1:
During vork under PDCE H2-90-032, deficiencies have been identified in-Drawing 25203-39692, Sheet 14C, Similar d?ficiencies have been identified for the drawings associated with radiation monitors RM-8262 and RM-8123.
Although these deficiencies have been identified to management, no corrective actions have been implemented.
Additionally, an engineer marked-up the above draving (39692, Sheet 14C) on March 11, 1991, thereby implementing a change to a plant draving without proper management review a' proval. Finally, the PDCE (H2-90-032) did not contain appropriate and p
guidance' for the required tagout, appropriate viring diagrams were not
'ncluded as requited to ensure a complete tabout.
Please discuss the validity of the above assertions.
Please discuss your corrective actions.for any procedural adherence or other identified problems and discuss if any generic deficiencies that may require additional action are identified.
9110310066 911011
.PDR ADOCK 05000336 P
PDR-
Mr.CharlesV.Shhl,' Director-
]
U. S. Nuclear Regulatory Commission AC9559/Page.2 i
August 9,.1991
Background:
PDCE H2-90-032 does not reference Draving 25203-39692 Sheet 14C. - A redev of thefGeneration Records Information and Tracking System- (GR1W),
. indicates -that no such drawing exists in the Northeast Utilities drawing system.
Vithout specific details of these deficiencies it is difficult to assess what corrective action should be taken at this time.,
Related to the issue of the engineer and improper implementation-of' a change -to a plant.dravings. pen and ink changes to design modification j
packages are required by ACP-0A-3.10 " Preparation, Reviev, and Disposition i
of Plant Design Change Records (PDCRs)." The drawings being referred to
--here-are copies being used for construction.
The official controlled
_draving is maintained at the Northeast Utilities _ corporate office and can i
only be changed by a Design Change. Notice (DCN) or a Design Change Request (DCR) vith proper reviev. Upon completion of the modification, the pen and ink changes on-the copi/.s become an "as-built" draving, and are submitted as a DCR or DCN. -This is typical for all modifications being implemented by the PDCR/PDCE process.
i ACP-0A-3.10 for PDCRs does not address requirements for tagouts.
It is not
-required that the PDCR contain or reference all the information necessary to_ complete a_
tagout.
Per ACP-QA-2.06A " Station Tagging", it is the-j responsibility of the Operations Shift Supervisor and the Job Supervisor to.
1 establish the necessary boundaries and requirements for -the tagout.. By-1 I
definition in ACP-0A-2.06A, the Job Supervisor is the lead person actually
_ performing-the work in the field, i.e.,
Mechanic, Electrician.
{
L Technician, etc. No corrective action is planned since all other actions taken vere in accordance with plant approved procedures.
ISSUE 2 The following errors in authorized work order procedural references have i
L been identified; (A) Procedure IC 2422D-1 deletes reference to photohelic h
section for RM-8434A data sheet. The photohelic calibration is checked in l'
procedure :IC2422B; however, the physical location.of the photohelic is in radiation monitor RM8434B.
(B)_ radiation monitor 8132B has a magnehelic sensor but no calibration data sheet section exists. The flov inst.rument is in radiation monitor RM-8132A.
Procedure SP-2404AF has the calibration for.FIS-8132A.
(C) Radiation monitor RM 8145A has a magnehelic calibration-section;'however,-the flov element is in RM-8145B as opposed to RM-8145A.
L i-
'Please discuss the validity-of the'above assertions.
Please discuss any corrective actions that you have taken or vill take to correct any identified problems.
Background:
The radiation monitors for Millstone Unit No.
2 vere manufactured by l.-
Nuclear Measurement Corp.
(NMC).
The typical gaseous and particulate
[
monitor consists of a skid -design containing tvo lead shield assemblies, l-for particulate'(A) and one for gaseous (B) monitoring.
Each assembly one 8
, _. _ - ~.,
~
l l
Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Commission A09559/Page 3 August 9, 1991 houses one detector. The shield assemblies (A&B) are piped in series with a sample pump which draws the sample through each monitor, and discharges back to the system being monitored.
Sample flow through both shield assemblies is controlled by a flov switch located between the last shield and the sample pomp.
The flov svitch identification is not related to either of the detector / shield assemblies (A or B), since it controls flov through both.
The phys;-.I locatior, of the switch is insignificant to its placement in either the particulate or gaseous monitor calibration procedure.
Instrumentation and Controls (I&C) procedures IC 2422B and IC 2422D perform calibrations for gaseous and particulate channels of monitors which are not required by the Millstone Unit No.
2 Technical Specifications.
SP-2404AF is used for the calibration of RM 8132 Unit No. 2 Stack Geseous Process Radiation Monitor, which is a Technical Specification req'; ired monitor.
Response
Item A:
A review of the Program Maintenance hanagement System (PMMS) database indicates that both procedures IC 2422B and IC 2422D are correctly referenced for RM 8434 since it has both particulate and gaseous channele.
No corrective actions are required.
Item B:
A review of the PMMS data base indicates that both procedurc IC 2422D and SP-2404F are correctly referenced for RM 8132 since it has both particulate and gaseous channels. No corrective actions are required.
Item C:
A review of the PMMS data base indicates that both procedures IC 2422B and IC 2422D are correctly referenced for RM 8145 since it has both particulate and gaseous chap. Ms.
No corrective actions are required, p
ISSUE 3:
On the job training is not provided when required. Training is conducted only in conjunction with INP0 visits.
Acceptable on-the-job training could have eliminated confusion of the technicians involved in completion of SP-2401B on February 16, 1991.
Please discuss the validity of the above assertions.
Please t dscuss any corrective actions that you have taken or vill take to co..ect any identified problems.
Response
There is no requirement to perform on-the-job training (0JT) prior to procedure performance for any specialist.
OJT is conducted within the constraints of the prohtam.
This occurs throughout the year as the
)
. -..., ~.. - -. -.
Mr. Charles N. Behl, Ditector U.' S. Nuclear Regulatory Commission A09559/Page 4 August 9. 1991
' surveillance. activities and_ appropriate personnel are available. The dates of these training activities do not occur-only in conjunction with_INPO
- visits, but are. scheduled throughout the year.
The vide range _startup functional test procedure OJT is being reviewed for the ability to-be performed in a non-critical path environment.
ISSUE 4 '
Instrument and Controls technicians in the " upgrade" supervisory position have not received annual Fitness-For-Duty supervisory training.
Please discuss the validity of the above assertion.
Please discuss any corrective actions that you have taken or vill take to correct any identified problems.
Responses-These ' assignments are for a short term duration.- In this role, the
" upgrade" position does not have Fitness-for-Duty (FFD) observation responsibilities.
The normal supervisor as well as the Department Manager are available for conducting FFD observation.
Supervisory FFD training is indeed necessary to be able to identify long term behavioral changes, and indications of aberrant behavior, but is not required for temporary upgrades to work supervision per our FFD Procedure Manual or 10CFR76.
-After our review and evaluation, ve find that these issues did not present any indication of a compromise of nuclear' safety. Ve were not aware of any of _the. issues identified by the NRC. These issues are of
- a. type that-ve could expect employees to bring directly_to our. attention. Ve appreciate
~the opportunity-to respond and explain the basis of our actions. Please contact my; staff if there are any further questiona on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY E. J 7'hioczka g/
Senior Vice President ce s.
W. -J. Raymond, Senior Resident Inspector, Hillstone Unit Nos.-
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor Projects E.. M. Kelly, Chief, Reactor Projects Section 4A e
f
. =
,-