A09657, Submits Response to Review of RI-91-A-0118 Issues Concerning Plant Activities
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NORTHEAST UTILmES o.n.,.i on.c.. s.m.n s%.t. e.,nn. conn.n.eu i IN$sYeN P O Box 270
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(2031 % 5 5000 Augu' d 16, 1991 Docket No. 50-336 A09657 RE: Employee Concerns l
Mr Charles V. Hehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 Dear Mr. Hehl Hillstone Nuclear Power Station, Unit No. 2 RI-91-A-0118 Ve have completed our review of the identified issues concerning activities at Hillstone Station.
As requested in your trancmittal letter, our
. response does not contain any personal privacy, proprietary, or aafeguards information.
The material contained in this response may be reinsed 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 basis during the preparation of this distribution on a "need to knova response.
ISSUE 1:
On May 27, 1991 a manual work order 2-91-10 was prepared to lif t leads and install jumpers in accordance with OPS Procedure 2207, Section 4.9.2.
The purpose for this activity was to remove the S.I.A.S. open capability of MOV's 2-51-615, 625, 635 and 645.
No training had-been provided to the technician assigned the task.
- Further, the procedure calls for leads #3 and 69 to be lifted on terminal board TH.
In actuality, these leads nave designations #21 on the face of the tarminal board.
Similarly, on TBD and
- TDA, the procedure calls to lift leads 44 and 89 but they are marked #21.
- Further, the procedure calls for jumpers to be installed on-terminal 92 to -
94, and 88 to $10 on terminal board TH but the numbers on the terminal board are 412 and 822, and #12 and #32, respectively. Therefore, the procedure cannot be performed as written. No training was provided to l
ensure that proper acti m r, taken during the work.
9110310093 911011 PDR.ADOCK 05000336:
.P PDR;
Mr. Charles V. B;hl, Dircctsr U. S. Nuc1 car R:Fulatcry Commissicn A09657/Page 2 August 16, 1991
Response
The NNECO procedure is correct as written.
It provides the necessary technical details for a qualified electrician to remove the S.I.A.S. open capability from the four (4) LPSI injection valves.
The procedure
. identifies the valve, schematic, cable, terminal board, location on the i
terminal board, and the wire color to be lifted for each valve. The procedure was developed in cooperation with the Generation Test Service Department and verified prior to PORC approval.
The designations on the face of the terminal board discussed in Issue 1 are the wire number designations on the corresponding schematic.
These designations were installed.by Bechtel as part of the original plant equipment. As such, they are extra numbert not discusued in the procedure.
In response to this question, the procedure was again reviewed and valked through by the Millstone Unit No. 2 Electrical Maintenance Supervisor and the Millstone Unit No.
2 Generation Test Services Supervisor.
The procedure was found to be within the normal job skills of a qualified electrician.without any further training.
ISSUE 2 _
Vork Order M2-91-05370 recef'ed a department approval authorization by an individual with no or very little knowledge of Unit 2 systems, operations, or activities. Further, the authorizing individual has received no system training which would be required prior to authorizing vork on a category 1 system.
Responses Automated Vork Order (AVO) M2-91-05370 was written to replace a defective solenoid valve on the air operator for the "B*
Enclosure Building Filtration System (EBFS) -Filter Discharge Control Damper, 2-EB-42.
Subsequent to preparing this AVO, the problem was discovered to be in'the positioner and not the solenoid valve. The posit.foner was repaired by Northeast Nuclear Energy Company (NNECO) under a n parate work order, and M2-91-05370 vas canceled. Canceled work orders are not required to be kept for record purposes therefore, the hard copies of the AVO vere discardeo prior to receiving this concern.
Since the hard copy of H2-91-05370 is not available, NNECO is unable to confirm or deny any alleged deficiencies in the work authorisation.
Since no work was performed under M2-91-05370, there was no adverse impact on safety.
ISSUE 3:
Individuals temporarily upgraded to foreman or assigned as ' job supervisor"-
in accordance with ACP 2.02C have not been provided fitness-for-duty (TfD) training normally required for a foreman.
Neither have these individuals been provided supervisory training or training to deal with aberrant L
behavior.
Purther, other than basic system training, job supervisors have i,
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Hr. Char 1cs V. B:ble Dircetcr U. S. Nuclear Regulatory Commission A09657/Page 3 August 16. 1991 never been trained on system interaction and the effects of system interaction on plant operation and public safety.
This practice of temporary upgrade should be discontinued as it places the public in danger.
Response
Maintenance personnel are assigned as Job Supervisors based on their job qualifications as specified on the training qualification matrix and their experience with the equipment with which the job is associated. The Job Supervisor is the lead person actually performing vork in the field.
No special supervisory or Titness-For-Duty training is required for assignment as Job Supervisor.
Although Haintenance Supervisors are occasionally referred to as " Foreman," there are no " Foreman" job positions at the Hillstone Station.
Maintenance and 160 personnel are assigned as upgraded Maintenance and 16C supervisors during periods when the actual supervisor is unavailable due to
- vacation, training, sickness, etc.,
or when projects are of a sire and duration to varrant the assignment of a temporary supervisor.
Selection for upgrade to maintenance or 160 supervisor is based on an individual's experience.
The practice of upgrading personnel to serve in temporary supervisory roles is an accepted management practice which allows senior vorking level personnel to gain supervisory experience.
No additional training is offered to experienced individuals who may be j
selected for upgrade positions.
Maintenance and 16C supervisors do receive two days of training on recognizing behavior patterns and detecting aberrant behavior as part of our approved FFD prcgram.
This training is designed for permanent supervisory personnel (e.g. individual ob ervations s
over extended periods of time) and would be of little use to a person who is a temporary upgrade to stupervisor. Since the upgrade positions are for short intervals, additional s;upervisory asareness training is not needed.
If any questions arise regarding a particular individual's behavior, these question are referred to other management personnel on site.
NNECO has a highly competent technical staif to assist the Job Supervisors and Haintenance and I&C supervisors in the performance of their voik.
Neither the Maintenance nor I&C supervisors nor the temporary upgrades are expected to knov all the offects of system interactions on plant operations. They are expected to know their limitations in these areas and seek proper assistance when it is appropriate.
Experienced individuals with sufficient time in the department are selected for upgrade supervisors ensure they are capable of exercising proper judgment, and knowing from to whom they may obtain proper assistance when necessary.
F The assertion described in Issue 3 above is not valid. There is no adverse impact on public safety from the practice of temporary supervisory upgrades.
Mr. Char 10s V. H:hl, Directer U. S. Nuclear Regulatory Commission A09i57/Page 4 August 16, 1991 After our review and evaluation, we find that these issues did not present any indication of a compromise of nuclear safety. None of these issues were identified to us prior to receipt of your letter. Ve appreciate the opportunity to respond and explain the basis of our actions.
Please contact my staff if there are any further questions on any of these matters.
Very truly yours, NORTEEAST NUCLEAR ENERGY COMPANY i
FOR:
E. J. Mroczka Senior.Vice President
)~
BY:
V. D. Romberg }/
Vice President cci V.
J. Rrpond, Senior Resident Inspector, Hillstone Unit l'os.
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor Projects E. H. Kelly, Chief, Reactor Projects Section 4A t
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