A09660, Submits Response to Review of RI-91-A-0069 Issues Concerning Plant Activities
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1 NORTHEAST UTILITIES o.n...i on.c... s.io.n so t s.n.n. Conn.ci,cu
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P.O BOX 270 HARTFORD. CONNECTICUT 06141 o270 J C%lC.7,'
(203) 665-5000 L
August-16, 1991 Docket No. 50-336 A0966D RE:
Employee Concerns Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road l
. King of Prussia, Pennsylvania 19406
Dear Mr. Behl:
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-Hillstone Nuclear Power Station, Unit No. 2 RI-91-A-0069 Ve have completed our review of identified issues concerning activities at Hillstone Station. As requested in your transmittal letter, our response-l
.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 basis during the preparation of this distribution on a "need to knova response.
ISSUE:
In the past, failure to-adequately purge and/or sample for hydrogen when l
performing calibration activities on RH 9095 has resulted in hydrogen explosions in the radiation monitor cabinet. Specifically, Surveillance Procedure SP 2404AB, Revision 2, does not provide the necessary details to appropriately establish or ' accomplish a hydrogen purge when perfo'rming calibrations on RH 9095. Additionally, surveillance procedure SP 2404AG does not mention the need to sample for hydrogen, and this sampling is necessary when the detector is removed from the " pig".
Request:
Please discuss the validity of the above assertions.
If deficiencies are identified in the applicable procedurer, please notify us of the corrective actions you have taken to prevent recurrence. Please provide us with an Essessment of ',he significance with regard to safety of any identified deficiencies.
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l Mr. Charles V. B:hl, Dir0ctot U. S. Nuclear Regulatory Commission A09660/Page 2 August 16, 1991
Background
SP 2404AH Revision 2 contains the guidance for purging the radiation monitor pig and for verifying by chemistry sample that no hydrogen is present.
SP 2404AG governs the functional test for the radiation monitor and does not specify removal of the detector from the pig.
If any calibration activities are required as a result of the functional test, the user is directed to procedure SP 2404AH.
Response
The assertion that the surveillance procedure does not contain the necessary level of detail is not accurate. The required steps are included in the procedure and the level of detail it cppropriate for the I&C personnel using the procedure. The actual purgin, activity is performed by Operations personnel. They are avare of the need to properly purge the system to ensure that all residual hydrogen is removed.
The essertion that SP 2404AG specifies removal of the detector from the
- pig, and therefore also requires guidance on sampling for hydrogen, is not accurate. The procedure governs functional testing activities which do not include detector removal.
After our review and evaluation, ve find that this issue does not present any indication of a compromise of nuclear saftty. Ve vere not aware of this issue prior to receipt of the NRC letter on this subject. Ve appreciate the opportunity to respond and explain the basis of our actions.
Please contact my staf f if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Hroczka Senior Vice President BY:
V. D. Romberg (s'
Vice President ec:
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 E. M. Kelly, Chief, Reactor Projects Section 4A i
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