A09958, Discusses Review of RI-91-A-0243 Re Activities at Millstone Unit 2

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Discusses Review of RI-91-A-0243 Re Activities at Millstone Unit 2
ML20080L737
Person / Time
Site: Millstone Dominion icon.png
Issue date: 11/27/1991
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20079Q807 List:
References
FOIA-92-162 A09958, A9958, NUDOCS 9503020345
Download: ML20080L737 (2)


Text

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NORTHEAST UTM.mES mew- -%was w= P O. SOK 270

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November 27, 1991 Docket No. 50-336

) A09958 l 1

Y Employee Concerns l Re 1 l

! Mr. Charles V. Behl, Director j Division of Reactor Projects i U.S. Nuclear Regulatory Commission i 3 Region I  !

l 475 Allendale Road j King of Prussia, Pennsylvania 19406 1 I*

Dear Mr. Behl:

Millstone Nuclear Power Station, Unit No. 2

' R1-91-A-0243 I

Ve have completed our review of an identified issue concerning activities at )

Millstone station. As requested in your transmittal letter, our response does l l not contain kny personal privacy, proprietary, or safeguards information. The meterial contained in this response may be released to the public and placed in j

the NRC Public Document Room at your discretion. The NRC transmittal letter and our response have received controlled and limited distribution on a *need to i

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know" basis during the preparation of this response.

ISSUE:

j During the performance of SP-2404AV, it was noted that copies of form OF 2383C-1, 'Alaru Setpoint Control.' were not forwarded to the R:.gineering Department for review on two oc, tions as required by procedure OF 2383C, l

i "Radiati.on Monitor Setpoint Cont _ il.' Specifically, the alara setpoint changes j

for RMt6038, the Reactor Building Closed Cooling Vater Monitor, which occurred j

on May 11, 1991 and July 8,1991 were not forwarded to Engineering Department as 3

required. In fact, the last change made to the setpoint for RM 6018 which was i

reviewed occurred on February 2, 1991.

i REdUEST:

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Flease provide your review of the above assertion. If the above conditions are l

valid, notify us of the corrective actions you have taken to prevent recurrence.

3 Also, provide us with an assessment of the safety significance of any identified deficiencies, including any potentially generic considerations.

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RESPONSE:

1 The assertion is not valid as stated. Ve were aware of this issue prior to receipt of the notification letter f rom the NRC. The control forms for i

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, 9503020345 940009 PDR FOIA

HUBBARD92-162 PDR a v ,> v w.2 , s

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Mr. Charles V. Behl, Director A09958/Page 2 November 27, 1991 the two setpoint adjustments cited indicate that both 2383C-1 forms were sent to Engineering by Millstone Unit No. 2 Senior licensed operators at the In time that the setpoint changes were implemented consistent with governing procedures.

early September,1991, the Operations department responded to Copies the person who raised the concern, indicating that the forms had indeed been forwarded.

of the forms at issue are on file in the engineering department and were antisfactorily re-reviewed following original notification of the concern.

Af ter our review and evaluation of this issue, we find that this issuethe We appreciate did not present any indication of a compromise of nuclear safety. opp staff if there are further questions on any of these matters.

Very truly yours, NORTHEAST NUC1. EAR EhT.RGY COMPANY

% F. Cw J . F . %9p'e ka

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Executive Vice President cc 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 J. T. Shedlosky, U.S. Nuclear Regulatory Commission, Millstone O

-[ UNITED STATES '

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8' . NUCLEAR RECULATCRY COMMISS12N .

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e, 475 ALLENDALE AoAO KING oF PRusslA. PENNsVLVANIA 1940614tl n .....

3 Docket No. 50-336 FEB 24 W  ;

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i ' Mr. J. Opeka

! . Executive Vice President - Nuclear

[ Northeast Nuclear Energy Company P.O. Box 270

Hartford, Connecticut 06141 0270

Dear Mr. Opeka:

[

Subject:

NRC Region I taw Report No. 50-336/9131

! Mr. J. T. Shediosky and others of this office conducted a special safety inspection December 17, j 1991, through February 7,1992, at the Millstone Nuclear Station Unit 2, Waterford,

Connecticut. De inspection results.are documented in the enclosed report. Dey were i discussed with Mr. J. S. Keenan and other members of your staff at the conclusion of the inspection.

l Areas examined during the i===

  • ion are described in the enclosed report. Within these areas,
the inspection focused on issues brought to Northeast Utilities by the NRC. Our independent
review evaluated your performance in complying with regulatory requirements important to j public and worker health and safety. His review consisted of performance observations of i ongoing activities, inspection of plant equipment, interviews with personnel, and review of

) records.

j Our overall assessment was that performance was acceptable. De enclosed inspection report i notes a number of issues on which your staff agreed to provide a responte to the NRC.

} NNECO's response to the NRC may be made in communication with thc adent inspectors.

i

! In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and j its enclosures will be placed in the NRC Public Document Room. De responses directed by

this letter are not subjected to the clearance procedures of the Office of Management and Budget j as required by the Paperwork Reduction Act of 1980, Public Law No. M.511.

t l You/ cooperation with us is appreciated.

S' y. I 1 .. s,.

J Edward C. -

!=4) Chief 7,

i Projects Branch No. 4 1- Division of Reactor Projects G

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FEB 241992 -

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Northeast Nuclear Energy Company 2

Enclosure:

NRC Region I Inspection Report No. 50-336/91-31 i oc w/ enclosure: ,

W. D. Romberg, Vice President, Nuclear Operations j D. O. Nordquist, Director of Quality Services I R. M. Kacich, Manager, Nuclear Ucensing i S. E. Scace, Nuclear Station Director, Millstone J. S. Keenan, Nuclear Unit Director, Millstone Unit 2 i Gerald Garfield, Esquire Nicholas Reynolds, Esquire l l

K. Abraham, PAO (2) l

. Public Document Room (PDR) l j 14 cal Public Document Room (LPDR)

Nuclear Safety Information' Center (NSIC) i NRC Resident Inspector State of Connecticut i

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Conclusions regarding the adequacy, on programmatic basis, of non-seismically qualified j instrumentation installed in seismic category I systems were pending NRC evaluation of NNECO's assessment of this matter, i

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9.0 ADMINISTRATIVE CONTROL OF RADIATION MONITOR 4

MADRENANCE 1

1 Concerns had been expressed .wding administration deficiencies surrounding activities for radiation monitors. Specific issues include contradictions between procedures and vendor manuals, setpoint control, and inadequate radiological work practices, j Assessment '

2 -;

One concem involvWiscrepancies berecc acceptance criteria specified by a vendor technical

manual and that specified by surveillance procedure SP 2404AG, " Waste Gas Process Radiation
Monitor (RM 9095) Functional Test," revision 1. Specifically, the vendor manual had stated i that correct operation of the Upscale Check system was verified by @kiaa a " count level j

equal to the check source level." However, the procedure specified acceptance criteria for the i Upscale Check as " count levelindicator increase.' Because of this Agj, the validity of i the surveillana, and therefore the operability of the monitor was in doubt.

a W licensee had r*W that the vendor inanual contained generic recommendations for Upscale Check tests, and that these recommendations were not applicable and were superseded i by the PORC-approved procedure. 'Ihe Northeast Utilities Service Company (NUSCO)

Radiological Analysis Branch had confirmed the adequacy of the Waste Gas Monitor functional l test in a memorandum (NFe91-RA-338, dated May 28,1991) and concurred that the procedure I

took prh over the vendor manual.

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  • Ihe original concern and licensee response referenced Section 6.2 of a draft Revision 2 to the

{ surveillance procedure as providing the intended acceptance criteria (*Upecale Check >

! Background"). To date, this revision has yet to be approved. 'Ibe inspector considered that j NNECO should have referenced an approved procedure in response to this concern.

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h !=5== also reviewed a copy of SP 2404AF, Revision 1, Change 5, which includes corrections to identified problems and extensive procedure step rewrites that were incorporated i

as part of this latest upgrade. 'Ibe inspector determined, based en review, that the original procedure "deficicacies' would not have prevented a knowledgeable I&C nar*=leima from .

completing the calibration in a satisfactory manner. 'Ibe Gange Routing Sheet used to process and implement the I&C procedure change is not required by Millstone administrative procedures, ~

j but rather is a tool developed by the MP2 I&C department to initiate, track, and document i actions taken by personnel in the procedure upgrade process.

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l 26 j' A concern was identified related to the disposition of setpMnt control forms for radiation

monitor surveillance. Specifically, procedure OP 2383C, " Radiation Monitor Sotpoint Control,*

i requires that Alarm Setpoint Control form OP 2383C 1 be forwarded to the Engineering j

l Department for review following an equipment setpoint change. However, during the

performance of SP 2404AV, "RBCCW Radiation Monitor RM 6038 Calibration,' it was noted

! that Setpoint Control forms for two setpoint changes conducted May 11,1991, and July 8,1991, had not been forwarded to the Engineering Department.

NNECO responded that the a-**==ry forms were on file, having been reviewed in September 2 1991. 'Ihe inspector obtained copies of the forms in question and conducted a review of the

forms and procedure OP 2383C. 'Ihe procedure specifies no time frame restrictions for routing Setpoint Control forms to the Engineering Department, and the inspector concluded that the procedure was being followed. Unit 2 Engineering does maintain a file of all radiation monitor l setpoint control forms. .

l Conclusion i

j 'Ihe inspector determined that NNECO took appropriate action in response to the above issues.

3 Correct actions were taken to resolve vendor manual and procedure differences for RM 9095.

j Additionally, the Change Routing Sheet was adequate as initially filled out to implement the i

sw+seary procedure change of SP 2404AP, and the I&C supervisor was exercising supervisory

{ discretion in his assignment of the procedure change action. The issues reflected minor j administrative problems in the conduct of routine maintenance, procedures, and record keeping.

1 These issues did not affect nuclear safey, and the corrective actions taken indicate that these

!. concerns should be closed.

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10.0 STATION BATTERIES

) The NRC provided a concern about the safety-related Station Banery and the non-safety-related i

Tushine and Computer Battery procedures. 'Ibe NRC disposition of this concern involved an j i initial NRC inspection of the safety aspects of the concern and then the concern was provided J .l to the licensee for review and resolution. After the licensee response was received, a subsequent I i NRC ing=+iaa was conducted to evaluate the adequacy of the licensee's corrective actions.

i NNECO letter A10024, dated January 8,1992, described the licensee's evaluation of the l concern. The results of the subsequent NRC inspection are as follows:

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i Assessment -

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'Ihe inspector reviewed the battery procedures in question along with the tehnte=1 manual and i other applicable technical documentation associated with the installed batteries. The inspector  !

j also interviewed the engineer responsible for battery procedures and reviewed the ongoing l a actions at Millstone to improve the battery procedures, i

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A change to " Battery Pilot Cell Surveillance," SP 2736A, did provide retorque values for the 4

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-  ! g NUCLEAR REGULATORY COMMISSION g e afGioN I 475 ALLENDAtt meAo i e, f g"***j owo or enussia, etwwsytv4wiA iwsiais OCT 2 41991 Dea

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Per your October 10,1991 request, enclosed is a listing of concerns that you have provided to the NRC which are currently open according to our records. For your information, we have broken down each allegation into individual concems, and there are 86 concerns that remain open. The 21 concerns which are preceded by an asterisk are considered technically closed with the appropriate paperwork in process. You will be receiving closcout letters for those concerns, commensurate with their priority and our other work activities.

The enclosed listing provides the date of receipt of your concerns, and a brief summary. Your records should enable cross-reference between our case file numbers and related correspondence h

that you have received. Regarding any ot r allegations you have made, according to our files, those are closed with no further action planned by the NRC. I trust this meets your needs. I may be con:ac:ed at CIS) 337-5225 if you have any further questions.

Sircerely.

H Edward Wenzinger, Chie Reactor Projects Branc 4

Enclosure:

As stated ~

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i lnictmation in this record was deleted '

m ecco:da:Ce with the Freedom of Information Act, exemptions C~

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