B13905, Submits Response to Review of RI-91-A-0064 Issues Concerning Plant Activities
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L L IJ (203) 665-5000 August 9, 1991 Docket No. 50-336 B13905 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-0064 Ve have completed our review of identified issues concerning activities at Millstone Station. As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information.
The material contained in these responses 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.
In our letter of July 10, 1991 (A09594) addressing Issue 1 of RI-91-A-0064, ve addressed the technical aspects of the prefabricated structure for the new steam jet air ejector monitor. Ve vould like to supplement that information at this time with additional background.
NU vas aware of the situation throughout the entire process. The inspector who questioned, the fit-up inspection, docueented the condition on a Non-Conformance Report on March 28, 1991 in accordance with our. quality program.
Functional line and station management became involved in the resolution and recommended corrective action options on April 2, 1991.
This is the same date on which the Nuclear Safety Concerns Program (NSCP) was also contacted on a confidentiti basis regarding this issue. The NSCP continued to monitor progress towards resolution via independent contacts on site. This monitoring assured the material, as well as procedural, aspects of the issue were thoroughly addressed.
The NRC Resident
. Inspection ' staff were apprised of cor actions throughout this process.
Subsequent-line management review of this situation for generic implications was completed on May 17, 1991, two veeks before the NRC Staff's letter was issued to NNECO.
911031007B 911011 PDR ADOCK 05000336.
P PDR
A Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Commission
_ 13905/Page 2 B
August 9, 1991 Ve, provide the above background information to assure you of our ongoing efforts to bring all concerns to prompt and thorough resolution.
ISSUE 2:
On1 April.8,_1991, a NNECO technician and a contractor vere assigned fire protection-surveillance,' IC-2439A.
The NNECO technician had never been trained-on. ihe -surveillance procedure.
lDn April 3,
- 1991, another
-technician was performing monthly function surveillance SP-2410A for the acoustic valve monitoring-system associated with the pressurizer relief valves.
This_ vas ^the first time the_ technician had performed the surveillance since the last, major revision and again,-there had been no training' on the conduct of'the procedures with the incorporated revisions.
In both cases, the technicians experienced difficulty in completing the-procedures and numerous questions vere raised.
Please discuss the validity of the above assertions.
Please discuss employee training prior to performance of complex surveillances especially
.in cases involving: first time assignment and performance subsequent-to
- major revisions.. Please discuss any corrective actions that you have.taken.
or vill take'in these cases, to' ensure that the surveillances are completed competently _and' safely.
Backgrounds.
I&C Procedure SP-2439A A' review of the completed data sheets indicates that the Instrumentation and Controls (I&C) procedure was performed competently and safely. The technician assigned to this work had worked on various components of the fire protection system a total of 13 times since February 11, 1987, with
.the most.recent vork effort being Hay 23, 1991. While -working on the system the-technician has demonstrated to his management his competence and understanding of the system'and individual components, This technician has worked on the fire protection system both alone and n
with other members of the shop. When questions have arisen in the past he has not been reluctant to stop - and resolve those questions before continuing.
All of the preceding facts led to the decision to assign him to perform the procedure-in question. During the performance of IC_2439A there vere no unresolved questions that vere brought to the attention of
-I&C supervision.
L I&C-Procedure SP-2410A Both _ technicians. assigned to perform this surveillance had not received on-the-j ob training (0JT)'specifically for this procedure revision. They were, however, interim qualified due to their past experience in performing the
' procedure.
Each technician had successfully performed previous revisions of the procedure.
Since 1984, one technician had p,articipated in the. performance of this procedure 9 times and the other technician 4 times.
The technician who had performed the procedure 4 times had not done so since 1988.
Mr. Charics V. Bshl, Director U. S. N9 clear Regulatory Commission B13905/Page 3 August 9, 1991 Responset The two assertions are accurate. However.
it should be noted that it is
-not NNECO's expectation that all procedures vill be performed without any questions. by all vorkers. Difficulty may be experienced in performing a task that has not been performed for a period of time.
Personnel are expected to have a questioning attitude toward their vork and are encouraged to seek assistance from others in the shop.
In the case of the surveillances identified, the results of the work have been reviewed and found acceptable.
The procedures were completed competently and safely.
The personnel involved in these work activities were both Level 2 qualified which allows them to work independently on the majority of Hillstone Unit No. 2 systems. The process for training personnel to work on surveillances is to assign less experienced personnel to work with experienced personnel.
This allows for the transfer of knowledge and experience. The OJT program formally documents the training and evaluates aspects of this practice.
During implementation of the DJT program, experienced personnel are interim qualified to allow their continued participation prior to conducting the OJT activity.
ISSUE ?*
During performance of modification package PDCE M2-90-032, drawing errors l
vere noted for radiation monitor RM-9095. The errors involve the omission of a terminal board between the 120 VAC power supply and the radiation monitor solenoid valve on drawings 25203-39092 sheet 14a, 23203-31118 sheet 1,
and 25203-32026 sheet 53.
In addition to not identifying the drawing errors, the modification package did not identify the need for an equipment tagout.
l Please discuss the validity of the above assertions.
Please discuss actions that have been taken to correct ar e deficiencies with the modification package and with vork centrol deric." ries, in general.
Response
ACP-0A-3.14 " Design Change Notices For Design Documents," and ACP-0A-3.24 "Draving Change / Submittal Requests," provide the necessary guidance to anyone who feels that a draving change is necessary.
A review of the Generation Records Information Tracking System (GRITS) shoved no open change records for any of the reported drawings for this PDCE.
Since the design change package is still open, the necessary As-Built drawings vill be generated as part of the closure process.
-. ____. _ _. _ _ _ ~
Mr.- Ch:rles V. B:hl, Director i
U. S. Nuclear Regulatory Commission
-B13905/Page 4 2,
August 9,.1991 A ~ review of'the' reported dravings was performed in order-to determine exactly what changes'aight be required to respond to-this assertion. No
)
i deficiencies were apparent.
Unless more specific identification of the l
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missing terminal board can be supplied, no corrective action is believed to I
be. required.
i 1
The work consisted of preparction activities and actual work on installed i
plant equipment. It is our expectation that the AVO vould not initially p
specify-the need for tagout.
Tagout was added prior to the time actual work on the. plant equipment was started.
No work control deficiencies vere found during this reviev.
Our reviev.and evaluation finds'that the above assertions did not present-j any indication of a compromise-to nuclear safety..Ve vere not aware of-these two issues prior to the receipt of the Staff's 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 or these i-matters.
Very truly yours, NORTHEAST NUC EAR ENERGY COMPANY l
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i E.-J.yodzka'
-g Senior Vice President L
I cci V.
J. Raymond, Senior Resident inspector, Millstone Unit Nos.
1, 2, and 3 i
E.
C. Venzinger, Chief. Projects Branch No.
4, Division of Reactor 3
Projects E. M. Kelly, Chief, Reactor Projects Section 4A i
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