IR 05000336/1989022
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UNITED STATES
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k MUCLEAR REGULATORY COMMISSiOH REGION 1
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KING OF PRUSSIA, PENNSYLVANIA 19406
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Mo Docket No. 50-336
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File No. RI-A-SS-0040 ( A.47.01)
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Subject: Allecation Ccncerninc Millstone Nuclear Power Statien Unit 2 The NRC Region I cffice bas ccrpleted its f ollowup in response to two concerns you brought to our attention en September 22 and October 24, 1989.
The first corcern was that the reactor ;rotecticn system was apparently inoperable based on the performance of surveillance procedure SP2:01D cn September 22,19E9.
The seconc concern was tr.at tre direction you received frc i the shif t super-
visor to finish the test cn Sectember 22 and then investicate ancmalous incica-l
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i tiens, was c
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We four.c ycur concerns unsubstantiated and have documented both issues in inspecticn report 50-335/E9-22 cetail 9.2, dated February 27, 1990.
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We appreciate ycu informing us of your concerns and feel that our actions en this atter have been responsive to ycur concerns. Should you have acditional questions, or if I can be of further assistance in tr.is ratter, please call ce collect at (215) 337-5220.
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Enclosed are applicable excerpcs from inspection report 50-335/89-22.
Sincerely, t
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Reactor Projects Secti n 4A
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Division of Reactor Projects
Enclosure:
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NUCLEAR REGULATORY COMMISSION
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REGION I
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475 ALLENDALE ROAD
KING OF PnusSIA, PENNSYLVANIA 19406 Occket Nos. 50-245; 50-336; 50-423 i
Northeast Nuclear Energy Company ATIN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations P. D. Box 270 Hartford, Connecticut C6141-0270 Gentlemen:
Subject: NRC Region I Combined Inspection 50-245/E9-23 and 50-336/89-22 and NRC Region I Inspection 50-423/89-23 This refers to the reutine resident safety inspections conducted by Mr. P. Habighorst and others of this office on September 6, 1989 through October 20, 1989 at Millstone Nuclear Power Station Units 1 and 2 and conducted by Messrs. W. Raymond and K. Kolaczyk of this office on November 28, 1989 thrcugh January 4, 1990 at Millstone Nuclear Pcwer Station
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Unit 3.
Areas examined during these inspections are described in the NRC Region I inspection reports which were enclosed in my letters to you dated January 3, and February 26, 1990.
Based on the results of these inspections, it appears that one of your activities was not ccnducted in full compliance with NRC and Department of Transportation recuirements, as set forth in the Notice of Violation enclosed herewith as Appendix A.
The violation ccncerned a September 14, 1989 Millstone Station shipent of a limited cuantity package of contaminated ladders and a fibersccpe to the Haddam Neck Plart. A licensee external radiation level survey of the package conducted at the Haddam Neck Plant revealed that the dose rate on contact with the package was 1.1 millirem per bour (mr/hr), which is in excess of the 49 CFR limit of 0.5 mr/hr for shipment of a limited quantity cf radioactive materials.
The violation has been categorized by severity level af ter consideration of "The General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy). You are required to respond to this letter, and in preparing your response, you should follow the instructions in Appendix A.
The response directed by this letter and the accompanying notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reducticn Act of 1980, PL-96-511.
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y Your cooperation with us in this matter is appreciated.
Si erely, I f
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Projects Branch No. 4 Division of Reactor Pro ects CC*
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W. D. Romberg, Vice President, Nuclear Operations 5. E. Scace, Nuclear Station Director, Millstone Station J. P. Stetz, Nuclear Unit Director, Millstone Unit 1 J. 5. Keenan, Nuclear Unit Director, Millstone Unit 2 C. H. Clement, Nuclear Unit Director, Millstone Unit 3 D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (POR)
local Public Document Room (LPDR)
ficclear Safety Information Center (NSIC)
NRC Resident inspector State cf Connecticut
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The loss of normal feedwater analysis assumes the normal feedwater regulating system is inoperative. Assuming single active failure of one of the two motor driven pumps, and a passive AFW feedline break, one motor driven AFd pump is still available to maintain a heat sink in the steam Senerators. The turbine-driven AFd pump is inoperative due to loss of steam flow from the steam generator with the passive failure.
In the course of this review the inspector noted an apparent discrepancy between the FSAR accident review and the T5 basis for the combination of AFW pumps necessary to remove reactor decay heat. The
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discrepancy was presented to the licensee for disposition.
In conclusion, the licensee maintains the auxiliary feedwater
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system's intenced safety function with one of two parallel steam
,upply valves shut to the turbine driven auxiliary feedwater pump.
9.2 Allecation: Reactor Protection System (RPS) Matrix Testing (RI-SS-0040)
On Septemoer 22, the inspector received two concerns frcm a licensee employee. The concerns were: During performance of RPS matrix
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testing, an abnormal time celay was indicated in the activation of the hold / crop-cut light'in the trip path for channels A and D RPS logic combination, potentially resulting in a time delay impacting RPS respense time and operability, and the alleger was " directed" by the shift sucervisor to continue the surveillance rather than investigate the icentified test discrepancy as required per procecure.
On September 22, the alleger was performing monthly surveillance
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protec_-e SP 2001D "RPS P. atrix Logic and Trip Path Relay Test" as required per technical specification 3.3.1.1, Table 4.3-1, Item 12 and 14.
Procedural step 6.18 says to place the AD matrix channel trip select switch to off and verify the AS-1, AD-2, AD-3, and AD-4 hold / drop-out white lights are on.
The acceptance criterion is that the lights are illuminated with no prescribed time interval. The alleger indicated that the hold / drop-out lights illuminated with an abnormal time interval (two-four seconds). The initial concern was
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if the time delay potentially impacted the RPS operability. The
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inspector assessed RPS operability utilizing licensee wiring diagrams, FSAR 7.2.3.2.2, and 7.2.4, discussions with licensee persennel, review of SP 24010, and review of T5 3.3.1.1 requirements.
RPS matrix testing (SP 2401D) is performed by opening a pair of contacts in the trip matrix and then selectively allowing one matrix relay at a tire to operate. Matrix testing on 9/22/E9 noted a time delay between when position 2 was selected on the AD matrix trip select switch and when the matrix relay dropped out. The following is a description of how the matrix test circuit works.
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The contacts in the trip matrix are selected by the channel trip
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This selects the parameter (e.g., high power) to be When a valid position is selected on the channel trip select j
select switch.
tested.
switch, and the matrix relay bold push button is pressed, power is applied to the " buck" coil in each of the two trip matrix relays
The buck coil opposes the normal coil and forces the trip l
selected.
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When the relays open, the corresponding trip matrix relays to open.
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lights illuminate on the RPS bistable indicating the trip matrix t
relays have opened. Opening the trip natrix relay contacts removes power to the matrix relays. The matrix relay hold push button also The boost coils l
applies power to the matrix relay " boost" coils.
i nold tne matrix relays closed when the power is removed from the The
normal coils. This prevents a plant trip during r. atrix testing.
l matrix trip select switch opens the circuit to the boost coil of one The matrix relay selected then drops cut and
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matrix relay at a time.
If the contacts on the matrix trip
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a pair of scram breakers opens.
I switch co not open, the power to the boost coil isn't removed select and the matrix relay won't drip out. The buck and boost test circuit
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coils in the trip matrix relays and matrix relays are electrically The normal relay coils
separate from the normal trip relay coils.
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i continue to function even while the test circuit coils are being used.
j The f unction of the RPS to open the scram breakers in the required l
time when a trip condition exists is not affected by position 2 of
the AD matrix trip select switch and subsequently the time delay l
associated with the hold / drop-cut lights.
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The licensee investigation further indicated this item was previously 18, 1988 during the performarce of surveillance identified en August i
Work crcer P.2-SS-09225 was generated to replace the matrix SP 2601D.
relay select switch for the RPS AD matrix during the mid-cycle outage
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starting on October 21, 1989.
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The The inspector interviewed the shift supervisor on September 23.
shif t supervisor stated that during the matrix test, the alleger came
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l to him to report an anomaly in completing the test which the alleger l
thought was an anomaly required to stop the test pending further i
investigation.
The problem presented to the shift supervisor was
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that the drop-out light was delayed by several seconds while l
performing the test of the AD logic.
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The shift supervisor stated he spent time with the alleger reviewing the step in question, what action was required, and wnat procedure
Based on this
requirements existed for completion of the step.
the shift supervisor stated he concluded there was little
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review, since significance in the delay in illuminating the drop-out light,
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there is no explicit acceptance criteria stated or implied to Since the desired action did occur after only a
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complete the step.
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few seconds, the shift supervisor concluded that the delay was not significant, that the intent of the step had been met, and that there
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I was no anomaly that would warrant immediate investigation such that testing should be suspended. The shift supervisor stated that during i
the test ne requested the test be continued, ("I would like to finish l
the test").
The shift supervisor stated he tried to contact I&C l
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sunervision to request evaluation of the test results after comple-
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tion. The shift supervisor was aware that the issue was evaluated later on September 22 and determined to be a known problem that
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involved the RPS matrix test circuitry only. The shift supervisor's
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basis to continue the surveillance at the time of the test, was that the delay was not significant because of the lack of explicit or i
implied acceptance criteria in the procedure on the completion of the step. The shif t supervisor was confident at the time that RPS.
operability was not at issue based on his general knowledge of
testing procedures at Millstone, and critical test results are
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highlighted by acceptance criteria.
Followup review by the inspector indicated the licensee was aware of
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the problem in the RPS test circuit since August, 1958. The
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inspector concluced that control of trouble-report identification for
this item was inacequate, and a work brief prior to conducting the
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surveillance procedure snould have identified the known discrepancy.
t Inspector review has concurred with the licensee conclusion that RPS l
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operability was not affected. When icoking at the basis for the shift superviscr's decision, it can be said it was reasonable given the f acts available, and it was ultimately proven acceptable when the t
issue had the benefit of full review by management on the same day of occurrence.
The inspector concluded a difference of opinion exists between the alleger and the shift supervisor. The inspecter considered that the shift supervisor decision, to continue testing and resolve the significance of the anomaly after the test was
completed, was acceptable. This item is closed.
9.3 Followup on Previous Allecations l
f On October 31, the NRC issued special allegation inspection report 50-336/e9-13 for Millstone 2.
As a result of the inspection, five violations were identified which dealt with 1) multiple examples of
failures to follow procedures, 2) lack of seismic documentation for
an electric conduit run, 3) technicians using outdtted drawings, 4)
failure to functionally test a radiation monitor alarm, and 5)
improper control of overtime. Nore of the violations, either singularly or collectively represented a major safety issue. The i
inspectors will review licensee actions in response to the special i
inspection report during future routine inspections.
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10.0 Manacement Meetinos Periodic meetings were held with station management to discuss inspection findings during the inspection period. A summary of findings was also
discussed at the conclusion of the inspection. No proprietary information
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was covered within the scope of the inspection. No written material was
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given to the licensee during the inspection period.
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IDENTIFICATION Number: SP 7401D Rev. 2
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Title:
FEACTOR PROTECTION SYSTEM MATRIX LOGIC AND TRIP PATH RELAY TEST Prepared By-him Ritchie / Vernal Wrighg g
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REVIEtV
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I have reviewed the above procedure and have found it to be satisfactory.
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TITil S1GNATURE DATE DEPARTMENT HEAD
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SPECIFl.C UNREVIEWED S AFETY OUESTION EVALUATION REOUIRED:
Modifies intent of procedure and changes operation of systegu as described in design documents.
YES [ ]
NO l tL -
(if yes, perform written USQ determination and Safety
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Evaluation, and contact Manager, Safety Analysis Branch to determine need for Integrated Safety Evaluation.)
ENVIRON %1 ENTAL REVIEW REOUIRED f
(Adverse environmental impact)
YES [ l NO D.
SPECIFIC S AFETY EVALUATION FEOUIRED Affects response of safety systems. performance of s3 stems which may have been credited in the safety analysis or non-credited systems which may indirectly affect safety system response.
YESl ]
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(lf yes, perform written Safety Evaluation and contact Manager, Safety Analysis Branch to determine need for Integrated Safety Evaluaticn.)
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INTEGR ATED S AFETY EVALUATION REOUIRED YESl }
NO l t F.
PROCEDURE REOUIRES PORC/SORC REVIE 'l (in addition to review, items with a YES response must be documented in the PORCWmeeting minutes.)
YES [d NO l l
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PORC/SORC APPROVAL PORC/M leeting Number
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APPROVAL AND (MPLEMENTATION The attached procedure is hereby approved, and effective on the date below:
W.o O lfl.LMP-
? El bf Stao sn/ Service 9 Unit Superintendent E11ective Date SF303/9/s/SES/87-12/lof1
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sP ;4Jiu Page 1 Rev.9
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UNIT 2 REACTOR PROTECTION SYSTEM MATRIX LOGIC
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AND TRIP PATH RELAY TEST PAGE NQ EFF.REV.
1-13
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1.
OBJECTIVE 1.1.
To verify the operation of the Reactor Protection System (RPS) Matrix
Relay Logic.
1.2.
To verify the operatioHfWe~ ReactorTrip BFeWers (TCB's) on a trip
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signal for each two (2) of the four (4) RPS Channel Combinations.
2.
ACCEPTANCE CRITER_IA 2.1.
As specified on I&C Form 2401D-1.
3.
REFERENCES 3.1.
Technical Specifications 3.1.1.
Surveillance Requirements 3.1.1.1.
Table 4.3-1 (Reactor Proactive Instrumentation) ltem 13 & 14.
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3.1.2.
Limiting Cendition for Operation (LCO)
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3.1.2.1.
NONE
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3.2.
Final Safety Analysis Report (FSAR)
3.2.1.
Paragraph 7.2.3.2.2 (Logic)
3.2.2.
Paragraph 7.2.4 (Testing)
4.
PREREOUISITES 4.1.
The Shift Supervisor (SS) cr the Supervisory Control Operator (SCO) has authorized the test and has signed 1&C Form 2401D-1.
4.2.
Reactor Protection System is in normal operadon.
4.3.
Plant conditions should be at a steady state with no step change anticipated.
4.4.
Four Reactor Coolant pumps must be in operation if power is to be applied to the CEDM's.
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4.5.
All channels should be free from Trips and Pre-trips. If not, annotate
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reason for such on ]&C Form 240]D-1.
,b.6.
In the 14'6" West DC Switchgear Room insure that the four UV Test switches located in the Reactor Trip switch gear cubicles OO3A B, C. and
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D are in the NORMAL position.
4.7.
Contact Electrical Maintenance and Inform them that it will be necessary to establish communication with them to locally close the TCB's as directed by. Operations / I&C Department personnel.
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5.
PRECAUTIONS q.....,........._.....................................s D
C A U TIO N
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s This procedure constitutes HIGH RISK testing and must be
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cleared by the Shift Supervisor (SS).
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5.1.
If a pre-trip or trip occurs on any other than the channel under test, return system to normal.
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5.2.
At no time, may Reactor Trip breakers be reset if TCB-9 is OPEN.
5.3.
If at any time during the procedure an abnormal indication is received, secure testing until the indication is explained / resolved.
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6.
PROCEDliRE
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C A U TIO N s
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During the following test, the Reactor Prctection System Logic is
tested for proper operation. This Logic blatrix test will, at various
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times, place the RPS in a Half-Tripped condition, s..............,....
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6.1.
PERFORhl a lamp test on the RPS Trip Status Panel by DEPRESSING each TCB status indicator and VERIFYING the lamp lights. REPLACE light Bulbs as Required to obtain a satisfactory tamp test.
6.2.
VERIFY that TCB-9 is CLOSED.
6.3.
VERIFY that all Channel Trip Select and hiatrix Relay Trip Select switches are in the OFF position.
64.
DEPRESS the Test Power ON pushbutton to energize the RPS Test Power Supply.
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NOTE:
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Satisfactory completion of Steps 6.5., 6.6., 6.7., and 6.16. may be
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denoted by writing SAT in the As Found and As Left columns on
.iC Form 2401D-1. Other than satisfactory performance may be
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denoted by writing UNSAT in the columns.
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SP 2401D Pace 4
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6.5.
VERIFY the integrity of the Matrix Relay Hold circuit:
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C A U TIO N I
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The Matrix Relay Hold pushbutton must be DEPRESSED and
HELD during the completion of the following steps. The
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pushbutton may be RELEASED only when the Matrix Relay Trip
q Select switch is in the OFF or intermediate positions.
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Assssssssssssssssssss,ssss~sssssssssssssssssss,sssssss0 6.5.1.
DEPRESS and HOLD the Matrix Relay Hok' pushbutton on the AB Matrix Test Module and VERIFY that the 4 Hold lights are ON. RECORD results en 1&C Form 2401D-1.
6.5.2.
SELECT position 1 on Matrix Relay Trip Selector switch of the AB [
Matrix test module, and VERIFY #1 Hold light is OFF; #2, 3, and 4 Hold lights are ON. RECORD results on I&C Forn' 2401D-1.
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SELECT the intermediate position (between 1 and 2) on Matrix l
Relay Trip Selector switch of the AB h! atrix test module, anci l
VERIFY that all Reactor Trip Brcakers remain CLOSED and that all Hold lights are ON. RECORD results on 1&C Form 2401D-1.
6.5.4.
SELECT position 2 on Matrix Relay Trip Selector switch of the AB [
Matrix test module, and YERIFY #2 Hold light is OFF; #1, 3, and g 4 Hold lights are ON. RECORD results on 1&C Form 2401D-1.
6.5.5.
SELECT the intermediate position (between 2 and 3) on Matrix l
Relay Trip Selector switch of the AB Matrix test module, and
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VERIFY that all Reactor Trip Breakers remain CLOSED and that all Hold lights are ON. RECORD results on 1&C Form 2401D-1 6.5.6.
SELECT position 3 on Matrix Relay Trip Selector switch of the AB g Matrix test module, and VERIFY #3 Hold light i: OFF; #1, 2, and g 4 Hold lights are ON. RECORD results on l&C Form 2401D-1.
6.5.7.
SELECT the intermediate position (between 3 and 4) on Matrix
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Relay Trip Selector switch of the AB Matrix test module, and g
VERIFY that all Reactor Trip Breakers remain CLOSED and that all Hold lights are ON. RECORD results on 1&C Form 2401D-1.
6.5.8.
SELECT position 4 on the Matrix Relay Trip Selector switch of the [
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AB Matrix test module, and VERIFY #4 Hold light is OFF; #1, 2. [
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and 3 Hold lights are ON. RECORD results on 1&C Form 2401D-1.
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6.5.9.
SELECT the OFF position on the Matrix Relay Trip Selector switch of the AB Matrix test module, and VERIFY that all Reactor Trip Breakers remain CLOSED and that all Hold lights are ON.
6.5.10. RELEASE the Matrix Relay Hold pushbutton.
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6.6.
Verify the integrity of the Matrix Relay Ladder and Matrix Relays p m s m m m s m m m x m m m m m u m m s m g-CAUTlON
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The Matrix Relay Hold pushbutton must be DEPRESSED and
HELD during the completion of the following steps. The
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pushbutton may be RELEASED only when the Channel Trip s
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Select switch is in the OFF position.
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6.6.1.
DEPRESS AND HOLD the Natrix Relay Hold pushbutton.
6.6.2.
SELECT each position (1 thru 9) of the Channel Trip Select switch of the AB Matrix, and VERIFY that in each position the AB Matrix white lights (AB-1, AB-2, AB-3, and AB-4) are OFF and that the appropriate bistable trip lights (as indicated on data sheet)
are ON. RECORD results on 1&C Form 2401D-1.
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SELECT position 10 of the Channel Trip Select switch of the AB Matrix, and VERIFY that the AB Matrix white lights (AB-1, AB-2.
AB-3, and AB-4) are ON. RECORD results on 11C Form 2401D-1.
6.6.4.
SELECT position 11 on the Channel Trip Select switch of the AB Matrix, and VERIFY that the AB Matrix white lights (AB-1, AB-2, AB-3, and AB-4) are OFF and that the appropriate bistr.ble trip lights (as indicated on the data sheet) are ON. RECORD results on I&C Form 2401D-1.
6.6.5.
SELECT positions 12,13, and OFF on the Channel Trip Select switch of the AB Matrix, and VERIFY that in each position the AB Matrix white lights (AB-1, AB-2, AB-3, and AB-4) are ON.
RECORD results on 1&C Form 2401D-1.
6.6.6.
RELEASE the Matrix Relay Hold pushbutton.
6.7.
REPEAT Steps 6.5. and 6.6. fer the AC, AD, BC, BD, and CD Matrix Test Modules.
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MATRIX LOGIC & TRIP PATH RELAY TEST l
SURVEILLANCE COVER SHEET
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FCRM APPROVED
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DATE PAGE
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OF 17 j
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REFERENCE SPEC.
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REFE AENCE PROCEDURE rgC dr j.,,n MG40. E 2-69-/5)
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o-i nems 43 r..d i4 SP 24010
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SCHEDULE DATE V
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APPLICABLE MODE 5RE QUENCY
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1, 2. and Note !
MONTHLY. START-UP (Note 21
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TEST AUTHOAt2ED BY DATE i
,33,3 ACCEPTANCE CRITERIA MET:
COMPLETED By CATE ACCEPTED By DATE YES ($$1 ApPAovEO BY (DEPARTMENT NEAD)
CATE NO
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r O TECH SPEC MAINTENANCE SYSTEM NON-TECH SPEC i
SURVE1LLANCE RESTORATION AltGNM ENT SURVEILLANCE ISI TESTING l
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TEST EOUIPMENT l
OA NUMBER CAL DUE DATE L
None N/A N/A i
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i ACCEPTANCE CRITERIA
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As specified on data sheets, pages 2-15 i
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i IN ACCCROANCE WITH PEFEAENCE FROCEDUAE INITIALS 1.
FPEREQUISITES/ INITIAL CONDITIONS COMPLETED 2.
PP.ECAUTIONS NOTED 3.
COMMENTS: (;F MA!NTENANCE FESTORATICN. ANDICATE BELOW WORK ORDER e. ETC.)
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Note 1: Reactor Trip Breakers are closed.
Note 2: If not performed in previous 7 days.
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4.l DATA
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NOTE: Sakisfactory completion of steps 6.5, 6.6. 6.7, and 6.16 rnay be denoted by uriting SAT in the As
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Found ar.d As Left columns. Other than satisfactory perforrnance may be denoted by writing UNSAT in the
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columns.
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l; I&C Form 2401D-1
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Step 4:5J/ 6.14.
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DESIRED IND1CATlON '///////////////hh/W/Oh
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RELAY TRIP SELECT STEP 4 MATRIX AB SWITCH POSITIONS HOLD LIGHTS AS FOUND AS LEFT
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6.5.1/6.14 Off All On
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6.5.2/6.14
- 1 Off 2. 3 & 4 On f
i 6.5.3/6.14 between 1 & 2 All On-l 6.5.4/6.I4
- 2 Off.1. 3. & 4 On
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6.5.5/6.14 between 2&3 All On l
6.5.6/6.I4
- 3 Off.1. 2 & 4 On (
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l 1&C Form 2401D-1 j
Rev.6
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Pace 2 of 17
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k UNITED STATES
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NUCLEAR REGULATORY COMMISSION a
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W ASMiGUGTON. D. C. a0555
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ACKNOWLEDGMENT
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ibis acknowledges receipt of your recent Freedom of Information Act (FOIA) request. The F0IA number which it has been assigned and the date it was received by this office are noted on the face of your request, a copy of which is enclosed.
We have also enclosed a notice about fees that shows NRC's evaluation of your request with regard to assessment of fees. The notice pertains to the present F0IA fee structure (5 U.S.C. 552(a)(4)) and NRC's regulations
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at 10 CFR Part 9 (52 Fed. Reg. 49350).
If a notice about fees requires no action by you, the NRC will respond to your request as soon as possible. However, because of the existing backlog.
of cases and the titre needed to search for records subject to your request, there may be some delay in our response.
If you have any questions about the status of your request, you may telephone the staff member whose nama and telephone number are identified below.
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FDIA-90-277 Natalie Brown j
(301) 492-4095 i
Sincerely
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P Lind L. Robins n, Chief FOIA/LPDR Branch Division of Freedom of Information and Publications Services Office of Administration and Pesources Management Enclosures: As stated in!:'m2Sa in this reca:d vias Mied
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in 2::::fn:2 wdh the feedom of 'nismation
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NRC f oRM Sog U.S. NUCLE AR RECULATORY COMMIS$10N REQUEST NUMBER A>>.o.g o av oug 13 Init
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FEES FOR DATE
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FREEDOM OF INFORMATION ACT (FOIA) REQUEST b2 Nh RECi U % T f y4}~.' M
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Pursuant to the W. J b.o n. :ottaH41. and the NRC's regulations.10 CF R 9.33. 52 FR 49350. your FOIA request has been evalust J for proper categorization for payment of fees. as noted below,if the NRC estimates that fees will exceed $25.00,the NRC will prodde a statement of estimated fees in the comments section of th's form or by a separate notice that will be sent to you as soon as possible, unless your FOI A request states your willingness to pay fees as high as estimated.
A request for recorcs for a commercial use, w hicri requires the payment oi costs for search. revievv, and duplication cf records which are responsive to your request.
A request for records for a noncommercial use by a representative of the neas media, an educational or noncommercial scientific institution, er a,n indiddual who requests under the Privacy Act and the FOlA records on the indwidualin a Privacy Act system of records, which reovires the payment of costs f or the dup!ication of records responsive to your request that exceed 100 pages.
A reasest for records for a noncommercial use, whtch recuires the payment rr tuh h search for records responsive to your request that exceeds two hours and for duptcation of c:sclosed records whict. ncW,CO pages.
Based on information in voer request, the NRC categori:ed the request as noted above. If you disagree with the noted utegorizat,on. Please telephore, w; thin five days from the date of th s notice, the NRC employee whose name and telephone r. umber appear on the acknowledgment ietter to notif y the NRC of your disagreement with the categorization Ficase provide a written emp;anation cf your intenced vse of the 'ecorcs with.n 20 cays from the date of this notice. If you do not tele.
phone the NRC employee within fae dan, se N7C will presume that you gee with the noted categorization and will process your request in accordance w.th that categorization. If you disagree but do not provide a written explanation within 20 cays t om the date of this notice the NRC will presume you have r:o further interest in the records and wi!! close the fHe on your FOl A request. You may submit a new request wi'h the necessary explanation in the future.
Your FOl A request cannot be categorszed for payment of fees because you ha6e not provided a sufficient emplanation of your intended use of the requested recorcs. Flease proude a written explanation of your intended use of the records within 20 days f rom the date of this notice if the N RC does not receive a written explanation with.n that time.the NRC will presurae that you have no further interest in the retords and wi!! close the file on your request. You may submit a new FOI A recuest with the recessary explanation in tne future.
CO WiENTS SIGNAT - E - CHIE F, F
.PDR BR ANCH
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U s_ D,ucil&& SEGJL ATOPY roMbi'ssioN W As**lWToN Dc 20!.% ANo To THE PAP [PWoDH RioUCTloN
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f DESCRIPI]ON OF ALLEGATION:
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1. Procedare SP 2406A, " Water Qaality Monitor (WQM)
Functional Test, Revision 3 i:ple:ents a conthly surveillance to satisfy the National Pollutica Discharge Elimination System (NFDES) requirements for intake, discharge, and quarry cut te:perature licitations.
On Septe:ber 16, 1990 the alleger docu:.ented an internal three-way cesorandum to the IC depe.rtment head. The alleger g
ncted that there were no graduations between cajor te=rerature points on the monitor recorder.
(The graduatione were 9 degrees F.) The data eheet SP 2406A-1 calls fer a +/- 1 P determination by the IC technician on The alleger peinted cut then, that it the recorder cutput.
appeared no basis for the 0.1 degree F reeolutien requirrent fcr the terperature detectct, since the reccrder output is every 9 degrees F.
The IC departzent head recycr.ded to the three-way remerandu i
l It was determined to install new reccrder in the en 9/20.
Mt! upgrade that is echedaled for the next operating echedule (11/90 - 3/92).
Durir.g the week of 4/7/e1. snother IC technician "
The f~'""Rwas charge in revising Sp 2406A (To revision 4).
3ec}dician was incorporatir.g cc:= ente into the revisicn.
(Q@%noted the ea e ierce that the alleger raised in l
September,1990 in that the te:Perature gradient expected technicians to record was not practicable.
In resicnee to l
this,IBx Minitiated a reccrder ecale with one degree
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increments to be incorporate into the procedure. The
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procedaral revision has not been approved as of receipt of Q
this concern.
ALLEGER'S MCERN:
SP 24C6A is a conthly functional test.
kE No action by the licensee was taken in the chcrt term to
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a F l correct the alleger's concern, and as such the curveillance U
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has been acco:plished apprcximately six (6) tires without The alleter pointed out that NNECo 3$ lj actions in this regard are typical to poet issues.
Eg rk licensee reepense.
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TIMELY action, not No ACTION at all by NNECo. The E 5.8 '
345 procedural surveillance to coet co=pliance wi*,h NPDES
}I$g It requirements, not technical epecification requirements.
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zay be noted that technicians should net be asked to ny94 document on the curveillar.ee data sheet te:perature within
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ene deErce when einer gradaaticra on the recorder are nine degree s.
Specifically, the technician incerte a calibrated temperature detecter (within 0.1 degree F) into the water at
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the intele, discharge, quarry cut, and re. cords the value.
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This reading is co: pared to the desired value
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detemine with the calibrated temperature sensor.
reading.
This concern appears to be that of useability of theThe inspec
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concern, since it does not affect requirements of techn ca surveillance.,
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f NNECo epecifications, only the potential unti=ely action o Z
to address a monitor functional surveillance for the WNo
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review of the procedare, determined that the functionality
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monitor.
and operation of the monitor is not jeopardized without
addressal of this issue.
2. The alleger told the inspector, that he was going to call 0*]
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The purpose of the'
the regional administrator (Regien I).
I call was to infom him that he was dissatisfied withJhi way the NRC dealt with the private meeting af ter th,e.S/IPThe alleger believed 28, 1991.
management meeting on March thisactionbytheNRCinterferedwithefWetive communications and was a actions that iihis eyce was loss f
j In addition, the,al' leger is diepleased with
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of credibility.
the NRC's dealing with past FOJA requests on NNECo's l
The alleger
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responses.to the " chilling effect" letters.
etated that OSHA, and t)s' DOL provided acceptable FOIA requests however, thc4RC does not.
rzed DRP eection chief of the alleger ~a The inspectorJe intention tVeall the regional administratcr on the parpose of the e 11.
INS CIOR REC 0tttENIATION: The inspector has no f(commendation on the issue of P01A within the NRC.
3. The alleger presented an iesce that the retest requirements for authorized work order M2 90 15363 were Specifically, the retest stated that f1cw is ineppropriate.
controlled between 2.5 - 3.5 cfm as verified by fluw In addition, portions of calibration procedare S' 2404AH.
co=plete SP 2404 AG. The authorized work order was to I
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i=plement PDCE MP2-90-032 for the waste gaseous etack
radiation monitor (P&9095).
l The alleger notified his superviecr of the error in the reteet requirements, in that the functional surveillance has nothing to do with the replacement of the flow ewitch for
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The supervisor acknowledged the allegers co:: cents, P& 9095.
and changed the retest requirements not to include the functional eurveillance SP 2404AG. This was to the l
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alleger's eatisfaction.
ALLEGER'S CONCERN: The review process of the plant l
sodification, or the initiation of the authorized work order i
did not identify this error in the retest requirements for P31-9095. The alleger's believes this is a problem.
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eallege/0 de rh contipucit to pr INSPECIOR ASS %'SMDrf@.c(ntro)ofpint fiejtlen DCI with'
Indi. dually, ch e
MP2-90-032 tot)sinspecto.to past/AISEGATIO F L
etings, issues with items Five n present over tv'NNECo.
ce v e ah I'd be withdispos)pontot ismattV,thisi pastpRCdpinions
'cenese.
i tupned over to th b
fly.drogen vJ 4. The alleger presented an issue,on-threcptrol o dring gas accumulation, near and aroun activities.
calibration, or functional surve 21, 1988 when he k
The alleger recapped an issue back on July libration on A
and another technician were perferming the caThe individua h
when air flow was noted coming from t e EM-9095.
valves to the monitor the flow switch The isolation disconnected lines.The calibratien continued when the lot flow This resulted in an explosion from theChemistry initial were shut.
alarm tripped.
radiation monitor cabinet.
found no hydrogen, subeequently the isolation valves were h
At cracked open, and the hydrogen detector pegged hig.
rences card.
this time the alleger autaitted a cafety awa HPES compliant, and changes to the operations and IC procedures were identified.
another technican made a compliant to his supervisor on the control of calibratione/ functional On 11/28/89 i
surveillances with the potential to have a explos vein January,1990 hTS hydrogen mixture present.
In June,1990 an evaluation Assessment Branch was notified.
h libration was documented on this iseue in reference to t e ca
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procedural controls.
25203-26021 sheet 2 of 3 The alleger provided hTSCo drawing to discuss nitrogen purging of the monitor prior to aStep 4.4.2 of SP calit> ration per SP 2404AH revision 2.2404AH identifica In additien, chemistry department The for 8 to 10 minutes.
camples the cabinet and pig internals for hydrogen.
hydrogen concentration is initia11ed in 10 form 2404AH-1.
Procedure SP 2404AH revision 2 does not ALLEGER S 00NCEP.N: provide the necessary detaile to approp In addition,
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purge path, and how to acco:plish this purge.
the functional surveillance SP 2404AG does not mention theT need to sample hydrogen.
detector is removed frons the pig.
In addition, the alleger stated he has previously informed the NRC of this problem in March,1989 and in late 1990.
INSPECIOR ASSISSMDrT: Re-review of the allegation matrix to understand past NRC actions in this regard.
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The Note in procedure SP 2404AH revision 2 just above step i
4.2.2 states referral to fit.2re 9.4 within the procedure, l
25203-26021 sheet 2 for aneletance in i
and NUSCo drawing deterzining potential. purge paths. It appears the alleger
has an identified purge pathway developed, and wants that -
The procedure pathway within the IC calibration procedure.as written,. elec
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It is the. inspector's assesement, that the real issue.within
' I this allegation is not how or how not to purge the monitor
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to minimize the amount of hydrogen potentially accumulated,
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but WHAT VALVES ARE LEAKING TO GET HYDROGEN TO TH j
(either from the waste decay tanke, or from: Millstone Unit 1 i
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stech)
Turn 1: sue over to the licenses for resolution.
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10/12/88 MEMORANDUM FOR:
Ebe C.
McCabe, Chief, Reactor Projects Section 1B, PB 1, DRP FROM:
William J. Raymond, SRI, Millstone 1, 2.& 3, PB 1.
DRP.
SUBJECT:
ALLEGATI ER INFORMATION FROM
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called me at 9:20 a.m.
on 10/11/88 to provide f urther I
f n ormation on previous concerns and to discuss new concerns involving i ssues that were previously addressed wit,h the licensee but were not satisf actorily resolved.
1.
Hydrocen Builduo in Waste Gas Discharoe Header was assigned to perf orm a calibration in 1986 on radiation channel 9095, which monitors the waste gas discharge-
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After isolating the monitor from the header and while-injecting the test radioactive gas, a small hydrogen detonation occurred inside the sample flow path within the instrument cabinet on the -25.ft. el of the auxiliary building.
Although no equipment damage occurred, the occurrence was significant because (1) it demonstrated a hydrogen control problem existed in either unit 2 vent gas header or in the interface with unit 1 on the discharge path to the stack; and (ii) the potential for more adverse consequences exi sted.
The occurrence'was discussed with 1&C supervision and plant management.
Actions were taken to add a caution to the IkC
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calibration procedure and to add a requirement in an operatio s procedure to purge the header ortor_ to the ILC calibrations.
asg ot performed the.RM 9095 calibration since=1986.
does not know if subsequent. detonations have but he f eels that ' the potenti al is still there and that occurre,
the actions to date have not addressed the root cause of the hydrogen buildup / leakage.
2.
SJAE. Radiation Monitor (RM 5099) Non-Reoresentative Samoles brevided f urther inf ormation on thi s i ssue' that was -
first addressed.in my 10/7 memorandum (i tem 2).
concern on'whether the r adiation monitor ' provides representati indication of SJAE radioactivity is based on the repair history The monitor mal f un/c t ons af ter)each plant trip for the monitor.
= g said_ chemistry because the sample. lines flood out.
personnel repeatedly submit trouble reports on the monitor. for
" repair" af ter finding that the moni tor does not show increases in radioactivi ty when i t exists' (due to f uel leaks) as shown by-
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DE CRIPI20N OF ALLEGATION:
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t 1.jProcedure SP 2406A, " Water Quality Monitor (WQM)
@nctional Test, Revision 3 implements a' monthly
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surveillance to eatisfy the National Pollution Discharge Elimination System (NPDES) require ents for intake, j
discharge, and quarry cut temperature limitations.
i On Septe:ber 18, 1990 the alleger documented an internal
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three-way cesorandum to the IC department head. The alleger I
noted that there were no graduations between cajor i
te=perature points on the monitor recorder.
(The t
graduations were 9 degrees F. ) The data eheet SP 2406A-1 calls fer a +/ _11F detemination by the-IC technicien on
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the~ recorder output. The alleger peinted out then, that it
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appeared no basis for the 0.1 degree F resolutien requirment for the teeperature detector, since the recorder output is
e every 9 degrees F.
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The IC depart:ent head respended to the three-way cemorandum
.l on 9/20.
It was detemined to install new reecrder in the i
WQM upgrade that is echeduled for the next operating l
schedule (11/90 - 3/92).
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Dar the week of 4/7/91, another IC technician:
was charge in revising Sp 2406A (To revision 4).
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te ician was incorperating cc::ents into the revision.
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f g'noted the sa:e iesce that the alleger raised in
September,1990 in that the temperature gradient ex;ected j
l techn cie.ns to record was not practicable. In reopense to g j
this, initiated a recorder scale with one degree W !
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increments to incorporats into the procedure. The
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this concern.
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H ALLEGER'S CDNCERN: SP 2406A is a monthly functionel test.
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No action by the licensee was taken in the chort term to t' S j,l l
correct the alleger's concern, and as such the surveillance
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has been acco:plished approximately eix (6) tires without
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licensee reepense. The alleger pointed out that NNECo
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actions in this regard are typical to poet issuer.
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S INSPECIVR ASSESSMENT: The issue hen appeare-to be ene of l
!jy g
TIMElX actica, not No ACTION at all by_ NNECo. The
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y3yg-j procedural surveillance to coet co:pliance with NPDES requirements, not technical epecification requirements.
It i
may be-noted that technicians should not be asked to t
I document on the eurveillance data sheet te=perature within
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one degree when minor graduations on the recorder are nine
degrees. Specifically, the technician incerts a calibrated I
i temperature detector (within 0.1 degree F) into the water at h
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the intake, discharge, quarry cut, e.nd records the value.
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The technician is then directed to record the MF1 recorder
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i This reading is compared to the desired value reading.
determine with the calibrated temperature sensor.
This concern appe$re to be that of useability of the surveillance. The insrector does not consider this a concern, eince it does not affect requiresents of technical epecifications, enly the potential untimely action of NNECo to address a monitor functional surveillance for the MM Notwithstanding, the alleger's concern, inspector sonitor.
review of the procedure, determined that the functionality and operation of the monitor is not jeopardized without addreesal of this issue.
The alleger told the inspector, that he was going to call th7 regional administrator (Regien I). The parpose of the
)
call was to inform him that he was dissatisfied with the way the NRC dealt with the private meeting after the SALP manage =ent meeting on March 28, 1991. The alleger believed i
this action by the NRC interfered with effective cormunications and was a actione that in his eyes was loss of credibility. In addition, the alleger is displeased with
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the NRC's dealing with past FOIA requests on NNECo's-v i
responses to the " chilling effect" letters. The alleger l'!'
stated that OERA, and the IOL provided acceptable FOIA s
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requests however, the NRC does not.
l The inepector informed DRP eeetion chief of the alleger ~e
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intention to call the regional administratcr on the parpose i
of the call.
INSPECIDR RECCttGNDATION: The inspector has no
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y recommendation on the issue of FOIA within the NRC.
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G 3. The alleger presented an issue that the retest requirenents for authorized wcrk order rf2 9015363 were
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inappropriate. Specifically, the retest stated that flow is
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controlled between 2.5 - 3.5 cfm as verified by fluw portions of calibration procedure EP 2404AH.
In addition, complete SP 2404 AG. The authorized work order was to implement PDCE MP2-90-032 for the waste gaseous stack l
radiation monitor (F31-9095).
l l
The alleger notified his euperviser of the error in the l
retect requirements, in that the functional eurveillarzee has I
nothing to do with the replacement of the flow ewit'ch~for
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FRho.
ir.e supeMisor acknowledged the allegers comments, and changed the reteet requirements not to include the l
func11onal'eurveillance SP 2404AG; Thie was to the
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alleger's eatisfaEtion.~ ~
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ALLEGER'S CONCERN: The review procese of the plant modification, or tho' initiation of the authorized work order
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did not identify this error in the retest requirements for l
RF90957Mlegeri belTeves this is a problem.
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INSPECTOR ASSESSMENT: The alleger has centinued to provide
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issues with the control of plant modification FICE
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Individually, each of the
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MP2-90-032 to the inspector.
items have been presented to past ALLEGATION PAi3L cestings, f
In cencert, with j
with dispositien to turn over to NNECo.
past NRC decieiens in this matter, this issue should be turned over to the liceneeo.
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4. The alleger presented an issue on the control of hydrogen
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j/gasaccumulatien,nearandaroundRM-9095during
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cat 6ratl os. or_ functional ~ surveillance ~ activities._
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The alleger recapped an issue back en July 21,1985 when he and another technician were performing the calibration on RM-9095. The individuals were dieconnecting the fittings to the flow ewitch when air flow was noted ce=ing frem the disconnected linen. The isolation valves to the conitor were shut. The calibration continued when the low flow alarm tripped. This resulted in an explosion from the radiation monitor cabinet. Che=istry initially samplid and
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found no hydrogen, subsequently the isolation valves were cracked open, and the hydrogen detector pegged high. At this time the alleger submitted a enfety awarenees card, HPES compliant, and changes to the operations and IC procedures were identified.
On 11/28/89 another technican made a ec= pliant to his supervisor on the centrol of calibrations / functional surveillances with the_. potential to have a explosive hydrogen mixture present.
In January, 1990 NUSGo Radiation Assess:ent Branch was notified.
In June, 1990 an evaluation was documented en this issue in reference to the calibration procedaral controls.
The alleger provided NUSCo drawing 25203-26021 sheet 2 of 3
to discuss nitrogen purging of the monitor prior to a calibration per SP 2404AH revision 2.
Step 4.4.2 of SP 2404AH identifies operation department to purge the monitor for 8 to 10 minutes.
In addition, che=istry department camples the cabinet and pig internals for hydregen. The hydrogen eencentration ie initialled in IC form 2404AH-1.
ALLEGER'S CDNCERN: Procedure SP 2404AH revision 2 does.po_t_
provide the necessary details to appropriate establish the
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In addition, j
peg'e }aD7and how t'ei a'eco:plish this purge.
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the~fuTct'ional survbiMancE'SP 2404AG cces IIot mention the j
need to comple hydrogen. This need maybe necessary when The detector le removed froFthe pig.
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In addition, the alleger stated he has previously informed theNRCofthisprobleminMarch,1989[andinlate1990.
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INSPECIOR ASSESSdstTr: Re-review of the allegation matrix to j
understand past NRC actions in this regar 't o
.
The Note in procedure SP 2404Ni revision 2 Just above step 4.2.2 states referral to ficare 9.4 within.the procedure,
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and NUSCo drawing 25203-26021 cheet 2 for nasistance in determining potential purge pathe. It appears the alleger i
has an identified purge pathway developed, and wants that The procedure pathway within the IC calibration procedstre.
as written, elects the develo ment of a pathway in general
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ter=8.
It is the inspector's aseeeement, that the real issue within
this allegation is not how or how not to purge the raonitor to minimize the amount-of hydrogen potentially accu =alated,
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but W.AT VALVES /H LEAKING TO GET HYDROGEN TO THE MONITOR (either from the waste decay tar.ke, or from Millstene Unit I stack)
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Turn i sue over to the licensee for resolution.
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ALLEGAil0N RECE!PT REPORT
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kr/d 11 j Allegation No. f M l % - O M 7 D(tkI?;11'.lfpM (leave blant)
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Address:
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Name:
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City / State / Zip:_
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Phone:
Confidentiality:
Yes _ _ No i Vas it requested?
Yes _ No was it initially granted?
Yes No Vas it finally grantec by the allegation panel Does a confidentiality agreement need to be sent Yes No ~
to alleger?
Yes No Has a confidentiality agreerent been signed?
Yes _ No Ferro co:umenting why it was granted is attachedb e
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Pesition/ Title:[
bO' 63b bkk5Cof2, Docket No.:
Facility: _
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'OA (A11egatien Sumtnary (brief description of concern (s):
rEadmahcms
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d Needer of Concerns:
h1 A o[4 hoy Eeployee Receiving Allegation: {Tirst two initials and last nar.e)
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I (d) _ Other: Safeguards
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Reactor Type of Regulated Activity (a) _ Vender (e) _
(b) _ P.aterials (Specify)
(c) _
Materials License No. (if applicable):
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e) Entgency Preparedness
_ _((f) Onsite Health and Safety
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Functional Area (s): _ (a) Operations b) Construction
~~((c) Safegcards
[((g)OffsiteHealthandSafety
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_ (d) Transportation h) Other:
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(KRC Region I Fore 207
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Revisea 10/89)
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ker: Loa u c.s rme t.m e..
in accc bacc sign gy, g,eegam cf N.
Act. 0xtmptoas
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jPR12'9116:23 11RC' MILLSTONE OFFICE P02
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ALLEGATION RECE1PT REPORT gf} n > 2 30f.M.
Allegation No. gt-9 - A - o oG 7 t
Date / Tire. k D(t 12 ;lY gg. pg (leave blant)
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Receivec: _
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Address:
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City / State /ZiM_
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Phone:
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Confidentiality:
Yes _ No b l
Was it requested?
Yes _ No Was it initially granted?
Yes No l
Was it finally granted by the allegation panel i
Dees a conficentiality agreement need to be sent Yes No _
te alleger?
Yes No Kas a confidentiality agree ent teen signed?
emo c::amenting hy it was granted is attached?
Yes _ No
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Position / Title:
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$0 '#>3 h dikk5 CAP 1
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Docket No.:
Facility:
t ( A11egatien Semary (brief description of concern (s): h66 dCSCfif,7
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Number of Concerns:
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k1-A 014
$0Y Eeployee Receiving Allegation:
(first two initials and last nameJ~
Sa feguards (d) [ Other:
Reacter Type of Regulatec Activity (a) [ Vender (e)
(b)
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(c) _ Materials (Specify)
Materials License No. (if applicable):
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Functional Ares (s): _ (a) Operations'
(e) Energency Preparedness j
b) Construction f) Onsite Health and Safety-
~~((c) Safeguards
[(((g)OffsiteHealthandSafet
__(d) Transportation h) Other:
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hf r n:.c h :.;r w.. _..,.7
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(NRC Region I Fortn 207 f 2d*Vk ifahranon f
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"Cl 622 DY 7C ~
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FDA_f"b;SR ~/6 2
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V.{
Revisee10/E9)
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DESCRIPI1ON OF ALLEGATION-
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1. Procedure SP 2406A, " Water Qaality Monitor (W Z )
i Functional Test, Revision 3 imple:ents a =enthly i
surveillance to satisfy the National pollution Discharge -
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Elimination System (NPDES) requiremente fer intake,
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discharge, and quarry cut temperature 11 citations.
On September IB, 1990 the alleger documented an internal
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three-way memorandas to the IC department head. The alleger
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noted that there were no graduations between cajor
temperature points on the coniter recerder.
(The
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graduations were 9 degrees F.) - The data eheet SP 2406A-1
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calle for a +/- 1 F determination by the IC technician on l
The alleger peinted out then, that it
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the recorder output.
6ppeared no basie for the 0.1 degree F resolution requirment
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for the terperature detector, since the recorder output is
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every 9 degreee F.
The IC derertzent head reep:nded to the three-way =emerandum
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l It was determined to install new recorder in the on 9/20.
WZ upgrade that le schedaled for the next operating schedole (11/90.- 3/92).
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,,the week of 4/7/91, e.nother IC technicianf
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f Quas charge in revising Sp 2406A (To revieicn 4). The Dr
l tecnnician vae incorporating commente into the revision.
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% noted the same issue that the alleger raised in
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l Eeptember,1990 in that the temperature gradient expected techn cians to record was not practicable.
In respcnee to l
' initiated a recorder ecale with one degrec
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increments to h incorporate into the procedure. The j
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procedural revielen has not been approved as of. receipt of l
this cencern.
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ALLEGER'S CONCERN: SP 2405A is a menthly functional test.
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No action by the licensee was taken in the short tern to i
correct the alleger's conecrn, e.nd as such the surveillance has been acco:plished approximately six (6) times without licensee recponse. The alleger icinted out that NNECo actions in this regard are typical to poet desnes.
.l INSPECTOR ASSESSMENT: The issue here appeere to be ene of l
TIMELY action, not No ACIION at all by NNECo. The
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procedural surveillance to meet ec pliance with NPDES It requirements,-not technical epecification requirements.
may be noted that technicians should not be asked to
document on the curveillance data sheet te=perature within
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one degree when minor gradaations on the recorder are nine degrees. Specifically, the technician inserts a calibrated te:Perature detector (within 0.1 degree F) into the water at i
J the intake, discharge, quarry cut, and records the value.
The technician is then directed to record the KM recorder E.
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This reading is cc pared to the desired value reading.
determine with the calibrated temperature senser.
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This concern appears to be that of useability of the The inspector does not consider this a t
concern, since it does not affect requiremente of technical earveillanee.
specifications, cnly the potential untimely acticn of NNECo to address a monitor functional sarveillance for the WQM l
Notwithstanding, the alleger's concern, inspector review of the procedure, determined that the functionality monitor.
and operation of the monitor ie not jeopardized without
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addressal of this issue.
2. The alleger told the inspecter, that he use going to call The parpose of the the regional ad:inistrator (Regien I).
call was to infern him that he was dissatisfied with the way i
the NRC dealt with the private meeting after the SALP management meeting on March 26, 1991. The alleger believed this action by the NRC interfered with effective
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ccamanications and was a actione that in his eyee was less In addition, the alleger is diepleased with
of credibility.
the NRC's dealing with rest FOIA requests on NNECo's The alleger responses to the " chilling effect" letters.
stated that OERA, and the DOL provided acceptable 101A
requests however, the NRC doec not.
The inspecter infereed DEF eettien chief of the alleger's intention to call the regional adninistratcr on the purpcee
i of the call.
INSPECIOR RECOW.ENDATION: The inspector has no recommendation on the issue cf }DIA within the NRC.
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3. The alleger presented an iesue that the retest
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requirements fcr authorized ucrk crder M2 90 15363 were inappropriate. Specifically, the retest stated that flou is
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controlled between 2.5 - 3.5 cfm as verified by flow portions of calibration procedure SP 2404AH.
In addition, complete SP 2404 AG. The authorized work order was to implement PDCE MP2-90-032 for the vaste gaseous stack
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i radiation moniter (RM-9095).
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The alleger notified his eupervisor of the error in the
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reteet require:ents, in that the functional curveillance has nothing to do with the replacement of the flow ewitch for l
RM-9095. The supervisor acknowledged the allegers comments.
t and changed the retect requirements not to include the i
functional eurveillance SP 2404AG. This was to the alleger's eatisfaction.
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l ALLEGER'S 00NCEEN: The review procese of the plant j
modification, or the initiation of the authorized werk order
did not identify this error in the retest requirements for RM-9095. The alleger's believes this is a problem.
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The alleger hoc continued to provide INSPECIOR ASSESSMENT: issues with the control of plant modification PD Individually, each of the MP2-90-032 to the inspector.
items have been presented to past ALLEGATION PANEL meetings, In cencert, with with dispcsition to turn over to NNECo.
past NRC decisions in this catter, this iscue chould be turned over to the licensee.
4. The alleger presented an issue on the centrol of hydrogen gas accumulation, near ed around RM-9095 during calibration, or functional surveillance activities.
21, 1986 when he The alleger recapped an issue back on July end another technician were performing the calibration en Tne individuals were discennecting the fittings to EM-9095.
when air ficw was noted ec ing from the the flow switch The isolation valven to the =0 niter disconnected linee.
The calibratien continued when the low flow l
were shut.
This resulted in an explosion from the alar = tripped.
Chemistry initially sampled and radiation menitor cabinet.
found no hydrogen, subcequently the isolation valves were At cracked open, and the hydrogen detector pegged high.
this time the alleger submitted a eafety awarences card, HPES cc pliant, and changes to the operatiens and IC
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procedures were identified.
another technican made a cc= pliant to his On 11/28/89 appervisor on the control cf calibrations / functional surveillances with the potential to have a explosive In January,1990 NUSCo Rediation hydrogen mixture present.
In June, 1o90 an evaluation Assess:ent Eranch was notified.
was documented en this iscue in reference to the calibration procedural controls.
The alleger provided NUSGo drawing 25203-26021 sheet 2 of 3 to discuss nitrogen purging of the scnitor prior to a
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calibration per SP 24003 revision 2.
Step 4.4.2 cf SP 2404AH identifies operation department to purge the menitor
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In additien, chemistry department for 8 to 10 =inutes.
The eamples the cabinet and pig internels for hydrogen.
hydrogen concentration it initialled in IC form 240MH-1.
Procedure EP 240&R revision 2 does net
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ALLEGER'S CONCERN:
provide the neccesary deteils to appropriate estebliah the
In eddition, purge path, s.nd how to acco:Plich thic parge.
the functional surveillance SP 2404AG does not cention the need to earple hydrogen. This need saybe necessary when the detector is recoved from the pig.
l In addition, the alleger stated he has previously informed tb, NRC of this problem in March, 1989 and in late 1990.
INSPECTOR ASSESSMENT: Re-review of the allegation matrix to
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understand past NRC actions in this regar..
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APR 12 '91 16: 25-NRC MILLSTONE OFFICE P06 l
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The Note in procedure SP 2404AH revision 2 just above step i
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4.2.2 states referral to ficare 9.4 within the procedore,
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and N'JSCo drawing 25203-26021 sheet 2 for ameistance in determining potential puree patho. It appears the alleger has an identified purge pathway developed, and wants that patheay within the IC calibration procedure. De procedure
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as written, elects the deveJorcent of a pathway in general te r::.o.
that the real issue within It is the intpectcr's aseeec ent, this allegatien is n:t how or how not to purce the coniter
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to cinicize the arount of hydrogen rotentially accumulated, but W.AT VALVES AFI L911NG TO GET HYDROGEN TO THE M]NI7VR
(either from the waste decey tenho, er from Millstone Unit I etech)
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Turn leeue over to the licencee for resolution.
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