IR 05000423/1998001

Insp Rept 50-423/98-01 on 980223-26.Violation Noted.Major Areas Inspected:Emergency Preparedness Program,Plant Support

ML20247D873
Person / Time
Site:	Millstone
Issue date:	05/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247D844	List: IR 05000423/1998001 ML20247D841 ML20247D856
References
50-423-98-01, 50-423-98-1, NUDOCS 9805180129
Download: ML20247D873 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.

50-423 License No.

NPF-49 Report No.

50-423/98-01 Licensee:

Northeast Nuclear Energy Company Facility:

Millstone Nuclear Power Plant, Unit 3 Location:

Niantic, Connecticut Dates:

February 23-26,1990 Inspector:

Nancy T. McNamara, Emergency Preparedness Specialist Approved by:

Gregory C. Smith, Acting Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety l

9805180129 980506

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EXECUTIVE SUMMARY MILLSTONE NUCLEAR POWER STATION Emergency Preparedness Program inspection February 23-26,1998 Inspection Report No. 50-423/98-01 A programmatic breakdown was identified with the Post Accident Sampling System (PASS), in that:

Since 1988, the licensee has not been in compliance with the requirements of the

Unit 3 Technical Specification, Updated Final Safety Analysis Report (UFSAR)

commitments, and the Emergency Plan.

PASS maintenance was found to be ineffective, resulting in continual system

problems and 31 condition reports generated during the period of 1995-1997.

l Emergency and chemistry surveillance test procedures were found to be inadequate.

• Based on observation of the collection of a containment air sample, the licensee did

not meet the 3-hour time requirement in accordance with the UFSAR and NUREG

0737.

PASS procedures and maintenance were inadequate in that the containment sump

portion of the reactor coolant liquid sample module was not operationally tested at least semi-annually to ensure system availability as specified in section 9.3.2.6.4 of the UFSAR.

The failure to maintain an adequate PASS,is a violation. VIOLATION 50-423/98-

01-01)

in addition to the PASS findings:

Inspector Follow-up item (IFl 97-08-01) regarding the potential of over-

classification, was closed based on the recent information submitted by the licensee stating that changes to the their emergency action levels were approved by the Plant Operating Review Committee.

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Report Details IV. Plant Support P8 Miscellaneous Emergency Preparedness (EP) Issues P8.1 Post Accident Samplino System a.

Inspection Scope The inspector reviewed Post Accident Sampling System (PASS) operation procedures, survei!!ance records, condition reports and conducted staff interviews to determine the adequacy of the licensee's PASS prior to facility restart. Also, the inspector observed the collection of an actual PASS containment air sample to verify technician technique, system operability and procedure adequacy.

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Observations and Findinas Millstone Unit 3 Technical Specification (TS) 6.4.8.d, PASS, requires there be a program in place to ensure the capability to obtain and analyze post accident

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samples under accident conditions. The program shall include: "(1) training; (2) procedures; and (3) provision for maintenance of sampling and analysis equipment." The licensee's UFSAR, Section 9.3.2.6, PASS, describes in detail maintenance of the PASS, design bases and testing. In Section 9.3.2.6.4,the licensee committed to test the PASS which includes a primary coolant liquid sample, containment sump liquid from the recirculation sump, and a containment atmosphere sample, semi-annually, at a minimum.

The inspector reviewed the licensee's PASS operability surveillance from 1987 to the present. The records were not complete, therefore, the inspector was not able to determine if the licensee had met testing frequency requirements for the system during the period preceding 1995. Most of the operability surveillance test records indicated numerous problems with the operation of the PASS. Examples include:

(1) instrument tubing and fitting leaks; (2) valve position indication failures; (3) solenoid valves f ailures; (4) inadequate design; (5) inadequate testing procedures; and (6) the licensee has not been able to successfully separate total dissolved gases from the reactor coolant since 1988. In addition, a UFSAR commitment for collecting a PASS sump liquid from the containment recirculation, was deleted from the licensee's chemistry procedure in 1988, which discontinued the sump testing. Finally, PASS instrument calibration frequencies did not meet the j

vendor's specifications in that the instruments were being calibrated every 18 months rather than every 12 months as specified by the vendor, and no analysis or evaluation was performed to support this reduced frequency.

Prior to 1995, electrical engineers were typically given responsibility for the system

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and interviews with staff members indicated that the condition of the system was j

not monitored well due to high engineering staff turnover, lack of expertise and training, and ineffective management oversight. In 1995, the licensee hired a system engineer to have direct oversight of the PASS. Over the course of the past two years,31 condition reports were generated describing vanous problems with i

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the system. However, despite the high number of condition reports, the system engineer did not receive adequate support from management to ensure the system was entirely operational. An internal audit was conducted in late 1997, which stated that " Millstone Unit 3 had failed to maintain an adequate PASS program."

The inspector concluded that prior to that audit, management oversight was not effective in ensuring the system was adequately maintained and operable at all times and that PASS problems continued during chemistry surveillance tests but root cause analyses were not performed.

The inspector reviewed surveillance test procedures and found them to lack

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sufficient detail to provide the technicians with the information needed to successfully acquire a sample. The procedures lacked clarity, procedure steps were left out and, as stated above, a UFSAR commitment was deleted. The licensee collected an actual containment air sample during this inspection. The inspector g

observed that the " routine" surveillance test procedure had to be revised prior to the

'l sample collection and procedure steps were out of order. During the sample collection, valves were noted to be improperly marked and system identification tags could not be distinguished from some of the valve identification tags.

Although a sample was eventually acquired, a radiological analysis due to lack of radiological activity because of plant shutdown, could not be performed. Therefore, the inspector was not able to verify if the sample was adequately collected to determine if the licensee was able to properly measure and assess the contents of the sample. However, given the problems incurred by the licensee during collection of the sample, sample results would not have been reported within the 3-hour time requirement. (NUREG 0737," Clarification of TMI Action Plan Requirements, ll.B.3, PASS Capability") Also, the inspector noted that technician training appeared to be inadequate because the chemistry technicians were not familiar with the procedure.

Under post accident conditions, chemistry technicians would be expected to obtain the samples.

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The licensee is required per their Emergency Plan, Se ction 6, " Emergency Measures," to perform an annual PASS drill. Poor record keeping prevented the inspector from determining if this requirement had been met. However, the chemistry staff stated that when PASS samples were taken, the staff used the surveillance test procedures. The staff could not recall ever using the emergency PASS procedure which outlines sample acquisition, radiological protection, analyses and timeliness under emergency conditions. The EP staff stated that typically during exercises post accident sampling is simulated. The inspector noted that simulation does not adequately demonstrate capability and timeliness.

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Conclusion

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l-Since 1988, the licensee has not been in compliance with the requirements of the Unit 3 TS, UFSAR commitments, and the E-Plan. PASS maintenance was found to

be ineffective, resulting in continual system problems. Emergency and chemistry surveillance test procedures were found to be inadequate. Observation of obtaining a containment air sample did not meet the 3-hour time requirement in accordance to NUREG 0737. PASS procedures and maintenance were inadequate in that the containment sump portion of the reactor coolant liquid sample module was not operationally tested at least semi-annually to ensure system availability as specified in section 9.3.2.6.4 of the UFSAR.

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The failure to maintain an adequate PASS is a violation. (VIOLATION 50-

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245:336:423/98-01-01)

P8.2 (Closed) IFl 97-81-01 - Potential over classification because of Emeroency Classification Levels (EALs) CNB4 and CNB5 I

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During the August 1997 exercise, it was observed that EALs CNB4 and CNB5, as worded, could result in over-classification of an event in which the reactor coolant system barrier was lost, with a moderate amount of core damage, even with the containment barrier intact. During inspection 98-80, this issue was reviewed by the NRC. Inspectors discussed the licensee's proposed changes to these EALs to l

provide clarity. The inspectors concluded that these changes were adequate to prevent over classification of certain events as had occurred during the August 1997 exercise. The issue was not closed pending Plant Operating Review l

Committee (PORC) approval of these changes.

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Since inspection 98-80, the licensee's PORC had reviewed and approved the changes to the two EALs. Documentation of the PORC approval, as well as, documentation of an effectiveness review and safety evaluation screening were

j submitted by the licensee to the inspectors. Based upon assessments made during inspection 98-80 and the subsequently submitted documentation by the licensee,

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l this issue is closed.

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PARTIAL LIST OF PERSONS CONTACTED l

K. Beagle, PASS Engineer, Millstone, Unit 3 T. Blount, Manager, Emergency Planning Services S. Mathis, Chemistry Manager, Millstone, Unit 3 l

J. Watson, Lead Emergency Planning Coordinator, Facilities and Equipment

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INSPECTION PROCEDURE USED l

lP 82701:

Operational Status of the Emergency Preparedness Program t

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ITEMS OPENED, CLOSED AND DISCUSSED Opened 98-01-01 VIO Failure to maintain post accident sampling system operational Closed 98-80-01 URI Failure to maintain post accident sampling system operational 97-81-01 IFl Potential over classification because of EALs CNB4 and CNB5 a

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LIST OF ACRONYMS USED l

l EAL Emergency Action Level

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EP Emergency Preparedness l

PASS Post Accident Sampling System PORC Plant Operating Review Committee TS Technical Specification VIO Violation UFSAR Updated Final Safety Analysis Report b

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