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{{#Wiki_filter:$ { - L'M4 y.- { ?l3 4fl g Cf V pa trag IC, UNITED STATES "(' iE Qj NUCLEAR REGULATORY COMMISSION ,a; y REGloN I g %,r j' 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 APR 0 21991 Docket Nos. 50-336 File Number RI-91-A-0010 Nonheast Nuclear Energy Company ATTN: Mr. E. J. hiroczka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received information concerning activities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and followup. We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the date of receipt of this letter. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such information shall be contained in a separate attachment which will be withheld from public disclosure. The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91-A-0010 when providing your response. The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public Document room. The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. (' 9303040128 921105 PDR FOIA HUBBARD92-162 PDR
{- A ' Northeast Nuclear Energy Company 2 Your cooperation with us is appreciated. We will gladly discuss any questions you have conceming this information. Sincerely, i LL y Char gs W. hem,I, Director Division of Reactor Projects
Enclosure:
(10 CFR 2.790(a) Information) cc w/o encl: Public Document Room (PDR) local Public Document Room (LPDR) State of Connecticut bec w/ encl: W. Raymond, SRI. Millstone Allegation File. RI.91-A@l0
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f i a r~ J:n .t JfY WGhh. ~ TMITED DJSTRIBUTJObhEOT~FOR PUBLIC-DIS,CLOSOC-ENCLOSURE Issue 1: Some of the steam generator manway sttids are from the training mock-up. There were no quality controls in place at the mock-up and the studs are not suitable to use on the steam generator manways. A non-conformance report (NCR) was written concerning use of the studs, but the work order was closed prior to disposition of the NCR. The sequence of events is prohibited by administrative control procedures. Please discuss the validity of the above assertions. If an NCR was written, please provide a copy of the NCR for our review. If any procedural requirements were violated, please discuss your corrective actions and the significance to safety of the violation (s). f Issue 2: During a recent performance of SP-2402P, it was identified that the bistable for low steam generator pressure on the Reactor Protection Block does not function properly. A modification is underway to correct drift adjustment. A number of other problems with the bistable have been identified but no corrective actions have been taken. l Please discuss the validity of the above assertions. If problems with an RPS bistable have l been identified, please discuss the operability of that channel of the RPS. Please discuss why i identified discrepant conditions, if any, associated with the RPS have not been addressed by j management. l t i Issue 3: Work order M2-90-15362, used to upgrade the flow indication of the containment radiation monitor, RM-8123, was authorized and worked without a tagout. Please discuss the validity of the above assertion. Was there an administrative requirement to have a tagout in place to perform the work and why was this requirement not followed' Please discuss any generic implications. I / I ' LIMITED-DISTRIBUTIONdOTTOidlUBLtCECi OSpR$ [ O s i i
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ALLEGATIONS AND COMPLAINTS - GENERAL RI 121'0.1/1 APPENDIX 4.0 i SAMPLE RECORD OF ALLEGATION PANEL DECISIONS l SITE: ill 5 -1 PANEL ATTENDEES: ALLEGATION NO.: kl 't(-/r'cCro Chairman - (A ! < ss in f '///rh! (Mtg.[2345) Branch Chief - DATE: j PRIORITY: High Medium h I Section Chief (AOC) -- m ~ D - Ml i i bl aal -Dd P l n SAFETY SIGNIFICANCE: Yes 'Nof Unknown Others - t t DDh)SC CONCURRENCE TO CLOSEOUT: CONFIDENTIALITY GRANTED: Yes IkO r (See Allegation Receipt Report) " l IS THEIR A DDL FINDING: Yes No ISCHILLINGEFFECTLETTERWARRJIED:Yes No HAS CHILLING EFFECT LETTER BEE SENT: Yes No i i HAS LICENSEE RESPONDED TO CH LIh EFFECT LETTER: Yes No t i ACTION: 5 pec. J idiid &ueda3 I) bOK ls s 4L '^ hthwNpd kMe4 1 $c ce51 2) O o t i i t Y\\ VD W r!(C O p te (it /)M( 3 h 6e { t h5 \\fk P G t) qn 3 e % C > M uk K L, u an ~w.w/ Mc)<wdn i p% 1 sh % ow L hee e i i i (0- SP-a c G.s>< (2) % sLh (s) kw4; 1 R i NOTES: i (d no, m i :, k. 4,,,4,/.a.(~si 005 hktk (G5%kLJx b~# I t
t A LL E.G AT ION HA N A G E HENT SY STE M ALLEGATION NUMBER - RI-01-A-0010 RUN DATE: 910117 DOCKET / FACILITY / UNIT: 35000336 / MILLSTONE 2 /2 DOCKET / FACILITY / UNIT: / / DOCKET / FACILITY / UNIT: / / 30CKET/ FACILITY / UNIT: / / j ACTIVITY TYPES - REACTOR MATERIAL LICENSES - FUNCTIONAL ARE AS OPERATIONS i DESCRIPTION - 1) DIFFICULTY PERFORMING SURVEILLANCE SP-2001B 2)S/3 STU35 MAY NOT BE D A M AT ERI AL 3)I&C DE PT OV E R T I M E-DIS P A R
- T Y IN i
TPE ATHENT 1 4)!s~ DEPT OVERTIME-DISPARITY IN TREATMENT 2 CONCERNS -
- 5) RPS BLOCK 6) PHOT 0 HELIC TAGOUT.
0 I t LICENSEE EMPLOYEE CON ~IDENT - NO SOURCE l RECE!VED - 710111 3Y - PJ H ABIGHORST / RI (FTS)346-51?O ACTION OFFICE CONTACT - DR MAVEPKAMP t SAFETY SIGNIFICANCE - UNKNOWN LOAPC NOTIFICATION - STATUS - OPEN SCHED COMPLETION - 910315 DATE CLOSED - l ALLEGATION SUBST ANTI ATED - ALLEGER NOTI:!ED - 31 ACTION - OI REPDPT NUMBER - f REM ARKS - ISSUE 1-NOT AN ALLEGATION,CLOSE IN ACK LTR. 2-TURNOVER TO LIC. 3 C 4-NGT AN NRC ISSUE (MSMT/L An0R CONCERN. 5 & e-i TURNOVED T3 L!C. l l t i i SUPPORT OFcICE: RPS-4A, RESIDENTS l ACTION PENDING: ACK LTR TO ALLEGER, TURNOVER TO LICENSEE i DOCUMENTATION: ALLEGER LAST CONTACTED: 910111 (RECEIPT) i
REFERENCE:
KEYWORD: SURVEILLANCE, T AGO UT, DVERTIME,0A ) qjll RECORD CHANGED - 910117 EM7ERED SYSTEM - 910115 CLOSED SYSTEM l V l )' i l
y ec ,!4, ei-ALLEGATIONS AND COMPLAINTS - GENERAL RI 1210.1/1 , ge / j s,,.. !! ( / 5[! ~ [/ APPENDIX 3.1 ALLEGATION RECEIPT REPORT .Mg., t r,,1 2 3/3 3 /'IU Allegation No. RI A-ocW Date/ Time Received: (leave blank) ~ Name:j Address: City / State / Zip:b Phone Confidentiality: Was it requested? Yes No X Was it initially granted? Yes No >C Was it finally granted by the allegation panel Yes No 4 Does a confidentiality agreement need to be sent to alleger? Yes No X Has a confidentiality agreement been signed? Yes No 2 Memo documenting why it was granted is attached? Yes No 4 y' ~ Alleger's q Employer: /t'cgruga 57 A.futfar?z Position /
Title:
j / ExcM u' [v. /Y75 b Occket No.: CC-336 Facility: -(Allegation Summary (brief description of concern (s): PJ)C/ dowo[M CvAit" 0 aM, c4 d-ec uw.ad afb vtwd,J.q' ny' md <g/etigno[Z\\ E esA aut kE I wrrl-m f; m cw n l / r2 e Mr &:w~ -- r d~4cwonnx=,~ cw:d a&wut 5 d 1 v ij 1: Number of Concerns: 2 R.] s v: a. Employee Receiving Allegation: M, HOto DV 2 i!N (first two init1als and last name) % gi b .;Q;I dJ'; Type of Regulated Activity (a) _^ Reactor (d) _ Other: Safeguards (b) ~ Vendor (e) - - 'T,, g (c) _ Materials (Specify) f 5;,,q f E @p. s Materials License No. (if applicable): sam & Functional Area (s): (a) Operations (e) Emergency Preparedness ljj]@ (b) Construction (f) Onsite Health and Safety (c) Safeguards (g Offsite Health and Safety (d) Transportation gh Other: M+~CD DDL (nkwe6. (NRC Region I Form 207 Revised 10/89) A3.1-1
S""*U 215 337 5349 05/28'91 15:31 U. S 14. R. C. FEGIOf 4 1 Kill 001 9 far-90-A tog ftORTHEAST UTILtTtES c.nor.i ome.. s ie.n su i. a.nm, conn.cucm 9 .7
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P.O BOX 27D t 1 = *a.. i.. w. w " HARTFORD. CONNECTICUT 061414270 i L L J I,((',1',*$ E.*7 (203) 665-5000 0 S' e_O \\ t ) April 26, 1991 Docket No. 50-336 A09353 Mr. Charles V. Hehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Hehl:
Hillstone Nuclear Pover Station, Unit No. 2 RI-90-A-106 Ve have completed our review of an allegation concerning activities at Hillstone Unit No. 2 (RI-90-A-106). As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information. The material contained in this response may be released to the public and placed in the NRC Public Document Room at your discretion. The NRC letter and our response have received controlled and 11mited distribution on a "need-to-know" basis during the preparat on of ? + ,I this response. Based upon our request on March 15, 1991, Region I .e personnel extended the due date for this response to April 2f, 1991. ] Additional time vas requested to support the ongoing INP0 evaluation and to, :s ~ for an Enforcement conference held on March 27, 1991 involvingan53 prepare 33 ongoing allegation-related matter. bl 8Q }l % 1ssue r; d:Y N numbers 3 and 5 vere no longer E R In April 1990, CS-137 calibration sources standards traceable to the p 3 Y I available. Old standards vere replaced by new National Bureau of Standards (NBS). Calibrations performed using the old t s ;; may not have been traceable to NBS and, therefore, may have been ;; y standards invalid. A plant incident report should have been prepared to document the.3.;j a i use of the old standards. The use of nontraceable standards vas a problem y y y ,8 that was overlooked by management for a long period of time. g ggg * ..=<u. discuss the validity of the above assertions. If any discrepanefes Pleaseidentified as a result of your review, please discuss any actions that are you have taken or vill take to correct the discrepancies. ~91o S 310b?S w .m m % w Q
215 337 5349 05/28/91 15:32 U.S N.R.C. REGION 1 KIN 002 -Mr. Charles V. Hehl, Director U.S. Nuclear Regulatory Commission A09353/Page 2 April 26, 1991
Background
In April 1990 CS-137 calibration sources numbers 3 and 5 vere removed from service due to the poor physical condition of the sylar coating. The sources have been maintained in Chemistry Department custody but not issued for use due to the above condition. Nev sources vere purchased and placed into service as replacements.
Response
Calibrations performed using the old standards are valid. The~ sources are traceable to National Institute of Standards and Technology through Chemistry Department records. A Plant Incident Report was not required. The sources were traceable and maintained in the possession of the --j)Chemis t ry Department. The issue related to source control has not been " overlooked by management." In fact, the issue related to source documentation control vas identified by the Radiological Assessment Branch (RAB) program and procedure reviev which took place in 1990. As a result of the reviev, a new Administrative Control Procedure ACP-0A-4.12,
- Radioactive Source Inventory and Control," has been issued to address the 4
recommendations of the RAB report. our reviev and evaluation, ve find that none of these issues taken After either singularly or collectively present any indication of a compromise of nuclear safety. Ve appreciate the opportunity to respond and explain the basis for our actions. Please contact my staff if there are any further questions on any of these matters. Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY B. J. K#berka 47 Senior Vice President cc: V. J. Raymond, Senior Resident Inspec. tor, Hillstone Unit Hos. 1, 2, and 3 E. C. Venzinger, Chief, Projects Brar.ch No. 4, Region I 8 ,-n- ,-.-m ,a.-- -p
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->C f. 'R' f hk * ** '.} T. .n. 'eie s a general weakness in calibration source traceability and documentation. Some tources used at Millstone for radiation monitor calibrations are not traceable to the Wationat institute of 5tendards and Technology (NIST-formerlythe NBS) and many of the
- 8.."4 Mottrees lack adequate do'cumentation to prove traceability. Vost chilbtation records do
'e (oot document the source used and/at times, an irbitrary, system of source identification As used. -,a ;~ ~; n < c <. . ;..>... r.. u.. ,.vz ; c. r a There are three recomrnendations: Replace non. traceable sourceswith sources traceable to the NIST. "It would be '1. preferable to purchase prepared sources with traceability certification. If sources are prepared on-site, use traceable standards solutions, then calibrate the prepered 40urce on an instro nt which has been calibrated with a traceable source. For sources which are r.:ady traceable, assemble all their documentation in a secure 2 and accessible losation. A source custodian l us described 'in the next recommendation,would facilitate this recommendation. 2. Designate a custodian for all Millstone calibration sources. The custodian would have responsibilityior storing all sources safely, making all sources readily available to users, and mainteining all source clocumentation. A Mllistone source custodian could also help reduce source proliferation and maintain source accountability. The best candidate for source custodian would be the Wealth Physics Services group. If , ^d such an arrangement is not viable at Millstone, it is recommended that each department havine) standard sources (l&C, Chemistry) e,stablish a procedure for source accountability and documentation. P,n!!c ct]Ibf ation procedures as needed to require Identification of the calibration
- 4 suurce. There should be a defined method for source identification so that the calibtation source documentation could be readily retrieved.
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i l' 215 337 5349 i 05'28/91 15:34 U. S IL R.C. REGIO!1 1 Kill 00-1 ,;,CD P!SCR! t' TION U t* ALLt.un i a um t satisfiec with a NU riesponse to the NRC on l ( was not c11' ~26, 1991 anvolvang the traceability of check sources for 'd10 tion monitor calibrations. NU stated that accountablilty and ccocbility of radiation sources st the station ara acc M e, &nd l sources are traceabin to NIST (,fw - 1 chtpistry department T,3 ' j:.%4 pointec out that the NULCo r&diological assesi'ument br ent h
- n N o v e rr.b e r, 1989 utated that a general Heal:nesr, its
.g "Eb M fsport .librotton t.ource tracuability and documentation at Millstone ntEtion Most c61i brat.i cn cracords cc not ar rod 14 tion monitor calsbrations.
- cumont the source used and at times, an arbitrary siysteth of s o u r c t.
fontificataan is used. .LEGATICN The allager's concern tc that NU 15 cocurhentang to the NNU taccurate infc mation based on an internal a s s e s ser.e n t i n 191:!"/. NRC et.tsr to all op.r cn t he choti. nource accountability was sc-nt on May . ~., 1991. ,a elloget essrussed th s matter with the DRP erction c.ha ed on thy 21 . the-o.m.,.nne verlaer witn the DRP branch chiaf. t 4JSFECTDh RECOMMENDATION: Evaluetc tne initial concern, BAE asseunnetnt couits (ettachec) and r e-inspect. the i st.us to dret e rmi ne thu secu* acy f tho in2 tie =1 NU' h retsponee to the NRC. I \\ stated that on Suriday May 19, that r1111 stone 1 1C was aslieh ' wi t h r eE.onnec ti on of 4 - SRM's anc B - 1RM's. TQn reconnectarar ~ f Istated that the ont.i eted cn install ation of e-ring seals. ork uctivity htd to be redche on pay 20 be auue the o ' ings wet e r nat al l ed improperly. t.teted that a MP 1 IC tech (!Nt el er ) ould provide additional i nicr met i on. ( Att6thed i n diagramf. cf tite n*Jtrument tube / gu a de-tubw connections) LLEGAT10lJ: Nu management did not l i st s-n to the technict ents at the regirinang of the work.nett vs ty 11: tnst the technicie.nm WGra usre of he pr cgor installation of the u-rsngs. 1hp technicians wer e tuld to rintinue wsth tnp .l ob by NU managerr.ent. Thw error in o-ring natall eti on al so l ead to acci tional r adit.tl en expouur e not. conci stent. n th ALtW-:6.
- NSFECTOR RECDnMENDaTION: NRC anspection.
! stated that recentl y two other IC technl ci ans at , I. 2 were impl ementing a 41ost
- wa tch modification to t.he EDG tilletone
- loarmwsste tank.
The modif ication was controllod under a FDC6. The
- wdatakhnicians (Ritchie and Hayware) were er. peri encitig iatainer ous ac-bulld wiring vs. drawing errors.
The technici ans were,,grocerring ~ frcwing change notic.es tuCNs). )- y.* l hLLEGATION: The modification package was anacequate striihet' e package Std not identify any of the as-butic drawing errors pridr o initiatten af tho modif ication impl ams ntati ots. N,,
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