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KING OF PRUSSIA. PENNSYLVANIA 19404 MAY 131%L f()
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Dear This letter refers to allegations that you provided to us on April 19,
June 5, and June 22, 1990, alleging: (1) that calibration standards were not traceable to the Nat d
Standards; (2) that the pressurizer spray valve positioner control wiring drawing was
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inaccurate; and (3) that the boronometer wiring drawing needed to be corrected after a) walkdown.
The first issue was referred to the licensee for their review and followup. A copy of the licensee response is attached for your information. The licensee found that the old standards were traceable to the National Institute of Standards and Technology and as such this part of your allegation appears to be unsubstantiated. We intend no further action in this matter.
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Issues (2) and (3) involve drawing inaccuracies that we inspected and discussed in inspection
- /d7 report 50-336/91-08. I have attached the applicable pages of the report for your review.
Your allegations in these cases were substantiated; however, system operation was not affected in either case. Although we intend no further action in these specific matters at this time, we will continue to monitor the licensee's configuration control program for any programmatic deficiencies.
Thankyou for informing us of your concerns.
Sin,ly;
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Edward Wenzinger, hief Reactor Projects Branch 4 Attachments: As stated Informaban in ' -
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f Allegation RI-90-A-0106,0107 closecut J. Stewart G. Kelly i
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April 26, 1991 Docket No. 50-336 A09353 i
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:
Millstone Nuclear Fover Station, Unit No. 2 RI-90-A-106 Ve have completed our review of an allegation concerning activities at Millstone 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 have received controlled and discretion.
The NRC letter and our response limited distribution on a "need-to-know" basis during the preparation of this response.
Based upon our request on March 15, 1991, Region I extended the due date for this response to April 26, 1991.
personnel Additional time was requested to support the ongoing INPO evaluation and to for an Enforcement Conference held on March 27, 1991 involving an prepare ongoing allegation-related matter.
Issue numbers 3 and 5 vere no longer In April 1990, CS-137 calibration sources standards traceable to the available.
Old standards were replaced by new Bureau of Standards (NBS). Calibrations performed using the old National may not have been traceable to NBS and, therefore, may have been standards the incident report should have been prepared to document invalid.
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The use of nontraceable standards was a problem of the old standards.
use that was overlooked by management for a long period of time.
discuss the validity of the above assertions.
If any discrepancies Pleaseidentified as a result of your reviev, please discuss any actions that ate the discrepancies.
you have taken or vill take to correct
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i Mr. Charles V. Behl, 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 mylar coating.
The sources have been maintained in Chemistry Department custody but not issued for use due to the above condition.
New sources were 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 s-urces were traceable and maintained in the possession of the Chemistry Department. The issue related to source control has not been
" overlooked by management."
In fact, the issue related to source documentation control was identified by the Radiological Assessment Branch (RAB) program and procedure reviev vhich 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 recommendations of the RAB report.
our review and evaluation, we 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 COMPAhT t
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E. J. 4t'oczka 47 Senior Vice President V. J. Raymond, Senior Resident Inspector, Hillstone Unit Nos.1, 2, cc:
and 3 E. C. Venzinger, Chief Projects Branch No. 4 Region I 4
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i U.S. NUCLEAR REGULATORY COMMISSION REGION I 1
50-336/90-08 Repon Number:
Docket Number:
50-336 License Number:
DPR-65 Nonheast Nuclear Energy Company Licensee:
Millstone Unit 2 Facility Name:
Inspection I.ocation:
Waterford, Connecticut Inspection Conducted:
March 5 to March 7,1991
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Inspector:
J. S. Stewart, Projectygineer Dath Division of Reactor Projects
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r Approved by:
D&e E. Kelly, C f
Reactor Pr ts Section 4B Inspection Summary: Routine Unannounced Inspection on March 5 thru March 7,1991 (Inspection Repan Number 50-336/9108)
Areas Inspected:
Routine inspection of licensee actions related to concerns provided to the licensee for followup and resolution. 'Ibe inspector reviewed licensee do:uments and discussed activities with plant staff.
==
Conclusions:==
Licensee documents penaining to the closcout of 22 concerns were reviewed by the inspector and dLvnW with plant staff. All of the issues reviewed were closed. Some minor weaknesses in licensee programs were identified that had significance.
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5 3.0 OTHER CONCERNS A number of licensee employee concerns presented to the NRC were given to the licensee Nuclear Concerns Program for review and disposition. Licensee actions in this regard have been reviewed by the inspectors.
(Closed) Configuration Control Discrepancy on NUSCO Drawing 25203-28500 3.1 A configuration control discrepancy was identified on NUSCO drawing 25203-28500, S 198, which is a wiring diagram for the boronometer. The discrepancy was identified supervision during a walkdown of the installation using the system wiring diagram.
completion of AWO M2-90-06407 corrected the drawing. System operation was not i
affected. This item is considered closed (RI-90-A-0107)
(Closed) Configuration Control Discrepancy Identified on NUSCO Drawing 25203 3.2 28500 A configuration control discrepancy was identified on NUSCO drawing 25203-28500, 50A-50D, which is a wiring diagram associated with the pressurizer spray valve positione The discrepancy was identified to unit supervision during a walkdown of the installatio the system wiring diagram. The completion of Drawing Change Request M2-P-llO-9 corrected the drawing. System operation was not affected. This item is considered closed (RI-90 A-0107).
(Closed) Configuration Control Discrepancy Alleged on NUSCO Drawing 25203 3.3 29014 A configuration control discrepancy was alleged on NUSCO drawing 25203-290 which is wiring diagram associated with the hydrogen analyzer panel C86. Drawing Ch M2P-077-90 was submitted to upgrade the drawing but the change, when reviewed by engineering, was determined to be an inappropriate enhancement to an interna drawing. The drawing change request was canceled. Drawing 25203-31116 wa as the drawing appropriate for the requested change and this drawing was found co This item is considered closed (RI-90-A-0107).
(Closed) Configuration Control Discrepancy Identi5ed on NUSOO Drawing 2 3.4 32031 A configuration control discrepancy was identific'd on NUSCO drawing 25203-is a wiring drawing for the "B" and 'C' engineered safety feature area high r=Mado gate alarm circuits. De alarms are provided as waming systems for personn is not shut. In their review of this item, the licensee identified that several high radia
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The NRC Region I has completed its followup to concerns that you brought to our attention 40'7'.e by way of the following memoranda; (1), March 27,1990 to your supervisor, alleging that the high radiation area gate alarm circuits were not properly depicted in the applicable i
drawings; (2), October 19,1989 alleging that the definition of " job supervisor" contained m ACP-QA-2.06A conflicted with that in ACP-QA-2.02C and that the licensee did not take action when notified of the discrepancy; (3), March 15,1990 alleging (a) that a blue tag on i
the turbine building component cooling water pump motor breaker was insufficient for the l
preventative maintenance to be performed, (b) the wrong breaker was tagged in preparation for preventative maintenance on the steam packing exhauster, and (c) that valves were manipulated outside the tagging boundary during maintenance on the instrument air system; dl!
-(4) March 2,1990 stating that a consultant had been contracted to identify electrical Y,p l deficiencies in the maintenance shop; and (5), April 4,1990 to your supervisor, stating that a l
drawing of the hydrogen analyzer power circuit was deficient.
-l With regard to issue (1), we inspected the licensee's handling of your memorandum and found that the licensee determined a general deficiency in high radiation area gate alarm circuit drawings and has commenced action to correct this deficiency. We documented our j
inspection in inspection report 50-336/91-08, Section 3.4 (attached). Your concern was substannated. We intend no further action on this matter.
j We referred your concern decribed in issue (2) to the licensee for their resolution. We then SE I
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inspected the licensee's handling of the concern and documented our effort in inspection 235;f 3$'
report 50-336/91-08, Section 3.7 (attached). Your allegation was substantiated in part, that part being that the discrepancy existed, but the licensee has revised ACP-QA-2.02C to correct i
e r E the inconsistency. We intend no further action in this matter, N9
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With regard to issue (3), we again referred your concerns to the licensee and inspected their h5 l[
followup and resolution of these items. Item a was determined by the licensee to be a proper y f
interplay between operations and the work group involved in the preventative maintenance.
5y Your concern that the breaker should be racked-out for the maintenance may be true, but may afI
.8 E not have been required for the activity to be conducted. The licensee found for item b that y f pb l the tagout used was appropriate for the activity being conducted and your allegation in this case appears to be unsubstantiated. We documented our review ofitems a and b in inspecti report 50-336/91-08, Sections 3.5 and 3.6 (attached). The licensee did not have enough35#e; 0}gR h Q"
e information to make a determination of the validity of item c. Applicable documents related to the maintenance on the instrument air system were reviewed, but the licensee did not find any discrepancies. Please inform us if you have funher information on this issue.
Otherwise, we intend no further actions in these matters.
We understand for issue (4), that the licensee has e program to identify and correct clectrical deficiencies throughout the plant. Part of this program was the load study to which you referred in your memorandum. At the present time, we are satisfied with the licensee's e >
actions in this matter.
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We inspected the licensee's followup of the concern stated in your April 4,1990 memorandum and found that licensee engineering did not consider the drawing upgrade that you proposed to be appropriate. We documented our inspection of this issue in inspection repon 50-336, 91-08, Section 3.3 (attached). We consider this matter closed.
i According to our records, we have completed our activities on all of your technical concerns provided to us prior to 1991. In addition to these issues, you have provided to us numerous allegations of harassment of you by your employer. We are continuing our investigation of these matters and will inform you of the results when we are finished. We again request that you provide your harassment complaints to the Department of Labor for their followup. We will continue to review Department of 1. abor activities in these matters. We appreciate you informing us of your concems and feel that we have been responsive to those concerns. If l
you have any additional questions or if I can be of further assistance, please call me collect (215) 337-5225.
Sincerely;
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g ward Wenzinge, hie Reactor Projects Branch i
Attachments: As stated i
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Allegation File RI-94A-0107, update Allegation File RI-88-A-0003, update only.(B20, B14,B21.1, closcout)
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[0, UNITED STATES j
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NUCLEAR REGULATORY COMMISSION f
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KINO OF PRUSSIA. PENNSYLVANIA 19408 APR 81991 i
I Docket No. 50-336; Nonheast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations P.O. Box 270
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Hanford, Connecticut 06141-0270 i
Gentlemen:
Subject:
Millstone Unit 2 Inspection 91-08 This letter transmits the results of the routine inspection conducted by Mr. J. S. Stewan of this office from March 5 through March 7,1991, at Millstone Nuclear Power Station, f
Unit 2, in Waterford, Connecticut, of activities authorized by NRC License No. DPR-21.
Our findings were discussed with Mr. Keenan and others of your staff at the conclusion 'of the inspection.
The inspection consisted of a review of your responses to concerns referTed to you by the I
NRC and is described in the enclosed NRC Region I inspection report. Your responses to the concerns reviewed were independently determined to be adequate, such that all of the issues inspected are considered closed.
Your cooperation with us is appreciated. No reply to this letter is required.
Sincerely, Mward
- ennnger,
'f Projects ch No. 4 i
Division of Reactor Projects j
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Enclosure:
NRC Region I In>,ection Repon No. 50-336/91-08 I
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t 4-7 Northeast Nuclear Energy Company 2
cc w/ encl:
W. D. Romberg, Vice President, Nuclear Operations R. M. Kacich, Manager, Generation Facilities Licensing J. S. Keenan, Nuclear Unit Director, Millstone Unit 2 Gerald Garfield, Esquire Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Senior Resident Inspector State of Connecticut i
bec w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enclosures)
I DRP Section Chief G. Vissing, PM, NRR J. Wiggins, DRP C. Hehl, DRP I
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U.S. NUCLEAR REGULATORY COMMISSION REGION I i
Report Number:
50-336/90-08 Docket Number:
50-336 License Number:
DPR-65 Licensee:
Northeast Nuclear Energy Company Facility Name:
Millstone Unit 2 Inspection Location:
Waterford, Connecticut Inspection Conducted:
March 5 to March 7,1991
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Inspector:
J. S. Stewart, Projectygineer Dath Division of Reactor Projects i
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i Approved by:
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D&e E. Kelly, C f
Reactor Pr ts Section 4B Inspection Summary: Routine Unannounced Inspection on March 5 thru March 7,1991 (Inspection Report Number 50-336/9108)
Areas Inspected:
Routine inspection of licensee actions related to concerns provided to the licensee for followup and resolution. The inspector reviewed licensee documents and discussed activities with plant staff.
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Conclusions:==
Licensee documents pertaining to the closeout of 22 concems were reviewed by the inWar and discussed with plant staff. All of the i
issues reviewed were closed. Some minor weaknesses in licensee programs were identified that had significance.
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I TABLE OF CONTEhTS i
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1 1.0 PERS ONS CONTACTED..................................
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l 2.0 IN S PECTIO N S COP E....................................
1 2.1 Report Details 2.1.1 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Letter Number A09188, dated January 1
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1, 1991, RI-90-A-0206...........................
2.1.2 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Letter Number A09066, dated I
December 3, 1990, RI A-0136....................
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l 2.1.3 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to i
E. C. Wenzinger (NRC), Letter Number A09076, dated 4
December 7,1990, RI A-0144.....................
2.1.4 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Letter Number A09163, dated Ic i
i December 21, 1990, RI A-0180....................
5 2.1.5 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to e
j E. C. Wenzinger (NRC), Letter Number A09166, dated l
December 21, 1990, RI-90-A-0204....................
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2.1.6 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to l
E. C. Wen 2inger (NRC), Letter Number A09187, dated January 5
l 4, 1991, RI A-0205...........................
2.1.7 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to j
E. C. Wenzinger (NRC), Letter Number A09166, dated January
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5 21,1991, RI-90-A-0208.
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3.0 OTHER CONCERNS....................................
l 3.1 (Closed) Configuration Control Discrepancy on NUSCO Drawing 6
l 25203-28500.....................................
l 3.2 (Closed) Configuration Control Discrepancy Identified on NUSCO 6
Drawing 25 203 -2 85 00................................
3.3 (Closed) Configuration Control Discrepancy Alleged on NUSCO 6
Drawing 25203-29014.................................
l 3.4 (Closed) Configuration Control Discrepancy Identified on NUSCO 6
Drawing 25203-32031................................
l Tagout Discrepancy Identified During the Preparations for Authorized 3.5 7
Work Order AWO-M2-89-02320.........................
3.6 Tagout Discrepancy Identified During Preparation for Work Order 7
i AWO-M2 10757.................................
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3.7 (Closed) Concern Regarding Definition of " Job Supervisor *.........
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4.0 MANAGEMENT MEETING................................
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DETAILS 1.0 PERSONS CONTACTED
- J. Keenan,- Unit Director
- J. Riley, Maintenance Manager J. Becker, Instrument and Controls Manager J. Smith, Operations Manager R. Rowe, Electrical Superintendent
- R. Zisk, Nuclear Safety Concerns Engineer
- J. Criscione, Assistant to Unit Director l
U.S.NRC
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- P. Habighorst, Resident inspector l
- denotes presence at exit meeting conducted March 7,1991 l
l 2.0 INSPECTION SCOPE l
t A number of concems have been provided to the NRC related to activities at Millstone l
Unit 2. The dispositioning of these concems has involved providing the concem to the j
licensee for their review and resolution, with subsequent NRC overview to ensure the adequacy of the licensee's actions.
Seven documents containing the licensee's evaluation of the above concems were inspected.
Eight additional concems had been previously provided to the licensee by the resident inspector, as detailed in Inspection Reports 50-336/90-06 and 50-336/90-14, and these were inspected.
2.1 Report Details t
2.1.1 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E..C. Wenzinger (NRC), Letter Number A09188, dated January 4,1991, RI-90 A-0206 i
Issue 1 involved troubleshooting of the reserve cooling pump for the main turbine-generator j
stator following plant startup. Restoration of the system to a normal status required recalculation of the serpoint for the reserve pump and calibration of the pressure switch. A root cause determination for the improper setpoint included identified procedural wa*Ws and improper procedural implementation by the technician. The ing+ -w aceefthatthe i
procedure has not been upgraded in the limnsee's on-going procedure upgrade program.
Inspection Report 50-336/90-19 reviewed this program and documented the licensee's 1
intention to have all procedures upgraded by 1992. In any case, the problem of being unable j
to secure the reserve stator cooling pump is of minor safety concem because the system was
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2 in operation and the generator stator was being cooled. The inability to secure the resene pump was identified by operations and appropriate corrective action was taken to restore the system to a normal configuration. This issue is considered closed.
Issue 2 involved compliance of the licensee's operational test program with technical specification requirements. The licensee's assessment that tec'mical specifications were complied with is considered adequate and the issue is considered closed.
Issue 3 involved the testing of the alarm associated with control element assembly withdrawal prohibit. The licensee's response that the testing is fully completed by existing procedures was considered adequate and this issue is therefore considered closed.
t 2.1.2 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Letter Number A09066, dated December 3,1990, RI-90-A-0136 j
Issue 1 involved the replacement of the flow control valve (FCV) for radiation monitor RM 8262 and other troubleshooting activities during the June to August 1990 time period. The inspector reviewed a detailed work history associated with the radiation monitor and also reviewed work order M2-90-04311 which was used to control the replacement of the FCV.
l The replacement valve was purchased non-QA and upgraded in accordance with the licensee's commercial grade dedication process by do:umenting the upgrade in a non-conformance report, NCR 290-520. When the replacement valve was taken to the job site, the thread engagement was insufficient to place the component in service. The replacement valve was f
then removed, rethreaded, bench leak tested, and returned to the job site for installation.
l These activities were not recorded in the work authorization. After the valve was installed, the system was returned to service, on June 28,1990, without the completion of the leak check specified in the work order. The leak check was performed on August 8,1990, and the work order was closed. During the perio' from June 28 to August 8, operators verified i
d that the radiation monitor was operational and recorded the flow once per shift except for maintenance periods. Furthermore, the radiation monitor is isolated from the containment on a containment isolation signal making the significance of these occurrences minimal with respect to safety.
The failure to conduct a complete commercial grade dedication inspection including checking thread engagement, failure to document the work required to install the rephmmt valve, and the restoration of the system to service without the completion of the work order are, in combination, considered a licensee identified weakness. Corrective actions included completion of the leak test, closeout of the work order, and discussions with licensee personnel by supervisors concerning the issue. Additionally, the li-is in the process of
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j implementing additional controls to better establish coordination of maintenance activities
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with plant operations. These actions meet the criteria of 10 CFR 2, Appendix C, V.G.1 for l
j the exercise of discretion; that is, the problems were identified and corrected by the licensee and were minor in nature. This item is considered closed (91-08-01).
Issue 2 involved a concern that a bypass jumper tagout had been improperly controlled during 1
maintenance controlled by AWO M2-90-OS033. Review of the AWO reveals that an Instrument and Controls technician initiated a work order to repair a broken pin connector.
When it was determined that the pin in question was not connected to anything the work l
order was canceled. No taggmg was required. This issue is considered closed.
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2.1.3 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger j
(NRC), Letter Number A09076, dated December 7,1990, RI-90-A-0144 l
Issue 1 involved the operation of the steam jet air ejector radiation monitor, RM 5099. The licensee has determined the adequacy of system performance during the periods in question.
The licensee has also stated an intention to replace the radiation monitor with an improved i
design in 1991. This issue is considered closed.
i Issue 2 involved communications between an instrument and controls staff member and the manager at a staff meeting. In the case provided for licensee review, either (1) the employee i
failed to properly communicate the question, (2) the supervisor failed to understand the question, or (3) the employee failed to followup to an incomplete response. This matter is j
1 labor-management in nature and is beyond regulatory concern. Administrative Control Procedure ACP-QA-1.20 provides a mechanism for communication by way of informal correspondence which could have been used to ensure adequate discussion of the issue. This issue to considered closed.
Issue 3 involved the control of work associated with troubleshooting the control circuit for the turbine bypass valves. Work Order M2-9%6498 was authorized on June 17,1990, to investigate a TAVE/ TREF alarm. As a result of the investigation pressure transmitter PT-4300 was found to have drifted and work order M2-90-07792 was written to calibrate the pressure transmitter during the upcoming outage. On September 10,1990, work order M2-90-09684 was written to troubleshoot a decrease in TREF which had caused a TAVE/ TREF alarm. A note on the work order identified the work that had previously been authorized to calibrate the pressure transmitter. De work orders were complete. Dere was no need to maintain a second, redundant tabulation of activities. This issue is considered closed.
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2.1.4 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Ixtter Number A09163, dated December 21,1990, RI-90-A-0180.
The issue involved the management of activities involved in troubleshooting and maintenance of the "A" channel of wide range nuclear instruments during refueling activities. The licensee has prepared a spare wide range drawer which will be installed and tested to determine if the spiking problem is diminished or eliminated. Recent inspection of this issue was documented in Inspection Report 50-336/90-22. This issue is considered closed.
Issue 2 involved the licensee's management of a procedure change. Licensee actions with regard to the concern were adequate and the issue is considered closed.
2.1.5 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wenzinger (NRC), Letter Number A09166, dated December 21,1990, RI-90-A-0204.
The inspector reviewed the licensee conespondence and had no further questions. The issues are considered closed.
2.1.6 (Closed) Licensee Conespondence E. J. Mroczka (NNECO) to E. C. Wenzmger (NRC),12tter Number A09187, dated January 4,1991, RI-90-A-0205.
The issue involved the control of work associated with the overhaul of the PSC service water pump motor. Because the activity involved both electrical and mechanical work groups, a number of station procedures and work orders were used to control the activity. Work Order f
M2-90-13312 was used to disconnect the motor leads, remove the motor, reinstall the motor, and reconnect the motor leads. A weakness in the coordination of activities allowed the pump motor to be removed without having the bearing oil drained. Having the bearings l
covered with oil presented no problems to the work being performed and when the condition l
was identified, the oil was drained to a collection drum. A number of enhancements to the procedures used in the overhaul have been implemented to ensure better coordination of future activities. The inspector notes that the procedures governing overhaul of the condensate and heater drain pump motors were similarly revised to eliminate potential confusion in these related activities. This issue is considered closed.
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2.1.7 (Closed) Licensee Correspondence E. J. Mroczka (NNECO) to E. C. Wmringer (NRC), letter Number A09166, dated January 21,1991,.RI-90 A-0208.
The issue involved a weld made to a moisture separator reheater manway to stop a small steam leak in the gasket. The inspector reviewed the licenw's response and di= W the activities with the engineer involved in the work preparation. The licensee's response is considered to be both complete and adequate. The issue is closed.
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5 3.0 OTHER CONCERNS A number of licensee employee concems presented to the NRC were given to the licensee Nuclear Concerns Program for review and disposition. Licensee actions in this regard have been reviewed by the inspectors.
3.1 (Closed) Configuration Control Discrepancy on NUSCO Dmwing 25203-28500 A configuration control discrepancy was identified on NUSCO drawing 25203-28500, Sheet 198, which is a wiring diagram for the boronometer. The discrepancy was identified to unit supervision during a walkdown of the installation using the system wiring diagram. The completion of AWO M2-90-06407 corrected the drawing. System operation was not affected. This item is considered closed (RI-90-A-0107) 3.2 (Closed) Configuration Control Discrepancy Identified on NUSCO Drawing 25203-28500 A configuration control discrepancy was identified on NUSCO drawing 25203-28500, Sheet 50A-50D, which is a wiring diagram associated with the pressurizer spray valve positioner.
The discrepancy was identified to ur.it supervision during a walkdown of the installation using the system wiring diagram. The completion of Drawing Change Request M2-P-110-90 corrected the drawing. System operation was not affected. This item is considered closed (RI-90-A-0107).
3.3 (Closed) Configuration Control Discrepancy Alleged on NUSCO Drawing 25203-29014 A configuration control discrepancy was alleged on NUSCO drawing 25203-29014, Sheet 9, which is wiring diagram associated with the hydrogen analyzer panel C86. Drawing Change M2P-077-90 was submitted to upgrade the drawing but the change, when reviewed by engineering, was determined to be an inappropriate enhancement to an internal wiring dawing. The drawing change request was canceled. Drawing 25203-31116 was referenced as the drawing appropriate for the requested change and this drawing was found complete.
This item is considered closed (RI-90-A-0107).
3.4 (Closed) Configuration Control Disempancy Identified on NUSCO Drawing 25203-32031 A configuration control discrepancy was identified on NUSCO drawing 25203-32031, which is a wirmg drawing for the "B" and "C" engineered safety feature area high radiation area gate alarm circuits. The alarms are proeided as warning systems for personnel that the gate is not shut. In their review of this item, the licensee identified that several high radiation
4 6
area gate alarm circuits were not covered by drawings and work was initiated to prepare and verify drawings for all of these circuits. The dmwing drafts have been prepared and will be hand over hand verified by June 1991. Final drawing preparations will be completed in 1991. This hem is considered closed (RI-90-A-0107).
3.5 Tagout Discrepancy Identified During the Preparations for Authorized Work Order AWO-M2-894)2320 A tagout discrepancy was identified during the preparations for Authorized Work Order AWO-M2-89-02320, which controlled the annual preventative maintenance on the steam packing exhauster. The item was reviewed by the licensee and it was determined that the tagout was appropriate for the work being performed, although the job supervisor replaced red tags with blue tags before the work was done. This type of change is consistent with station procedure ACP-2.06A, " Station Tagging." The inspector had no further questions on this issue (RI-90-A-0033, B20.2).
3.6 Tagout Discrepancy Identified During Preparation for Work Order AWO-M2 10757 A tagout discrepancy was identified during the preparation for work order AWO-M2 10757, which controlled the preventative maintenance on the "B" turbine building component cooling water motor. This item was reviewed by the licensee and it was determined that the job supervisor, in conjunction with operations, requested that the motor breaker be racked out prior to the maintenance activity. The licensee concluded that tl.e interplay between the work group and operations was in accordance with station procedure ACP-2.06A, " Station Tagging" and therefore was appropriate. The inspector has no further questions on this issue (RI-90-A-0033 B20.1).
3.7 (Closed) Concern Regarding Definition of " Job Supervisor"
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l A concern was raised that the definition of " job supervisor" provided in administrative control procedure, ACP-QA-2.06, " Station Tagging," differed from the definition provided in ACP-QA-2.02C, " Work Orders." The discrepancy had no apparent effects on plant activities and the licensee has revised the latter procedure so that the definitions are identical.
This issue is considered closed (B.14.01).
4.0 MANAGEMENT MEETING At the close of the inspection, a management meeting was held to summarize the inMon results. No written material was given to the licensee and no proprietary information was identified.
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d UNITED STATES j
NUCLEAR REGULATORY COMMISSION r
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a 475 ALLENDALE ROAD KING OF PRUSSIA PENNSYLVANIA 19404 h
4 Ad Docket No. 50-336 Dear This letter is to acknowledge receipt of technical concerns you have provided to the NRC involving the Millstone Nuclear Power Station.
These concerns have been re.frwed and assignee a priority for NRC follow up actions and iinal disposition.
The status of is% ts received since December 14, 1989 is provided in.
Your concerns were screened for safety significance. Some concerns received high priority and inmediate follow uD. Others were assigned for follow ut during routine NRC anspeciton or referred to the licensee. Cor cerns ref erred to the licensee for disposition will te audated and evaluated by the NRC staff to ensure adequacy.
You will be notified of the final NRC action on the issues after those concerns have teen appropriately closed out.
Your cooperation in this matter is appreciated.
Sincere 1y.
[
illiam J. Rays nfx,@
Senior Residen Insp ter Millstone Nuclear Powe,- Station
Reference:
File No. A.37.01, A.44.01.02, A.45.01.02, A.46.01, 3
A.47.01, A.48.01, A.49.01, A.50.1
.4, A.51.01, A.52.1.4
Enclosure:
Status of Flillstone 2 Allegations r
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bec: Allegation Fil W. Raymond' information in this record was dic'.ed D. Haverkamp in at;ordance w.th th Freefo~ 01 !nictmation f
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e DATE OF ALLEGATIONS PRESENT STATUS RECEIPT 12/14/09 Harassment and Intimidation Open Complaint i
03/23/90 (1) Licensee inability to (1) LER 90-002; implement required alternate Documented in IR monitoring capabilities for 50-336/90-11.
RM 8123 A/B; (2) Super-(2) Open vision told a co worker to limit procedure changes.
04/02/90 (1) Calibration deficiency (1) Closed; Documented for RM-6038; (2) Performance IR 50-336/90-06 appraisal evaluation with closecut letter.
discussions considered as (2) Open harassment and 2ntimidation.
04/19/90 Proced2re change for the Open steam iet air ejector radiation monitor.
04/19/90 Calibration SP 2404AM Open source traceability.
06/05/90 Potential configuration Open & E4D-A-DIO7 control for pressurizer spray valve 2-RC-100F, 06/11/90 (1) Loop diagram deficiency Closed; Documented wide range nuclear instru-in IR 50-336/90-11.
mentation; (2) Operability question for nuclear instrumentation; (3)
Appropriateness of non-intent change to Thermal Margin Low Pressure function test; (4)
Adequacy of detector plateau voltage.
06/1B/90 (1) Non-intent vs. Intent Open procedure change; (2) Inade-quate time allotted for procedure review; (3) Legal Activities Constitute Harassment; (4) Potential radiation hazards during containment monitor trouble-l shooting.
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h 06/22/90 (1) nonthly functional Open surve211ance not verifying control element assembly withdrawal proh2 bit; (2)
Potential discrimination for recent New London Day i
Newspaper Article; (3)
- R u_ R O -& O t ) r Inaccurate loop diagram a for boronometer; (4)
Radiological consequence of nay 15 Atmospheric Dump overflow on turbine roof.
06/27/90 Gaseous Radiation nonitor Open Procedure Inadequacies.
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ALLEGATIONS AND COMPLAINTS - GENERAL RI 1210.1/1 I
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Confidentiality:
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Yes No <
Was it initially granted?
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Yes No v
Has a confidentiality agreement been signed?
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Yes No
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Functional Area (s):
v(a) Operations (e) Emergency Preparedness (b) Construction (f) Onsite Health and Safety (c) Safeguards (g) Offsite Health and Safety (d) Transportation (h) Other:
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