ML20036B321
| ML20036B321 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/08/1992 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20036A053 | List:
|
| References | |
| FOIA-92-162 NUDOCS 9305190122 | |
| Download: ML20036B321 (4) | |
Text
{{#Wiki_filter:f '~ ^ _~. _1_. ~ 1 - - ~ ~~~ ~ - )h ) [ p**%q# e UNITED ST ATES 8 [' 3, ',} NUCLEAR REGULATORY COMMISSION REGloN i r t, 47s ALLEND ALE ROAD o, [ nNo or raussia. etNNSytv4NiA e40sms '.y y s jn e s M I l I I am responding to the concern (s) that you provided to us on June 3,1991, asserting i i there was no I&C technician emergency plan coserage from the morning of May 30th i i through the morning of May 31st at Millstone Unit 2. l f This concern was referred to Northeast Utilities (NU) for their evaluation; attached for your information is the applicable portion of their response. In addition, this concern was inspected by the NRC. The applicable portion of the report, which documents the re i l j that inspection, is attached for your information. Based on our inspection and the response that was received from NU, we hase determined that your concern was not substantiated. { j NU has developed sufficient redundancy in their on-call Station Emergency Organization l (SEO) to support anticipated contineencies. NU has also acquired an Emergency Notific i and Response System (EN&RS) to effectively recall personnel when needed. No one I ndividual is expected to be the only person available to perform an emergency assignment in l the site emergency organizations. Procedures hate been established to obtain replacements or substitutes when the need is identified. These procedures would hate been used by NU if Based on this information, no further your services were required on May 30-31,1991. action is planned by the NRC in this matter, and we consider this concern to be resolved. l We appreciate you informing us of your concerns and feel that we have been responsive. l Should you has e any additional questions regarding these matters, please call me collect l l (215) 337-5225. l SirIcerely, s l J ]. l i</ j' l Edward Wenzinger, Chief' Reactor Projects Branch 4 j I Attachments: (1) NU Response Letter A09699 of September 13,1991 Ossue 128). t t j (2) Excerpts from NRC Inspection Report 50-336/91-23 (Detail 8.0). 1-: J e --
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i f Uf' 0 Docket Nos. 30-245 License Nos. DPR-61 50-336 DPR-65 i NFP-49 i 50-423 i Str. John F. Opeka i Executise Vice President, Nuclear Northeast Nuclear Energy Company P. O. Box 270 Hartford. Connecticut 06141-0270 l t
Dear Str. Opeka:
l
Subject:
Combined Inspection Nos.. 50-245/91-19,50-336/91-23 and 50-423/91-19 On September 23-2S 1991 an announced, safety inspection of your September 26, 1991, emergency preparedness exercise and other emergency preparedness activities was conducted. by $1r. C. Amato and other members of this ofnce. The inspection was conducted at your l 51:llstone Nuclear Power Stat:en, Waterford. Connecticut, and at your offices in Berlin. Co:recticut In addition, the inspection was continued during the period October 7-30, 1991 at the NRC RI of6ce in King of Pruss:2. Pennsylvania to permit esaluation of documentation obtained during the on-site portion of the inspection and to review your corrective actions ( taken m response to the Unusual Event dec!ared as a result of Hurncane Bob. Discussions I of our findings were held by Mr. Amato with your staff at the conclusion of the on site portion of the mspection. l The es.ercise demonstrated the ability of ine Stillstone Station snd Corporate staffs to take timely and adequate protectise measures on behalf of public health and safety. Corporate staff exhibited excellent response to scenario accident conditions. An adequate emergency preparedness program was maintained. and no exercise weaknesses were identified. Although no violations were identified. an unresolved item is discussed in Section 7.4.4 of the enclosed inspection report. i w O '> \\ p/' 1 1 3 .I i (
O DEC 0f 39 Northeast Nuclear Energy Company 2 No reply to this letter is required. Thank you for your cooperation. Sincerely, k' N C s i 1..es H. Jo,ghief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards Enc!osure: Combined Insper::on Report Nos. 50-245/91-19. 50-336 91-:3 and 50-.::3 01-:9 cc w / enc!: l W. Romberg. Vice President. Nuclear Operations D. Nordcuist. Director of Quality Services R. Kacrcn. Manager. Nucleac Licensing S. Scace. Nuclear Station Director H. Haynes. Nuclear Unit Director C. C'ement Nac:er Unit Director G. Garfield. Esqu:re N. Rey o:cs. Esqu;re K. Abraham. PAO C) Public Document Room (PDR) Local Pubhc Documen: Room (LPDR) Nuc! ear Safet* Informanon Center iNSIC) NRC Res:cen* Inspec:or S:a:e of Connecucut I U. S. FEMA-1 l l I l 1 I
l l I e U. S. NUCLEAR REGULATORY COMMISSION l REGION I Report Nos. 50-245/91-19 i 50 336/91-23 $0-423/91-19 Docket Nos. 50-245 t 50-336 50-123 'l License Nos. DPR-61 i i DPR-65 NPI'-49 Licensee: Northeast Nuclear Energy Company P. O. Box 270 l liartford. Connecticut 06101-0270 Facilitt Name: Millstone Nuclear Power Station Inspec::on Conducted: September 23-28. 1991 and October 7-30. 1991 1 i Inspection At: Berlin. Connecticut: Waterford. Connecticut: and King of-Prussia. Penns3 sania 1 t i inspeno:s C. JJ. #-M ,fh/g j C. G. Amato. ErJergency Preparedness date Speciain:. Remn ! D. Dempsey, Resident Inspector, Millstone Point Plant P. Habighorst, Resident Inspector Millstone Point Plant K. Ihnen. Operations Engineer (Examiner). J. Jamison, NRC Contractor i K. Kolaczyk, Resident inspector, Millstone Point Plant l W. Raymond, Senior Resident Inspector, Millstone Point Plant G. Vissing, NRC Licensing Project Manager \\;;:.neJ: f M //[2) E. McCab. tWief. Emercency / date / Preparedness Section. Division of Rndiation Safety and Safeguards 00 svs l 1
~ t x i l 23 i i These drills evolve slowly, and subsequently the Site Area and General Emergency classi0 cations are performed by management at the EOF and not by the cen:ru. rw - l staff. Due to this fact, and the fact that simulator scenarios provide limited .i classi6 cation at higher levels (Site Area Emergency classifications are reached. l General Emergency classincations are not), there is no evidence or documentation that j shift staff is proncient in classification at high levels. This area is unresolved and j will be reviewed in a subsequent inspection (UNR 50-245/91-19-01,50-336/91-23-01 l and 50-423/91-19-01). Based upon the above review, this area of the licensee's program is acceptable. 7.5 Independent Resiews and Audits 10 CFR 50.5 m requires an audit' review every 12 months to determine the effectiveness of the emergency preparedness program. This audit is to be done by i personnel u ho have no direct responsibility for implementation of the emergency preparedness program. The licensee has several documents that reflect th:s - requi ement including nuclear and corporate procedures. as well as Techmcal l Spect5 cation. Admimstrative and Emergency Plan references. At the time of the inspection the audit had not begun. The audit will be performed by l i personnel of the Radiation Protection Section of the Radiological Assessment Branch (RAB). Although these personnel do not have direct responsibility for the emergency + preparecness program. the Branch does. and these personnel are qualifiec membert 0: the Corporate Emergency Response Organization. To date no con 0icts hate been l identined concerning the audits. However, in 1992 the Quality Senices Departmen-l (QSD) will assume responsibility for these audits. The QSD will continue to use l RAB personnel as technical experts. The RAB Manager and the RP Secuon Chief will assign personnel to these functions. This area w til be eviewed in a suosecue~ mspection. Based upon the above review, this portion of the licensee's program ts acceptable. f 8.0 Oncall Procedures and Methodology The licensee has established oncall procedures for the SE O a methodology for calling personnel and a means for testing the system. The inspectors reviewec ) procedures, interviewed personnel and test records to determine if adequa:e ) procedures, training and equipment are in place so the SE O may be activa:ec ann; off normal hours. The licensee has established several policies and procedures to define and control the encall process. NUP-56, " Pay Policies and Practices for Technical Employees' effective 9/1/S5, addresses administrative and craft personnel and covers such topics
24 as no more than 16 consecutive hours on duty personnel are coected to repen for emergency and ovenime, and 6tness for duty applies, including fangue. e.g. anyone called after working overtime may claim they are not 6t for duty due to fangue. Nuclear Engineering and Operations Procedure (NEO) NEO-90-G-292, dated 10/25/90, established policies that make supervisors and managers responsible for the response of individuals on the oncall list. Millstone station maintains two lists, one for emergency response and one for station suppon. Oncall staff may exchange with other staff members either formally or informai:y. Informally this is accomplished by passing on a pager while still maintaining responsibility. Formally this is accomplished by completing a form and transferring the oncall responsibility. Maintenance of the oncall roster is the lead supervisor's or manager's responsibility. However, this practice deviated from the commonality policy stated in the NEO procedure, in that Haddam Neck maintams a smgle oncall list and permits only formal transfer of onca'.! responsibility. The inspector reviewed a draft of "Onca:1 Procedure", EP-a211. Resision 15. This draft document changes responsibility for maintenance of the occall list to the SSNEPC. SE O members will be required to forward changes :o the oncall schedule to the SSNEPC. The procedure continues to maintain the mformal transfer method and assigns responsibilities to seven groups of station staff. Call-ins are accomplished by the use of a recently installed elec::anic system. the Emergency No::6 cation and Response Sys:em (EN&RS). The mspecter obsenec several tes: and exercise uses of this sys:em, which procces bcm scice anc hara copy messages and concluded it is efficient. Pagers are tested caily. with the s!gnal sent from five towers located throughout the NU service tern:ory. Based upon the above review. th:s pon:en of the licensee's ~egr2-is acceptable. 9.0 Licensee Response to Actual Events The inspectors reviewed repons of licensee response to a::ual c'.ents to de: ermine 2f the licensee's actions were consistent with their emergency plan and implementing procedures. Since the last inspection,13 Unusual Events (UEs) were declared. Of these. three were declared at Unit 1, two at Unit 2, seven at Unit 3, and one was a Millstone site declaration. The UEs all were correctly class:5ed ano notifications were timely. With the exception of the site UE. response actions were as expec:ed. The site UE was declared during Hurncane Bob and was not ce-escala:ed until tne next day. During the Hurricane the following events took place. The EOF was powered by the Emergency Diesel Genera:or (EDG). ] i
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p o por 270 3 HARTFORD. CONNECTICt/T 06141 o270 v., mm,.c aw Z I '.O *.7,"a.,"" a neas-moo L 1 2 September 13, 1991 Docket No. 50-336 A09699 RE: Employee Concerns Mr. Charles V. Behl, Director Division of Reactor Projects U. 5. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Behl:
Millstone Nuclear Pover Station, Unit No. 2 RI-91-A-0113N Ve have completed our review of the identified issues concerning activities Station. As requested in your transmittal letter, our at Hillstone does not contain any personal privacy, proprietary, or safeguards this response may be released to response information. The r.aterial contained in Document Room at your discretion. the public and placed in the NRC Public The NRC letter and our response have received controlled and limited on a "need to knov" basis during the preparation of this distribution Additional time in which to respond to these issues was granted 30, 1991. response. by the Staf f in telephone conversations of August 12 and August ISSUE 113N: an operator observed an abnormal indication on the Unit 2 stack radiation monitor (RM 8168). The abnormal indication was no On May 20, 1991, secured and inmediately reinstated variation on the seter. The operators power to the monitor and the zeter response was noted to hau returned. On May 21, operators again observed no variation in the monitor output. A was initiated and the technical specification action trouble report The one day delay is an was entered for an inoperable monitor. of operators falling to promptly initiate a corrective action statement example and f ailing to enter the technical specification action statements request when required. c , -, j r7 e t7 - m( r.oSQ e 1 .+
m i Mr. Charics V. Behl, Direct:r U. 8. Nuclear R:gulatory Commissics A09699/Page 8 September 13, 1991
Response
This assertion is not valid. On May 27, 1991 a trouble report was submitted to the Maintenance department to determine why the RM 8132 sample fan vould not develop proper flow. 14ter that same evening the sample fan was tagged out of service. On May 29, 1991 16C personnel worked on AM 81325, using AVO M2-91-05446, to check the lov flow problem identified on May 27. The " Tagging Required" section of the AVO indicated that a Technical Specification action statement was involved. This entry was made j by the control room operator at the time the AVO vas released. May 29, at 1310 hours, the plant entered Technical Specification action i On statement 3.3.3.10.a. Table 3.3-13, Action 2 for RM 8132 being out of aervice. The plant was logged out of the action statement at 1740 hours that same day. Nothing in the Shift Supervisor's log indicates this was anything other than a planned event. Realizing that one sample pump was out of service for preventive maintenance and that the other might have flov probler.s, it was proper to enter the action statement and trouble-shoot the remaining pump. Ve find no work control deficiency associated with this mainte-nance / trouble-shooting activity. Ve vere not svare that this was an issue of concern prior to receipt of the Staf f's letter. ISSUE 128: On June 1, 1991 a vorker learned that he had been assigned duty as the on-call I&C technician (Unit 2 Emergency plan) for a 24 hour period from the morning of May 30 through the morning of May 31, 1991. The worker was unavare of this assignment on May 29 when he informed his supervisor that he vould not be at vork on May 30 for personal reasons. The worker did not pick up the department radio paging device and no one else vas assigned as his replacement. Lapses in on-call coverage such as this example occur on a routine frequency. Request: Please discuss the validity of the above assertions. If any deficiencies in the on-call coverage for energency planning are identified, please provide us with the corrective actions you have taken to prevent In addition, please assess the frequency and significance with recurrence. respect to safety of lapses in on-call coverage by the Instrument and j Controls and Maintenance technical staffs.
Response
This is a valid concern, of which Northeast Nuclear Energy Company (NNECO) is well avsre. A lapse in on-call coverage for this particular I&C Technician position did occur on May 30, 1991.
- Bovever, three I&C Technicians and three Maintenance Tecimicians, one per unit, are on call at -
any time, l l
Mr. Charlcs F. Behl. Direct;r U. 8. Nuclect Ragulatory Commission A09699/Page 9 Septamber 13, 1991 l On-call schedules are published monthly and cover a period of one sonth and l five days. They are distributed at the end of each month so that the on-call personnel know their assignments for the upcoming month. A person have been made aware of that assigned to be on-call May 30/31 vould by recalving a copy of the on-call list in late April. It is ~ assignsent responsibility of the individual to review the list on a regular basis the to ansure that they pick up a radiopager on their assigned days. Being axcused from work for personal reasons does not automatically release an individual from on-call responsibilities. Emergency Plan Implementation (EPIP) 4211 directs an individual on-call but unable to fulfill Procedure their on-call obligations to arrange for a qualified substitute themselves. An exception to this is if a person calls in sick on the day they are to assume the on-call responsibilities. Then supervision vill assign another individual. If an individual becomes incapacitated or otherwise unable to their on-call responsibilities outside of normal vorking hours, fulfill4211 directs that individual to notify the Millstone Unit No.1 Shif t EPIP Supervisor (SS) vho vill assign the Millstone Unit No.1 Shif t Supervisor Staff Assistant (SSSA) to find a qua14fied relief. The purpose of the on-call Station Esergency Organization (SEO) is to provide augmentation of shift personnel to provide adequate and timely to abnormal and emergency conditions. Any one system has failure response probabilities, e.g., individual pager failure, auto accident or breakdovn during response, etc. In view of this, Millstone Station has developed a l l response in-depth program which provides reasonable assurance that adequate l l SEO staffing is available in a tisely manner. The 1&C and Maintenance Supervisors also supplement the SEO thereby exceeding Emergency Plan requirements. Lapses in on-call coverage for certain technician positions occur more l l frequently than ve consider acceptable from a manage rnt perspective but from a safety perspective. Ve have not had a total lapse in coverage not for any of the Maintenance or IIrc technician positions this year because of our response in-depth approach. If an individual from Millstone Unit No. 2 did not respond to a radiopager message during an emergency, the Millstone Unit No.1 SSSA, upon notification by the Millstone Unit No. 2 SS, vould call that individual at bone using the telephone. If the individual could not be reached or was not able to respond, the Millstone Unit No. 1 SSSA vill contact the next person on the on-call schedule for the same position to determine a-cilability to assume the on-call assignment. If necessary the SSSA vill continue to call until a qualified relief is found. This process limits the significance of any lapses in coverage. NNECO has recently upgraded the Emergency Notification System to l automatically verify the on-call SEO positions that have been notified of i the event (called into the station systes). This enables the on-shift communicators to make back-up calls to alternate SE0 members. emergency Each SEO position has a minimum of five trained staff and most non-manager positions have between ten and twenty. Ve have taken further steps to the on-call assignment to the SEO, dissemination of on-call strengthen l schedules to individuals, and have a traceable means of verification: l i
t Mr. Charl:s V. Behl Direct:r U. 5. Nucicar Regulat:ry Consission 'y A09699/Page 10 September 13, 1991 revision is planned to gPIP 4211 "On Call Procedure *, + 1. A major and strengthening the responsibilities of the IAad Managers clarifying and on-call individuals. l Emergency Plan Coordinator has been assigned 2. The station's for maintaining and monitoring of the on-call schedule. i responsibility 3 A new procedure, gPIP 4617, " Station goergency Organisation Response Drill *, to require a quarterly unannounced activation of l Verification the SEO is under final review. ISSUE 129: June 3,1991, the periodie evolution of refilling the volume control (VCT) level instrument reference leg was performed in accordance with On procedure IC-2428F. During the reference leg fill, a worker noted an tank unexpected increase in VCT level. Because of this unexpected increase, it suspected that the evolution actually drained the VCT reference leg. in the primary l vas l This observation was reported to supervision. Pressure makeup vater supply was checked, and it was discovered that valve 2CH-195 in the supply path was red tagged closed instead of being in the open specified by step 6.2 of procedure IC-2428F. The valve At that position ascheck had been performed by a Plant Equipment Operator. time the PE0 did not perform a hands-on position check of valve 2CH-195 and alignment There was a to notice the red tag indicating the valve was closed. between the work procedure IC-242BF, which required valve 2CH-195 failed conflict to be open, and the requirement to prevent boron dilution during reactor l shutdovn, which required the valve to be closed. Request: Please discuss the validity of the above assertions. If any deficiencies in vork control, attention to detail, or vork procedures are identified, the corrective actions you have taken to prevent provide us with and provide an assessment of the significance of the deficiency please recurrence vith respect to safety. Responses In stating that valve 2CH-195 vas tagged closed, as required to prevent boron dilution during reactor shutdovn, the assertion is accurate. l l with the I&C and Operations personnel involved have determined the valve lineup Interviews l that there was a miscommunication regarding whether or notThe Plant Equ had been completed. told the 1&C technician that the valve lineup had been completed when he was informed that the valve had been found closed. The importance of complete and precise communications is stressed regularly to Millstone Unit No. 2 operators, and examples of intra-and inter-departzental communication shortcomings are used in training and counseling sessions. 1 i ,}}