ML20036B448
| ML20036B448 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/18/1991 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20036A053 | List:
|
| References | |
| FOIA-92-162 NUDOCS 9305200089 | |
| Download: ML20036B448 (4) | |
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KING oF PRU8tlA. PENNSYLVANIA IN04 Docket No. 50-336 N28E File No. RI 58 A-0040 The NRC Region I office has completed its review of concerns that you brought to our attention on January 25,1990, regarding Millstone 2 control of radiation monitoring alarms. In particular, you alleged that: 1) operations did not follow pfzedert,s for cont of of radiation monitor keys on January 24 and 25; and,2) operations were leaving local SJAE radiation monitoring horns in diny' pass condition while these monitors were in service. Our resolutions of these concerns
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are as follows.
Your concerns were addressed in the special team inspection, IR 89 13, issued October 11,1989.
l The two issues, found to be substandated, were combined into a single unremlved item (50-336/89-1313) to be resolved by 6e licensee. A follow up inspection by the resident inspectors found that Station Procedures OP-2383A and Op-2383B were revised to require special controls of alarm bypassing. This inspection. IR 50-336/90-11, issued August 1,1990, closed Open Item 50-336/89-13-13 and, therefore, your concerns on this subject. The pertinent pages of these i
reports are enclosed.
J We apt.eciate you informing us of your concerns and feel that our actions in this matter have been responsive to those concerns. Should you have any additional questions, or if I can be of i
further assistance in this matter, please call me collect at (215) 337-5225.
Sin y,
l Edward C. Venzinger, Cr er' l
Projects Branch 4 Division of Reactor Proj ts NRC Region i 1
Attachments: As Stated i
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iono or raities A. peuweywAwtA seees DCT 111989 Docket No. 50-336 4
Northeast Nuclear Energy Company i
l ATTN: Mr. E. J. Mroczta
$snior Vice President - Nuclear Engineering and Operations Group
- p. O. Box 270 j
Hartford, Connecticut 06141-0270 Centlemen:
l
Subject:
Inspection Report No. 50-336/89-13 This letter refers to the special allegation team inspection conducte 4
l the period July 10 through 21, 1989,The inspection was conducted at the M111stene regional and headquarters staff.
Nuclear Generating Station, Unit No. 2 and consisted of document reviews, l
personnel interviews and observation of ongoing activities including equipmen j
The results of the inspection are documented in the enclosed The preliminary results vere discussed with you and seabers l
installattons.
inspection report.
of your staf f on July 21, 1989.
l several of the activities inspected were apparent violations of NRCThese are requirements and your operating license.
The violations have been l
of Vloistion enclosed as Appendix A to this letter.
categ.rized by severity level in accordance with the "Ceneral Sta tement of I
Policy and Procedure for NRC Enferenant Actions," 10 CFR part (Er.forcement Policy).
4 instructions in Appendix A.
The foregoing referencec violation's are symptomatic of other underlying probites Your employees should be trained in and encouraged I
that need your attention.
to utiltre your existing formal corrective action systees or your allegation processing program to resolve nuclear safety issues such as those th t
addressed in this report.
used reasonable efforts and a conservative approach to resolve identified safety However, the inspection results indicate a need for more aggressive i
actions on your part to identify potential employee concerns and create an issues.
j There-atmosphere conducive to the reporting and discussion of these concerns.
4 fore, in your response to this letter, you should address the actions that you l
have taken and plan to take to improve the two way comanunications between your l
In the future, we plan to direct alhgations of the i
employees and management.
tfe will monitor your tind discussed in this report ta you for resolution, allegation processing program to assure ourselves that it is rerponsive and j
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thorough.
7 In accordance with Section 2.790 of the NRCs " Rules of Prac fce," Part 2, i
Title 10 Code of Federal Regulations, a copy of this letter and its enclosure j
will be placed in the NRC Public Document Room.
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At A.6.17 and A.7.4 Disconnection of Pediation Montter Horns Allegation
'The problem that we're dealing with here is the disconnecting of the horns by the people in the area because they don't want to listen to the horn chirp. You can go to the control rcom and you can check out a key ard you can go down and shut the horn of f. By procedure, when an alarm comes in, the controt roca operations people acknowledge it. They generally log it in their log, and they're required to go down and research what's going on with that alars. They're also required to take a key, check it out, go down and bypass it. The horns have physically bun pulled out of their housing so they won't blast. The control room has an alarm cut out switch in the back of the radiation monitor. You can put that thing in alare defeat. What you do then is allow other radiation monitor alares from the other area or process monitors to come in and alert you to the fact that there is one out of spec. When you put the unit in alare defeat it really basically inops the alarm feature. So as a feature of that, when you put in through the alare defeat position, it blows the horn in the area where the monitor's local indication is and the red light and the horn come on. What He has to happens is whoever's down in that area doesn t like to listen to it.
go all the way to the control icom, check out a key, and cos,e all the way back and put a key in. So they pull if of f the wall."
Discussic_n PDCR 2-19-75, dated February 19, 1975, which authorized the installation of the horn bypass keys, stated as a reason for the change that area and process radiation monitor horns presented themselves as a nuisance during calibration and prolonged a' rz conditions. It further stated that plant operational experience has seen u,,ts physically removed ce tampered with as a means of elisinating the nuisance.
This allegation was previously investigated and documented in Regional Inspection Report (IR) 50-336/88-24 as unsubstantiated. In IR 50-366/88-24, two instances of disconnected horns (other than units that had been retired in place) were noted. These were P.M-7892, ' Solid vaste Drursiing and Deconttaination Room" area monitor (the allegation) and RM-9813, " Resin Drum Filling Operations" area monitor. The inspection report stated that RM-9813 had an outstanding trouble report to correct a low off scale indication. The inspection report assuetd that the horn probles was addressed by the trouble report; however, it did not address the f act that the horn was found disconnected on RM-7892 (the original allegation).
When radioactive material in the vicinity of RK-9813 was removed, the ganeral area radiation levels dropped below a predeterstned low setpoint causing the unit to alars. The control root has two annuncistors (pans 1 alarss), one for process sonitors and one for area radiation monitsrs. Once an alars (high or low) for one monitor comes in and is acknowledged, the control roca is incapable of detecting further alarms of that type from related monitors. If the alars cannot be reset in a reasonable period of time, standard practice is to place the sodule for that specific radiation sonitor into an 'alars defeat" position; thereby, allowing the control room to clear the alars and properly montter the
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remaining detectors. In placing a module in the alars defeat mode, the horn located in the area of the monitor, is automatically activated as a precautionary measure. In the case of RM-9813, the horn bypass keys, located in the control room, would have been used to silence the horn untti such time that a new low setpoint could be determined, appropriately set, the module reset and placed back into operation.
When alares are received in the control room, OPS Form 2387E, "CRAS, Annunciator Fors", Rev. 4, provides the operator a concise chart referencing the appropriate operating procedures and sections for responding to the alam. For area and process radiation sentters, it directs the operators to operating procedures OP23818 and OP2383A, respectively. Procedure OP23838, " Area Radiation Monitoring Operation", Rev. 3, dated Aprt) 12, 1984, is inconsistent in that it requires bypassing the horn on a high radiation alars, but not for an instrument failure (low) alarm. Procedure OP2383A, ' Process Radiation Monitors Operation" Rev. 6 j
dated March 27, 1986, also does not require horn bypassing on an instrument l
fat) alare and further directs the reader to other monitor specific procedures wher, addressing a t igh radiation alars. Of the 13 monitors listed, the inspector noted that the Itsted references for 6 monitors did not exist. This was due to f atture to update these references when the associated procedures underwent extensive format cl.anges. The inspector noted further inconsistencies in that, l
of the remaining references, two addressed the bypass keys whereas four did i
not.
During a review of completed surveillances, the inspector noted that on January 10, 1989, technicians performing procedure $P2404AQ noted that the local horn was alssing. However, the technicians did not initiate a trouble report or use any other nthod to cause the problem to be addressed other than a note on the
- l surveillance document. Subsequent to the Surveillance, operations personnel rediscovered the r.issing horn, initiated the proper docueentation and the horn was eventually replaced.
The inspector examined 26 process and area monitors for indications of horn tampering. None were observed although a few had horns that were loose but not to the point where it was felt that horn operation was comproatsed.
l Conclusion l
This allegation is substantiated. The licensee previously acknowledged a probles with horn taspering as a justification for installing the born bypass keys. IR 50-336/84-24 documented two instancts of such tampering and an additional example was documented by the licensee in a surveillance report. Procedural evidance to operations personnel for use of the bypass keys is spotty and inconsistant which say lead to an activated horn not being bypassed in a timely fashion and prompting a worker to use an siternate method to silence a nuisance horn. However, the probles with horn tampering appears to be a few isolated instances and does not seem to be pervasive. The inadequate procedural guidance to operations personnel regarding the use of the bypass keys is an unresolved ites pending itcensee corrective action and NRC review (50-336/89-13-13).
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s Docket No. 50-336 Northeast Nuclear Energy Corpany ATTN: Mr. Edward J. Mroczka Senior Vice President - Nuclear Engineering and Operations P.O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
Subject:
NRC Region I Inspection No. 50-336/90-11 This letter transmits the report of the routine resident safety inspection conducted by Mr. P. Habighorst of this office on May 30 - July 11,1990 at Millstone Nuclear Power Station, Unit 2. Waterford, Connecticut. The report covers activities authorized by NRC License No. OPR-65. The inspection findings were discussed by Mr. Habighorst with Mr. J. Keenan of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region I inspection report which is enclosed with this letter. Within these areas, the insp?ction consisted of observation of activities, interviews with personnel, r.easurements, and document reviews.
Also, this refe-s to your letter dated April 30, 1990, in response to our letter dated April 4,1990, concerning NRC Region 1 Inspection 9.eport No. 50-336/90-01. Thank you for informing us of the corrective and preventive actions documented in your letter regarding a violation that involved f ailure to docutent a Lice see Event Report for a condition prohibited by the plant's Technical Specifications. Your actions were exarnined and found acceptable as documented in Inspection Report No. 50-336/90-09, Section 7.4.1.
We have no j
further questions in this satter.
Your cooperation with us is appreciated.
Sincere 1y'slGrfED or ORIGl!ZL
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EDWARD C. WENZINGER 600S' Edward C. Wenzinger, Chief Projects Branch No. 4 Division of Reactor Projects l
Enclosure:
NRC Region I Inspection Report No. 50-336/90-11 I
0FFICIAL RECORD COPY IR MILL 2 90 0001.0.0 11/29/80 YCer i
'N 3
i drain system.
The RCS water entered the aerated waste drain i
tank and degassed.
The radioactive gas was subsequently trans-ported to the control room air conditioning (CRAC) room through three floor drains.
The gas transport occurred as a result of a small negative differential pressure (.08 inch water gauge) i between the aerated waste drain tank room and the CRAC room.
1.icensee action to prevent recurrence of this event iccluded installation of loop seals in the floor drains in the CRAC room anc repair of the control room ventilation system duct work.
Tht corrective maintenance work on the associated duct work eliminated the differential pressure between rooms (aerated waste drain tank and CRAC).
The inspector verified loop seals
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were installed in the CRAC room and that dif ferential pressure l
between the two af fected auxiliary and control building areas remained within intended limits through periodic inspection of the traps curing plant tours.
Inspector review of the licensee's assessment of control room habitability during the October 30, 1987, event identified that all license conditions were satisfied; specifically,10CFR20 and emergency procecure EPIP 4701-6 offsite release limits were met, technical specification air inleakage limits were satisfied, and raciation exposure to control room operators was much lower than regulatory limits.
This item is closed.
2.4.2 (Closed) Unresolved Item 50-336/89-13-13:
Inadecuate Procecural Guidance to Goerations Personnel Recarding Use of Raciation Monitor Alarm Bypass Key 1 is item concerr,ed inadequate procedural guidance to operations personnel regarding the use of bypass keys to bypass local area ractation monitor alarms.
Station procedures OP-2383A and OP-2383B have been revised to l
require that local radiation alarms, when placed in bypass to silence the alarm, must be returned to service when the alara condition clears.
This procedural requirement applies whenever an operator has used the bypass key to respond to a local alarm.
This item is closed.
2.5 Non-Intent Procedure Chance Timeliness On June 21, the licensee identified a non-intent procedure change that was not reviewed by the plant operations review committee (PORC) within fourteen days of issuance.
The deficiency was documented by the licensee in plant incident report (PIR) 90-54. Procedure EN-21132 Change 3, Revision 5, Service Water Operational Test" was approved by senior reactor operators on June 5,1990, and approved by the PORC on June 21.
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