ML20036B449
| ML20036B449 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/1991 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20036A053 | List:
|
| References | |
| FOIA-92-162 NUDOCS 9305200120 | |
| Download: ML20036B449 (1) | |
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Kwo or enussia. PENNsRVANA IMO&W6 l
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1 The NRC Region I of6ce has completed its followup of the concerns that you brought l
attention on July 5,1991, asserting the following81) two electricia;1Lwere usiened surve u
the tub; (2) the Procedures SP-240lR "CWP_HighTower" uit%eFpre ently oerformine 4
NNECO Task Force is interviewing employees to address safety concerns becaus conndence with NU management; and (3) based on the interviews with the NNECO Ta I
j potential harassment exists.
In regard to your Orst concern, the Integrated Performance Assessment Team (IP i
presently reviewing this issue from a generic perspective. "Ite appropriate actio 1
based on the team's findings and therefore, we intend no addidonal action at this time.
j to your second concern, since no specific safety concerns were identified, this is in regard to If you have specific safety concerns, please provide them for our review, harassment, the inspector has advised you to take such concerns to the Department of La (DOL) and you have been provided with the necessary materials in previous correspo 1
Should you have any further questions, or if I can be of further assistance in these regarus, please call me collect at (215) 337-5225.
- cerely,
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Edward Wenzinger, Chief Reactor Projects Branch i
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478 ALLENOALE ROAD 81 KINQ oF PRUsStA. PLNNsYLvANIA 16E*1418 l
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This letter refers to several concerns that you provided to us, the first set on March 2,1991, alleged that I&C i
technicians were required to work excessive hours in support of the Unit 2 startup on February 17,1991, and that a technician was insufficiently trained on a surveillance procedure. Your second concern, on March 5,1991, alleged that the procedures used to calibrate the replacement feedwater and charging flow transmitters were not appropriate for use with the newer Foxboro ' smart
- transmitters.
i These concerns were referred to the licensee for their evaluation. Attached for your information are their responses to these concerns. The licensee has made changes to improve l
the procedure review process and the on-the job training program to address your concern about technician training when procedures undergo significant change. The licensee also plans additional training for I&C technicians in the calibration process for the ' smart
- transmitters. The other concerns were not substantiated.
The NRC plans no further action in any of these matters. Please advise us if you wish to pursue further any of these issues. Thank you for informing us of your concems.
5 Sin y,
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ward Wenzing,
Reactor Projects Branc i
Enclosures:
- 1. NU letter A09557, dated 7/1/91 j
- 2. NU letter A09558, dated 7/1/91 V;W N
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July 1, 1991 Docket No. 50-336 A09557 Hr. Charles V. Behl, Director Division of Reactor Projets
- 11. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Frussia, Pennsylvania 19406
Dear Mr. Beh1:
Millstone Nuclear Power Station, Unit No. 2 RI-91-A 0046 have completed our review of identified issues concerning activities at Millstone Unit No. 2 (RI-91-A-0046).
As requested in your transmittal ve letter, our response does not contain any personal privacy, proprietary, orresponse safeguards information. The asterial contained in this released to the public and placed in the NRC Fublic Document Roost at your i
have received controlled and discretion.
The NRC letter and our response limited distribution on a "need to knov' basis during the preparation of this response. Based upon our request on June 25, 1991 vith Region I a four day axtension to this letter was granted to allov for personnel, routine and proper administrative processing.
I,.*~* U2 '
An Instrument and Controls technician worked on RFS natrix an calibrations to support the Millstone 2 startup following a setas on February 16, 1991.
The surveillance procedure had undergone extensive changes recently and the technician was not adequately trained on the recent revisions to the procedure. Special assistance was required for the technician to understand and complete the procedure.
Please discuss the validity of the above assertion. Please discuss any corrective actions being taken to train technicians on revisions to procedures prior to isplementation.
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'Mr. Charl:s V. Rahl Direct:r U. S. Nuclear Ergulatory Commission A09557/Page 2 July 1, 1991 MIN
- Backgrounds s
r a station procedure change er revision is M and far s w ifh n & !a-an
' he time of its Ma'-e-'-an.
A prospt to cons 1ces ik -
c67IsTdered st t
implementation has been added n(eT for training prior to procedure change the Millstone Unit No. 2 Instrument and Control (IIC) procedura routing to sheets.
This was done as an enhancement to the procedure review process and vill secelerate any necessary immediate modifications to the on-the-job Unless the procedure changes are significant in nature and beyond program.
the skills of the personnel performing the work, training does not typically take place prior to change implementation.
Procedures, chansas and revisions are written to a level of detail which is sufficient to ensure that the technician has the level of detail needed to perfora the task.
All revisions to IEC procedures are reviewed by the Technical Training Department for the need to sodify training saterials or to conduct additional training.
Response
The assertion that the personnel who performed startup support setivities were not adequately trained is not accurate. /The surveillance was 6 --- ia 1 performed correctly by the eersonnel assigned, withouf7he namn to undustand the nrocedure. / The surveillance data sheets have
~Tasistance tan revievec and the results found acceptable.
This issue had not been addressed to department sansgement.
The NRC l
Resident Inspector has reviewed this issue and concluded that the surveillances were properly completed as documented in NRC Resident Inspection Report 91-04 Section 7.5.
yurthermore, our technicians are instructed to return instruments to a safe condition and to seek assistance 11 they have any difficulty understanding the action requested by procedure.
Issue 2:
Hours in excess of overtime limitations, were worked by Instrument and Controls technicians in support of the Millstone Unit No. 2 startup on yebruary 17, 1991 One individual was "on-call" for plant support and was in the dosi role of being 'on-call' as an esertency i
activities This technician vorked a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> shift on Millstone Unit No. 3 responder.
on February 16.and remained on duty for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> keeping the pager until 0730 on February 17. This individual vas overworked and could not perform his duties in support of the unit startup.
4 Plasse discuss the validity of the above assertions.
Please discuss any actions taken to ensure overtise restrictions are not exceeded in cases such as that described above.
l'-
-Wr. Charles V. Ichl, Dirccter l *..
U. S. Nuclear Regulatsry Commission A09557/Fage 3 July 1, 1991 d
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l
Background
had worked a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> day was on call the night of Feb-One person whoHe was called in at 2030 to conduct instrument surveillance by ruary 16th.
the shift supervisor. Additional personnel were called in to relieve his later that saae evening. There were no personnel that verked total hours in excess of established station overtime guidelines.
The on-call individual was fully capable of fulfilling his energency plan responsibilities at all times.
This issue was evaluated by the NRC Resident Inspector and concluded that i
the surveillances vere properly completed as documented in NRC Resident Inspection Report 91-04.
This issue had not been addressed to department management.
Responses No overtise limits vere exceeded by this individual.
Established station performed their duties as required by procedures.
personnel on-call limits do not apply to personnel when they are performing on-call Overtime i
responsibilities and are at home. The on-call person who was called in was relieved prior to being overvorked and prior to exceeding any overtise guideline restrictions. If the energency plan had been activated in this same intervs1, back-up resources vould have been availableinJhe event been able to perform his duties, a t ia the the individual had not that of all energency-plan zenponders ta idantisy is -
-- em,
responsibility theirassignedduties/ No additional W re nnt e---b W p-rford ne actions are required.
Af ter our reviev and evaluation, ve find that neither of these issues taken either singularly or collectively present any indication of a compromise of l
nuclear safety. Ve appreciate the opportunity to respond and explain the l
basis for our actions. Please contact my staff if there are any further questions on any of these matters.
Very truly yours, l
NORTHEAST NUCLEAR ENERGY CONFANT I
'/
E. J.~ )Pfoe'ska
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Senior Vice President een V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief, Projects tranch No.
4, Division of Reactor Projects i
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NORTHEAST UTILFFIES
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' J July 1. 1991 Docket No. 50-336 A09558 1
Mr. Charles V. Behl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 Dear Hr. Hehl Millstone Nuclear Fover Station, Unit No. 2 RI-91-A-0049 i
have completed our review of identified issues concerning activities at ve Unit No.
2 (RI-91-A-0049).
As requested in your transmittal Millstone letter, our response does not contain any personal privacy, proprietary, or i
safeguards information. The esterial 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 knov' basis during the preparation of this response. Based upon our request on June 25, 1991 vith Region I personnel, a four-day extension to this letter van granted to allow for routine and proper administrative processing.
Issue:
" smart' or ' intelligent" transmitters were installed approximately Foxborofuel cycle ago to be utilized during the calibration of feedvater flov one transmitters FT-5269A, FT-5269B and charging flow transmitter FT-212. The use of these *ssart' transmitters is not in the contro111ag calibration IC-24265 for feed flow and IC-2429A for charging flow.
The procedures, modification work (FDCU PDCR) did not address the need for the controlling procedure changes.
In addition, training on the 'anart' calibration transmitter was limited to a Foxboro vendor representative presentation to the IIrc technicians.
Please discuss the validity of the above assertions. Please discuss actions taken to determine whether the above mentioned flov transmitters have been properly calibrated subsequent to the installation and tise of the Foxboro ' smart" transmitters.
h h e
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I Mr. Charles V. B;hl, Dirceter l,..
'U. 8. Nucicar Regulatcry Commissica A09558/Fage 1 July 1, 1991 Saekaround Two " intelligent' replacement transmitters have been installed in the feedvater flov application. The transmitters are one-for-one rep 1seements that did not require any plant modification for installation in this i
application.
The calibration method detailed in the procedure is the same for both intelligent and analog transmitters. The need for procedure changes at the time of the replacement was reviewed and determined to not be necessary.
After the second replacesant, an Instru. ant & Control (I&C) Specialist requested that additional training on this type of transmitter be conducted.
The vendor of the transmitter provided an overview of the transmitter operation. The Technical Training Department was requested to provide more detailed training on hardvere and software used during the t
calibration activity. This training is tentatively scheduled for the first quarter of 1992.
l This issue was documented in NRC Resident Inspection Report 91-04 Section l
5.5.2.
Easponsen l
The performance of the new transmitters has been reviewed and determined to be acceptable. The 'as left' calibration data document the results and l
acceptability of the calibration activity. The calibration methods are similar.
It is considered within the skill level of the IEC technicians who are trained in the calibration of similar transmitters. In fact, there have been no identified errors related to this calibration activity.
- However, the additional training vill further enhance the skill level and proficiency of the IGC technician performing the calibration tasks.
After our review and evaluation, ve find that this issue does not present any indication of a compromise to 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 j
natters.
Very truly yours, j
NORTEEAST NUCt2AR ENERGY COMPANT R. WijfbEsM ~/~
Senior'Vice President cc:
V.
J. Raymond, Senior Resident Inspector, Millstone tinit Nor".
1, 2, and 3 E.
C. Venringer, Chief, Projects Branch No.
4, Division of Reactor Proj ects