ML20036B453
| ML20036B453 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1991 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20036A053 | List:
|
| References | |
| FOIA-92-162 NUDOCS 9305200145 | |
| Download: ML20036B453 (2) | |
Text
46 pm Kto UNITED STATES g
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NUCLEAR REGULATORY COMMISSION 5
- l REGloN I 475 ALLENDALE ROAD
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KING oF PRUSSIA. PENNSYLVANIA 19406-141s t
AUG 141991
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I am responding to conceins that you provided to us on July 9,1991, alleging that (1) the stac low range radiation monitor RM 8132 does not meet the operability definition of the TS requirements, the calibration procedure for RM 8168 - SP 2402AS is deficient, and there is uncorrected problem with the channel which causes the control room indicator to lockup; and (2) the SP requires the technician to read an indicator to within 1 degree F accuracy when the scale markings can only be read to 4.5 degrees.
We are aware of no regulatory requirements which require the installation of the interlock between RM 8168 and RM 8132. nor any requirements for testing it, because this interlock is not a safety-related function of either monitor. Therefore, the NRC plans no further action in this matter and considers the issue closed. The second part of issue (1), your concerns regarding the calibration procedure for RM 8168 - SP 2402AS and the channel, will be addressed in our response to your concerns expressed to us on July 16, 1991.
Issue (2) above is not a regulatory requirement, however, we are generally reviewing quality of procedures. We will monitor the licensee activities and will take action when appropriate to address weaknesses that are identified. We plan no further action on this specific concern.
We appreciate you infonning us of your concerns and feel that we have been responsive to those Should you have any additional questions regarding these matters, please call me concerns.
collect at (215) 337-5225.
Sincerely; i
e R
M.,
ward ennnger, Chie i
Reactor rojects Branch 4 I
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August 16, 1991 Docket No. 50-336 A09716 RE: Employee Concerns l
i Hr. Charles V. Behl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region 1 l
475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Behl:
i Millstone Nuclear Pover Station, Unit No. 2 l
RI-91-A-0143 Ve have completed our review of the identified issues concerning activities at Millstone Station.
As requested in your transmittal letter, our responses do not contain any personal privacy, proprietary, or safeguards information.
The material contained in these responses 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 limited distribution on a "need to know" basis during the preparation of this response.
ISSUE 1:
The electrical circuit for radiation monitor RM 8132 (Stack Sample Fan 41B) l is improperly vited. Plant documents (Drawings 25203-32022, Sht.16 and l
25203-39092, Sht. 7) and the documents associated with PDCE 2-90-032 fail to adequately describe as built plant conditions.
The improper viring is I
associated with the sample fan control circuit, and may not have been documented dering installation of safety tags to support PDCE 2-90-032, -
when 60 volts vere found to be present at 9 terminals on 2 terminal boards.
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' Mr. Charles V. Behl, Director J
U. S. Nuclear Regulatory Commission 1
A09716/Fage 2 l
August 16, 1991 i
Response
The issue identifies improper viring of the electrical circuit for i
Radiation Monitor RM 8132's Stack Sample Fan 415, and notes that this condition say not have been documented during installation of safety tags.
Report (PIR)91-061 vas issued on June 13, 1991, and Plant Incident that removal of fuses F3 and F4 to remove the power from the RM identified 8132A flow control circuitry did not remove all power, i.e., 60 volts to ground remained.
Following issuance of PIR 91-061, the condition vas researched by repre-sentatives of the Engineering, Generation Test Services, and I&C Depart-ments.
This research concluded that mis-viring had occurred in the controls of fan The cause of tha mis-viring is not knovn. The viring was corrected F41B.
a separate Automated Vork Order (AVO) and drawings were corrected to under reflect the desired connections.
This issue has no significance with regard to safe'ty since the sample fan functioned as designed.
The mis-viring came to light during the work necessary to add a new piece of equipment. Fuse removal did not clear pover in all circuits. The item was immediately documented in PIR 91-061 when the tagout revealed that not all power had been removed after the fuses vere pulled.
I ISSUE 2:
A radiation monitor power viring diagram (Drawing 25203-39092, Sht. 14B) 's marked up vith draving/ installation discrepancies, as is a print of radiation monitor connections.
Response
The drawing number cited, 25203-39092, Sheet 14B, is in fact the power flow diagram for Radiation Monitor RM 9327. The actual drawing that should have been referenced is Draving 25203-39092, Sheet 14E.
Vhen the draving for RM 8132A/B vas referenced (39092, Sheet 14E), it was I
found not to show the existing timer relays, used for recording run times, This information j
and was missing a spare contact termination arrangement.
was added under Design Chang Request (DCR) M2-P-081-91. The absence of these two details is insignificant in regard to safety.
l ISSUE 3:
Draving 25203-31175, Sht. 102, for viring T497 Letween RC-14 and RM 8132 is, in error.
Mr. Charles V. Behl, Ditector U. S. Nuclear Regulatory Commission A09716/Page 3 August 16, 1991
Response
Drawing 25203-31175, Sheet 102 showed that the terminations of two cables terminal points 7 and 8.
Field inspection' being joined together were on revealed that the two cables vere actually terminated at terminal points 14 As a result, DCR M2-P-081-91 was issued to correct the drawing and and 15.
This issue has no significance in
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the correct termination location.
All cables were found to be joined together as required show regard to safety.
the design. Bad any trouble shooting or design vork been needed, the by available cable information was sufficient as shovn.
ISSUE 4:
undocumented lifted lead exists in Panel RCl4C in the Control Room.
lead is from Control Room Panel C101 to Control Room Panel RC14C, and An (The The automatic should have been attached to terminal block T6, location 3.
isolation and purge of the normal range ventilation exhaust radiation mor.i t or (RM 8132), by an isolation signal from the extended range monitor The isolation feature is (RM 8168), is disabled when this lead is lifted).
not checked during channel functional or calibration tests.
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Response
lif ted electrical lead vas immediately identified by PIR 91-65 on June
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The of this issue from the NRC. The lifted lead, 1991, prior to receipt 27, landed, vould perrit a high radiation alarm relay from the high range when Radiation Monitor RM 8168 to open the air purge supply valve, 2-HV 456.
This valve is on the inlet to RE 8132B, and when opened allovs air to purge This feature vas added during the design and inlet of the detector.
the of RM 8168, as a desirable protective function to prevent the installation from becoming contaminated by high level activity leaving the monitor The auto purge function was tested satisfactorily after its initial stack.
installation, but it cannot be determined when the lead was lifted.
The absence of the lead vould have prevented the auto purge of RM 8132B's detector.
- Bovever, there is no requirement to test this auto purge function (referred to as " isolation feature" in Issue 4 above), and thus this function was not routinely tested. The testing of this auto purge function has been added to the surveillance procedure for RM 8168.
There is no significance to the lif ted lead with regard to safety, based on the previous reviev. The addition of the testing of this function to the j
surveillance procedure is consistent with the intent of the original M
installation.
our reviev and evaluation, ve find that these issues did not present After compromise of nuclear safety. As indicated in our any indication cf a responses, several of these issues had previously been identified by
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Mr. Charles V. B;hl, Dirceter U. S. Nuclear Regulatory Commission
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A09716/Page 4 August 16, 1991 Northeas?
Utilities' corrective action system.
Ve appreciate the opportunity to respond and explain the basis of our actions. Please contact my staff if there are any further questions on ay of these matters.
Very truly yours.
NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Mroczka Senior Vice President BT:
V. D. Romberg / )
Vice Presiden V cc:
V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor Projects E. M. Kelly, Chief, Reactor Projects Section 4A l
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emergency plan implementing prceedures in defining a significant operational transient in relation to escalation criteria during a loss of annunciator event. Good technical support, r
team work, and management decision-making were evident throughout the event.
t 4.0 RADIOLOGICAL AND CHD11STRY CONTROI.S (IP 71707) i' f
4.1 Posting and Control of Radiological Areas During plant tours, posting of contaminated, high airborne radiation and high radiation areas was observed to be appropriate with respect to boundary identification, locking requirements, l
and nold points.
4.2 Stack High Range Monitor Rh18168 Operability The inspector reviewed the status of the stack high range radiation monitor, Rhi 8168, on July 8. The inspector noted that the high range monitor is electrically interconnected to the low mnge monitor, Rh18132, such that a high range release v. ll place the normal range monitor into a purge mode for the duration of the release. The inspector noted that NNECO found the electrical interlock with the low range stack monitor bypassed. The interlock was reinstated and surveillance procedure SP 2404AR was revised to add a test of the interlock.
The inspector questioned whether the channel was operable per the technical specification definition if the interlock functions had not been installed or tested.
Moniter Desien t
RM 816S is a Kaman model KMG-HPJi offline effiuent monitor that consists of a gaseous monitor, and particulate and iodine collectors for measuring effluents from the hiillstone 2 stack in the event of an accident. The system samples effluents using an isokinetic nozzle located in the hiillstone 2 ventilation stack. The high range monitor covers stack effluents in a range above that covered by the stack low range monitor, and measures concentrations from IX10-4 uCi/cc to 2X10+5 uCi/ce.
6 The purpose of Rh18168 is to monitor the level of radioactive effluent gases discharged from the hiillstone 2 ventilation stack during accident conditions and to provide an alarm if setpoints are exceeded. The monitor is used with the emergency plan implementing 4
procedures to provide an emergency action level for escalating from alen to site area emergency conditions. Although the hiillstone 2 stack represents a potential release path of post accident activity, all design basis post accident releases from hiillstone 2 are routed through the enclosure building filtration system to the 100 meter Millstone 1 stack. "Ite Millstone 2 stack ventilation fans are isolated (by procedure) upon high activity indication on
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i the normal range stack gas monitor. Thus, RM 8168 might not be of much use under accident conditions unless unusual conditions result in releases from this pathway.
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8 Regulatory Recuirements RM 8168 is a single channel (non-redundant) system installed by NNECO to meet the requirements of Item II.F.1 of NUREG 0737. Inspector review of the NUREG and the l,
NNECO docketed responses to Item II.F.1 determined that the installed configuration for 5
RM 8168 meets the requirements for channel redundancy, ranges, function, and alarm requirements. The interlock feature with the low range monitor is neither required by the NUREG nor a NNECO commitment to meet the post accident monitoring functions of installed instrumentation.
Technical Specification 3.4.3.3 (Table 3.3-6 Item 1.6) requires that Millstone 2 stack high range gas monitor be operable durirg reactor operation in modes 1 through 4, with an alarm k
serpoint at 2 x 10-1 uCi/cc and a measurement range of 10-3 to 10+5 uCi/ce. If the single channel system is not operable, NNECO must restore the monitor to an operable status within 7 days or submi: a special report to the NRC within the subsequent 14 days explaining the cause of the inoperabihty and the actions to correct the deficiency.
The inspector noted the technical specification definition for operability requires that components be capable of performing specified functions. The specified functions are those designated in the license and licensing documentation. In this instance, the specified functions for RM E16S are those specified in the technical specifications and the licensee commitments to NUREG 0737.
The electrical interlock with RM 8132 is a good design feature that could help preclude the t
need for maintenance (decontamination) on the low range monitor after a postulated accident.
However. the inspector concluded that RM S168 is operable per the technical specifications even if the interconnection is not functional and the licensee would not have to enter the LCO. The inspector noted that the NNECO position on channel operability is consistent with that stated above.
RM 8168 Maintenance Activity
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The inspector noted NNECO identified a recurrent problem with the RM 8168 channel that
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caused the control room indicator to lock-up at times. The lockup was noted by plant operators and the lockup was corrected at each occurrence. Since the problem was addressed l
previously in maintenance work orders but remained uncorrected, NNECO declared the monitor inoperable at 2:30 p.m. on July 13, 1991.
NNECO investigation determined that the intermittent failures were caused by Ductuations i.
the power supply output. The power supply Ductuations were detected by the microprocessor which is designed to detect the power Ductuations and save the programming information before complete loss of the power output. The effect of the power supply Ductuation was to halt the monitor operation.
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NNECO provi' J guidance to operators on how to reset the monitor to keep the unit in an operating status pending completion of repairs. NNECO described the repair action in a special repon submitted to the NRC on July 29,1991, per Technical Specification 3.3.3, i
Table 3.3-6 Action 17. The repair was to order replacement pans to rebuild and install a spare power supply. NNECO expected the repairs to be completed by July 21,1991.
The inspector noted that NNECO completed action to repair the power supply, and following a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> test run, the monitor was declared operable on Au3ust 1,1991. Long term stable operation of RM 8168 will be reviewed by the inspector as part of the routine review of Millstone 2 operations on subsequent inspections. The inspector had no funher comments on this item.
Conclusion The inspector concluded the RM 8168 is operable and NNECO does not have to enter the LCO if the interlock with RM 8132 is not functional or tested. NNECO actions to repair a faulty power supply associated with RM S168 and repon the matter to the hTC were appropriate.
4.3 Spent Fuel Pool Area Frisker A plant worker found there was no frisker in the frisking booth at the 38-ft elevation of the spent fuel pool area on July 7,1991. The individual worked in protective clothing in the work area for radiation monitor RM 8168, a contaminated area. The worker stated he frisked out using the PCMs on the 14-ft elevation at the main exit from the primary auxiliary building (PAB).
The worker noted that other plant personnel were also on the refueling floor performing spent fuel consolidation work, an activity requiring a radiation work permit and a frisk for personnel contamination upon finishing the job. The worker stated he mentioned the lack of a frisker to the duty health physics (HP) technical at the checkpoint on July 7, but nothing was done. The worker told the Millstone 2 HP supervisor about his observation on July 8, and actions were taken to place a frisker in the frisking booth.
The resident inspector reviewed this matter on July 8. The inspection included interviews with HP personnel, a review of station procedures, and tours of areas in the PAB. The inspector noted that a frisker was installed in the frisking booth during his tour on July 8.
Performing a whole body frisk is a good health physics practice as a final check that personnel are not contaminated. A frisk should be performed as close to the work area as possible to prevent the inadvenent spread of contamination. Station procedures do not specify the location of permanent friskers, but friskers are placed as needed by HP personnel as necessary to suppon ongoing work activities. Technicians at the HP control point keep track of the fixed frisker locations and one should have been stationed at the 38-ft elevation
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