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475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 Ken Major fd-3N State of Connecticut Department of Environmental Protection Bureau of Water Management (W-122) 165 Capito! Avenue Hartford, Connecticut, 06106 f
Dear Mr. Major:
1 The Nuclear Regulatory Commission (NRC) received a concern from a Northeast Utilities employee on April 11, and 12,1991, which related to fulfillment of the National Pollutant Discharge Elimination System (NPDES) permit issued to the Northeast Nuclear Energy Company for the Millstone Nuclear Power Station (NPDES Permit No. CT0003263).
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The employee questioned the adequacy of a station procedure which, in part, functionally tests temperature measuring instruments installed to fulfill the requirements of Sections 3A l
and 31 of the permit.
i The employee questioned the ability of a technician to successfully complete the procedural requirement of comparing the calibration standard temperature to the temperature displayed in the Millstone Unit 2 Control Room. This was due to the resolution afforded by the plant instrumentation. The employee's concern developed during the performance of the testing in accordance with station surveillance procedure number SP 2406A, " Water Quality Monitor Functional Test." A brief summary of the concern is attached.
We are not aware of any NPDES Permit limitations being exceeded because of this issue.
We wish to make you aware of this issue as it falls outside of the regulatory authority of the NRC. If you have any questions concerning this issue, you may contact me at 215-337-5222, or Mr. J. Scott Stewart. Senior Project Engineer, at 215-337-5232.
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q Thank you for your assistance in this matter.
j Sincerely,-
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4Lyhnuws3 Roy l-. Fuhrmeister Senior Allegation Coordinator -
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Enclosure:
As stated cc:
K.M. McCarthy, CT SLO T.R.E. Keeney, Commissioner t
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MILLSTONE WATER QUALITY MONITOR CONCERN Procedure SP 2406A, " Water Quality Monitor (WQM) Functional Test," Revision 3, implements a monthly surveillance test to satisfy the NPDES requirements on intake, discharge, and quarry cut temperature limitations.
An employee noted that there were no graduations between major temperature coints on the temperature recorder (every nine degrees Fahrenheit). Data sheet SP 2406A-1 calls for a +/-
one degree Fahrenheit determination by the Instrument and Controls technician on the recorder output. The employee then pointed out that there appears to be no basis for the 0.1 degree Fahrenheit resolution requirement for the temperature detector.
Instrument and Controls Department management have indicated that a new recorder will be installed as part of the WQM upgrade scheduled to be implemented during the November 1990 - March 1992 operatmg cycle.
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s 2 9 JUL 1931 Ken Major State of Connecticut Department of Environmental Protection Bureau of Water Management (W-122) 165 Capitol Avenue Hartford, Connecticut, 06106
Dear Mr. Major:
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l The Nuclear Regulatory Commission (NRC) received a concern from a Northeast Utilities employee on April 11, and 12,1991, which related to fulfillment of the National Pollutant Discharge Elimination System (NPDES) permit issued to the Northeast Nuclear Energy Company for the Millstone Nuclear Power Station (NPDES Permit No. CT0003263).
The employee questioned the adequacy of a station procedure which, in part, functionally tests temperature measuring instruments installed to fulfill the requirements of Sections 3A-and 31 of the permit.
The employee questioned the ability of a technician to successfully complete the procedural I
requirement of comparing the calibration standard temperature to the temperature displayed in the Millstone Unit 2 Control Room. This was due to the resolution afforded by the plant instrumentation. The employee's concern developed during the performance of the testing in accordance with station surveillance procedure number SP 2406A, " Water Quality Monitor j
Functional Test." A brief summary of the concern is attached.
We are not aware of any NPDES Permit limitations being exceeded because of this issue.
l 1
We wish to make you aware of this issue as it falls outside of the regulatory authority of the NRC. If you have any questions concerning this issue, you may contact me at 215-337-5222, or Mr. J. Scott Stewart, Senior Project Engineer, at 215-337-5232.
OFFICIAL RECORD COPY I\\
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^ A, Thank you for your assistance in this matter.
Sincerely, Original 01gned By Roy L. Fuhrmeister Senior Allegation Coordinator
Enclosure:
As stated cc:
K.M. McCarthy, CT SLO T.R.E. Keeney, Commissioner OFFICIAL RECORD COPY
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RI-91-A-0069 E.M. Kelly M.T. Miller concurrences RI: ORA RI: ORA RI: ORA RI:DRP RI:DRP h
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I OFFICIAL RECORD COPY
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MILLSTONE WATER QUALITY MONITOR CONCERN 1
Procedure SP 2406A, " Water Quality Monitor (WQM) Functional Test," Revision 3, implements a monthly surveillance test to satisfy the NPDES requirements on intake, discharge, and quarry cut temperature limitations.
An employee noted that there were no graduations between major temperature points on tha temperature recorder (every nine degrees Fahrenheit). Data sheet SP 2406A-1 calls for a +/-
one degree Fahrenheit determination by the Instrument and Controls technician on the recorder output. The employee then pointed out that there appears to be no basis for the 0.1 degree Fahrenheit resolution requirement for the temperature detector.
1 Instrument and Controls Department management have indicated that a new recorder will be installed as pait of the WQM upgrade scheduled to be implemented during the November 1990 - March 2 992 operating cycle.
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OFFICIAL RECORD COPY t
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- APR O P 9[17:02 HRC MILLSTONE OFFICE P03 I
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- 2. Un-April and a co worker were ass 2gned (RM-8132) K The rc-wre tse the Unit was a conterctcr2 stack r 621 &t2 On monitcr Mill stone U62 :
and 2.
who preva cusl y wors oc at The alleger sSJ nis cc wceker tvital aces) ccrrectivo maintenance wcrk onto invast2 Qate wor k condi tionssate and tagging ice s(Ectr bil l ci ng ?fcub s&quentl yRM-Ll:2.~b-T he al l ager auh i : l ar y the 1.s fem 1:4c tree f ol l or.e: L/
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toGether.
The inci v2 dusj s the cunill ery bu;1:a nck 15 m2 notes.
Bcth r en.al n ed in rne sees for indt vi cusi s ext tsc the[auxiI1 cry bul1 din')put-:l y ::: -
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since ne hac previousl y worked in thednlli stune Uni tHe had atm.Lc.
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however he would would Qet back The inspector apprz;iate to hit on his quest 2on.
tol d the allager ne THE IN5PECTOR DISCCS3ED THE ABOVE TWO 132VES W ON AFRIL 1.
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APPENDIX 4.0 SAMPLE RECORD OF ALLEGATION PANEL DECISIONS SITE:
J PANEL ATTENDEES:
d [U'h /AI ALLEGATION NO.:
9/ d - bb Chairman -
g DATE: (/
(Mtg/)2 3 4 5)
Branch Chief -
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(.d.,
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PRIORITY:
High Medium Section Chief (AOC) -
. bWid Yes(hU wn Others -
SAFETY SIGNIFICANCE:
DD h SC CONCURRENCE TO CLOSEOUT:
CONFIDENTIALITY GRANTED: Yes (I (See Allegation Receipt Report) "
-i IS THEIR A DOL FINDING:
Yes
/
IS CHILLING EFFECT LETTER WARRANTED:
Yes No-s HAS CHILLING EFFECT LETTER BEEN SENT:
Yes JNo MAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER.
Yes No I
ACTION:
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UNITED STATES NUCLEAR REGULATORY COMMISSION E
REQtON I T'g E
j 475 ALLENDALE ROAD KING oF PRUSSIA, PENNSYLVANIA 19408 MAY 2 : 1991 Docket Nos. 50-336 File Number RI-91-A-0063 Northeast Nuclear Energy Company ATFN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group F.O. Box 270 Hartford, Connecticut 06141 4 270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received information concerning activities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and followup.
We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the date of receipt of this letter. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed m the NRC Public Document Room. If necessary, such information shall be contained in a separate attachment which will be withheld from public disclosure.
The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91-A-0063 when providing your response.
The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public F ocument room.
The response requested by this letter and the accompaaying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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Nonheast Nuclear Energy Company 2
Your cooperation with us is appreciated. We will gladly discuss any questions you have concerning this information.
Sincerely.
Ori;inal ria, ed By in LL)<cl<y>wlW Charles W. Hehl, Director Division of Reactor Projects
Enclosure:
(10 CFR 2.790(a) Information) cc w/o encl:
Public Document Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut bec w/ encl:
W. Raymond, SRI, Millstone Allegation File, RI-91-A-0063 J. Stewan r
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LIMITED DISTRIBUTION - NOT FOR PUBLIC DISCLOSURE 7
ENCLOSURE I
Issue: On April 1,1991, an instrument and controls technician (*) and a contractor employee were performing troubleshooting activities on radiation monitor RM-8132 in the auxiliary l
building. The two workers entered the auxiliary building together but only the technician had authorized access to the area. There should have been a local alarm to alert the individuals involved that access was not authorized for the contractor. Security responded to the unauthorized access when the individuals were exiting the area approximately 15 minutes after entering. The issue was logged in the security logs.
Please discuss the validity of the above assertions. If the assertions are true, please explain why security did not respond when the individuals entered the auxiliary building and provide us the details of any investigation that was conducted to ensure that plant security was maintained. Please provide the corrective actions planned or taken to correct any identified deficiencies?
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NORTHEAST UTILITIES cener. On.ces. seioen streer. sen.n. Connect.cv
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HARTFORD. CONNECTICUT 061414270 e.on
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July 1, 1991 Docket No. 50-336 A09569 i
t Mr. Charles V. Hehl, Director i
Division of Reactor Projects l
U. S. Nuclear Regulatory Commission Region I i
475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. H'ehl:
Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0063 have completed our review of identified issues concerning activities at Ve Unit No.
2 (RI-91-A-0063).
As requested in your transmittal Millstone 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 l
discretion.
The !GC letter and our response limited distribution on a "need to know" basis during the preparation of this response.
Based upon our request on June 25, 1991 with Region I personnel, a four-day extension to this letter was granted to allow for i
routine and proper administrative processing.
Issue:
t On April 1, 1991, an Instrument and Controls technician and a contractor employee vere performing troubleshooting activities on radiation monitor RM-8132 in the Auxiliary Building. The two vorkers entered the Auxiliary Building together but only the technician had authorized access to that area.
There should have been a local alarm to alert the individuals that. access was not authorized for the contractor.
Security involved to the unauthorized access when the individuals vere exiting the l
responded The issue was logged in the approximately 15 minutes af ter entering.
area Security logs.
If the assertions are Please discuss the validity of the above assertions.
- true, please explain why Security did not respond when the individuals l
entered the Auxiliary Building and provide us the details of any.
. investigation that was conducted to ensure that plant security vas..
maintained.
Please provide the corrective actions planned or taken to l
correct any identified deficiencies.
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'Mr. Charles U. Hrhl, Director U. S. Nuclear Regulatory Co: mission A09569/Page 2 July 1, 1991
Response
On April 1, 1991 a security officer responded to an " Intrusion Unauthorized Key - Door Open" event that occurred on Door 244S, entering the Millstone Unit No. 2 Auxiliary Building, at 08:10:06 hours.
The unauthorized entry was made by a contractor technician working with a Millstone Unit No. 2 Instrument & Control (I&C) technician. The contractor had been badged on January 16, 1991 in support of the Millstone Unit No. 3 outage, and was cleared for unescorted access to all vital areas on Unit 3.
The contractor.
had recently been assigned to work on Millstone Unit No. 2.
The contractor keyed into the Millstone Unit No. 2 Auxiliary Building following the I&C technician, who was authorized for the area and had accessed the door properly. The contractor keyed into the area while the security door vas open. No alarm was received at the security door and the pair continued to their assigned work location.
A security officer was dispatched to respond to the ensuing security alarm and entered the Millstone Unit No.~2 Auxiliary Building through the same door at 08:11:44-hours. The Security Officer had been advised of the name of the individual he was looking for as well as the name of the ILC technician who was with him when he entered the area. The Security Officer proceeded to search for the individuals.
The Security Of ficer initiated the search on the 14'6" elevation of the Auxiliary Building and then proceeded to the upper levels of this building.
The radiation monitor that the individuals were working on is located in the East Fenetration Room on the 38'6" elevation.
At 08:32:14 hours an " Intrusion Unauthorized Exit" event was received on Door 244N. This event was caused by the same contractor who entered the Auxiliary Building at 08:10:06 hours. The Security Officer, who was still searching for the individuals, was advised that the individuals were attempting to leave the area and made contact with the individuals in the area of Door 244 at 08:32:22 hours.
Subsequent investigation into this event identified that the LED in the card reader on the south side of the door had failed.
As a result there vas no local indication to the contractor that he was not authorized for A few select doors in Millstone Unit No. 2, Door 244 being one the area.
of them, had previously been equipped with audible alarms that annunciate in conjunction with the red (denied) LED.
The red LED and the audible alarm are in series and are dependent on each other for operation. The failure of either component vill render the circuit inoperable. Our experience with this design has been excellent and there have been very few LED failures over the past six years. No further corrective actions are planned.
Once the LED failure was identified, a work order was generated and repairs-vere completed the same day. The veekly surveillance for Door 244 had been performed on the previous day and was signed off as satisfactory at 0027 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />.
Hence, we conclude that this was a recent failure of the LED. If the door had been closed when the contractor used his key in the reader, he vould not have been able to gain access to the area. The response by-the security officer, and by the (CAS) Dispatcher was both timely and appropriate.
.Mr. Charles U. Hehl, Director U. S. Nuclear Regulatory Commission A09569/Page 3 July 1, 1991 1
The failure of the LED and audible alarm on Door 244 contributed to this event. It is the responsibility of each individual granted unescorted i
access to ensure they are authorized for a particular area prior to entering.
The supervisor and contractor vere counseled in the need to that access cuthorization has-been granted to an individual for a ensure specific area prior to assigning vork to that individual in that area.
It should be noted that the contractor involved reported to work at Millstone Unit No.
2 the same day that this event occurred (April 1, 1991).
Subsequent to this event, the contractor was authorized for all vital areas on Millstone Unit No. 2.
This authorization was effective within several hours of the event.
After our review and evaluation, ve find that this event did not'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 COMPANY E."J/Mroczka//
Senior Vice President 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 t
Projects t
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1fDtit.
h RECORD OF ALLEGATION PANEL DECISIONS E
PANEL ATTENDEES:
SITE:
ST-il-h- 0063 Chairman -
lot *p sh 5 ALLEGATION NO.:
DATE: 240C, (Panel No. 1 2 3 4 5)
Branch Chief -
PRIORITY:
High Low Section Chief IAOC) -
0 4 h
Unkn Sr. A11ecatien Coord (SAC) a e med Ct-SAFETY SIGNIFICANCE:
Yes SC OT Perresentative -
CONCURRENCE TO CLOSEOUT:
DD b
t,-
c ol CONFIDENTIALITY GRANTED:
Yes (ff3) tother) bwe (See Allegation Receipt Report)
Q
!S THERE A HARASSMENT / DISCRIMINATION ISSUE:
Yes IF YES, 1) has the individual teen informed of the DOL process and tre need to file a complaint within 30 days Yes No 2) has the individual filed a cceplaint with DCL Yes No 3) has a letter been sent to the complainant seeking Yes No any safety concerns Yes No IS A CHILLING EFFECT LETTER WARRANTED:
Yes @
IF YES, HAS IT BEEN SENT Yes No HAS THE LICENSEE RESPONDED TO THE CHILLING EFFECT LETTER:
RESP ECD ACT!CN:
hRf TOW 9I 1)
(
OS C
- )
3) 4)
5)
NOTES:
APPENDIX 4.0 SAMPLE RECORD OF ALLEGATION PANEL DECISIONS SITE:
b t N Skx L PANEL ATTENDEES:
ALLEGATION ND.:
k\\-$\\sk-cC6Y Chairman -
bdt 99/n 3 DATE: Y/3/4/
(Mtg.k2345)
Branch Chief -
PRIORITY:
High Medium ( h SectionChief(AOC)-!CCN9 SAFETY SIGNIFICANCE: Yes No@cwD Others -
E cdd/T CONCURRENCE TO CLOSEOUT: DD(BDSC bOk mmd bM CONFIDENTIALITY GRANTED: Yes Np' 07 7'
(See Allegation Receipt Report) j/
Yes j! o IS THEIR A DOL FINDING:
N
/
IS CHILLING EFFECT LETTER WARRANTED:
Yes No j
HASCHILLINGEFFECTLETTERNEENSENT:
Yes No HAS LICENSEE RESPONDED T CHILLING EFFECT LETTER:
Yes No ACTION:
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475 ALLENoALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19aM JUN 0 4 591 Docket Nos. 50-336 File Number RI-91-A-00M Northeast Nuclear Energy Company ATTN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received information concerning activities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and followup.
We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the date of receipt of this letter. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such information shall be contained in a separate attachment which will be withheld from public disclosure.
The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91-A-00M when providing your response.
The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public Document Room.
The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
i 1
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Your cooperation with us is appreciated. We will gladly discuss any questions you have concerning this information.
Sincerely,
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Charb W. He 1, Director j
Division of Reactor Projects
Enclosure:
(10 CFR 2.790(a) Information) cc w/o encl:
i Public Document Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut bec w/ encl:
W. Raymond, SRI, Millstone Allegation File, RI-91-A-0064 J. Stewart i
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4 LIwPsamsTnTBdh0N<N6T3D ENCLOSURE Issue 1; On March 28,1991 a QC inspector was called by Generation Construction to perform a final weld inspection of a prefabricated structure for the new steam jet air ejector monitor. The final inspection was pan of procedure GWS-006. After the inspection, the QC inspector questioned if a " fit-up" inspection had been completed, as required by procedure.
The fabrication and assembly of the structure were Non-QA, thus as required by GWS-006, the job supervisor performs the " fit-up" inspection. Based on indication that no " fit-up" inspection had been completed, the QC inspector initiated NCR 2-91-035. On April 1, Generation Construction completed the authorized work order and documented that a " fit-up" inspection had been completed; however, it had not been completed. This is the way non-QA inspection and documentation are normally accomplished.
Please discuss the validity of the above assertions. Please discuss the aced for a " fit-up" inspection and the circumstances surrounding its completion, if required. Please discuss any corrective actions that you have taken or may take in response to any identified problems in procedural compliance or quality controls. Please discuss if the assenions are indicative of any generic problems.
Issue 2; On April 8,1991, a NNECO technician (*) and a contractor were assigned fire protection surveillance, jr' 439A. The NNECO technician had never been trained on the surveillance procedure. 2 April 3,1991, another technician was performing monthly function suneillance SP-2410A for the acoustic valve monitoring system associated with the pressurizer relief valves. This was the first time the technician had performed the surveillance since the last major revision and again, there had been no training on the conduct of the procedures with the incorporated revisions. In both' cases, the technicians experienced difficulty in completing the procedures and numerous questions were raised.
Please discuss the validity of the above assertions. Please discuss employee training prior to performance of complex stuveillances especially in cases involving first time assignment and performance subsequent to major revisions. Please discuss any corrective actions that you have taken or will take in these cases, to ensure that the surveillances are completed competently and safely.
(*) The identity may be obtained from the Senior Resident Inspector.
BUQON-h
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Issue 3; During performance of modification package PDCE M2-90-032, drawing errors were noted for radiation monitor RM-9095. The errors involve the omission of a terminal board between the 120 VAC power supply and the radiation monitor solenoid valve on drawings 25203-39092 sheet 14a,25203-31118 sheet 1, and 25203-32026 sheet 53. In addition to not identifying the drawing errors, the modification package did not identify the need for an equipment tagout.
Please discuss the validity of the above assertions. Please discuss actions that have been taken to correct any deficiencies with the modification package and with work control deficiencies, in general.
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July 10, 1991 Docket No. 50-336 A09594 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 Power Station, Unit No. 2 RI-91-A-0064, Item 1 Ve have reviewed the identified issues concerning activities at Hillstone Unit No. 2 (RI-91-A-0064). In a recent telephone conversation between your Mr.
Scott Stewart and our Licensing staff on June 26, 1991, ve asked for additional time to respond to the issues contained in your letter of i
May 22, 1991, (File Number RI-91-A-0052).
An extension to July 26, 1991, was granted.
The responses to two of the issues in your June 4, 1991, letter (File Number RI-91-A-0064) are related to responses being prepared for the May 22, 1991, letter (RI-91-A-0052). The review of the training issue in-Issue 2 of RI-91-A-0064 is similar to Issue 3 of RI-91-A-0052.
The PDCE referred to in Issue 3 of RI-91-A-0052 is in the process of being closed out.
Additional time is needed to review the close out documentation prior to responding.
Ve did not specifically request an extension in time to respond to Issues 2 and 3 of RI-91-A-0064 during our telephone conversation on June 26, 1991.
Ve now ask that the extension be granted, however, because of the close relationship to issues that vill be addressed in our response to RI-91-A-0052 and the need for more time to permit us to address those issues adequately. The basis for this additional extension was discussed with the NRC Staff on July 10, 1991.
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U. S. Nuclear Regulatory Commission A09594/Page 2 July 10, 1991 The following response addresses only Issue 1.
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 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:
On March 28, 1991 a OC inspector was called by Generation Construction to perform a final veld inspection of a prefabricated structure for the new steam jet air ejector monitor. The final inspection was part of procedure GVS-006.
After the inspection, the OC inspector questioned if a " fit-up" inspection had been completed, as required by procedure. The fabrication and assembly of the structure vere non OA, thus as required by GVS-006, the job supervisor performs the " fit-up" inspection. Based on indication that no " fit-up" inspection had been completed, the OC inspector initiated NCR 2-91-035.
On April 1,
Generation Construction completed the authorized work order and documented that a " fit-up" inspection had been completed;
- however, it had not been completed. This is the way non OA inspection and documentation are normally accomplished.
Please discuss the validity of the above assertions.
Please discuss the need for a " fit-up" inspection and the circumstances surrounding its completion, if required. Please discuss any corrective actions that you have taken or may take in response to any identified problems in procedural compliance or Quality controls.
Please discuss if the assertions are indicative of any generic problems.
Response
This issue involves a non-0A Category I installation of a structural veld for a support. The normal progression of events is that the velder first fits-up the components. A fit-up inspection is then performed by the Job Supervisor to verify correct fit-up, including gap dimension. This is documented on the Inspection Plan. The velder then finishes the veld, using the fit-up information to ensure correct final veld dimensions.
When the OSD inspector was called for the final visual inspection, no obj ective evidence vas available to demenstrate that the fit-up had been performed.
The fit-up vas, in fact, sigimd off three days later, by the Job Supervisor.
Follow-up discussions with all personnel involved could neither clearly substantiate nor disprove the performance of the fit-up inspection, since the fit-up signature vas dated three days after the request for final veld inspection.
Due to the configuration of the support, the fit-up gap could not be adequately reverified. In order to resolve the situation, the conservative position was teken to destroy the support (vitnessed by OSD) and rebuild it.
Mr. Charles V. Hehl, Director l
U. S. Nuclear Regulatory Commission A09594/Page 3 July 10, 1991 Meetings vere held with the departments involved with this work. The i
responsibilities of each department were reviewed. The need to follow procedure requirements and the requirement of the job supervisor to l
document actual fit-up inspections on non-0A Category I structural installations at the time of the actual inspection was stressed.
l After a review of the circumstances surrounding this event and recent experience with fit-up inspections of other non OA Category I structural
[
velding, ve have determined that this event represented a one-time lapse in attention to detail. All personnel involved with this work were aware of the procedure requirements and thought that they were in full compliance with them.
Inattention to detail by a failure to documert a fit-up inspection at the time that it occurred was the root cause of this event.
No further generic problems exist with this portion of our Quality Assurance program and no additional corre"tive action is appropriate.
l After our review and evaluation, ve find that this item does not present l
any indicttion 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, 3
NORTHEAST NUCLEAR ENERGY COMPANY i
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E. J. Krp6zka 47 i
Senior Iice President i
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J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
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August 9, 1991 1
Docket No. 50-336 B13905 Mr. Charles V. Hehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 t
Dear Mr. Hehl:
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RI-91-A-0 ]Sta '
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l Ve have completed our review of identified issues concerning activities at Millstone Station. As requested in your transmittal letter, our response does 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.
In our letter of July 10, 1991 (A09594) addressing Issue 1 of RI-91-A-0064, ve addressed the technical aspects of the prefabricated structure for the new steam jet air ejector monitor. Ve vould like to supplement that information at this time with additional background.
NU vas aware of the situation throughout the entire process. The inspector who questioned. the fit-up inspection, documented the condition on a Non-Conformance Report on March 28, 1991 in accordance with our quality.
program.
Functional line-and station management became involved in the resolution and recommended corrective action options on April 2, 1991.
This is the same date on which the Nuclear Safety Concerns Program (NSCP)
.i vas also contacted on a confidential basis regarding this issue. The NSCP' continued to monitor progress towards resolution via independent contacts on site. This monitoring assured the material, as well as procedural, aspects of the issue vere thoroughly addressed.
The NRC Resident Inspection staff vere apprised of our actions throughout this process.
Subsequent line management review of this situation for generic implications was completed on May 17, 1991, two veeks before the NRC j
Staff's letter vas issued to NNECO.
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Mr. Charles U. Behl, Director l
U. S. Nuclear Regulatory Commission
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B13905/Page 2 August 9, 1991 i
Ve provide the above background information to assure you of our ongoing i
efforts to bring all concerns to prompt and thorough resolution.
i ISSUE 2:
}
On April 8, 1991, a IMECO technician and a contractor vere assigned fire protection surveillance, IC-2439A.
The IMECO technician had never been trained on the surveillance procedure.
On April 3,
1991, another i
technician was performing monthly function surveillance SP-2410A for the acoustic valve monitoring system associated with the pressurizer relief valves.
This vas the first time the technician had performed the surveillance since the last major revision and again, there had been no j
training on the conduct of the procedures with the incorporated revisions.
In both cases, the technicians experienced difficulty in completing the procedures and numerous questions were raised.
Please discuss the validity of the above assertions.
Please discuss employee training prior to performance of complex surveillances especially in cases involving first time assignment and performance subsequent to major revisions.
Please discuss any corrective actions that you have taken or vill take in these cases, to ensure that the surveillances are completed competently and safely.
s
Background:
t A review of the completed data sheets indicates that the Instrumentation and Controls (ILC) procedure was performed competently and safely. The technician assigned to this work had worked on various components of the fire protection system a total of 13 times since February 11, 1987, with the most recent vork effort being May 23, 1991. While working on the system the technician has demonstrated to his management his competence and understanding of the system and individual components.
This technician has worked on the fire protection system both alone and t
vith other members of the shop. When questions have ariren in the past he has not been reluctant to stop and resolve those questions before continuing.
All of the preceding facts led to the decision to assign him to perform the procedure in question.
During the performance of IC 2439A l
there vere no unresolved questions that were brought to the attention of j
I&C supervision.
I6C Procedure SP-2410A i
l Both technicians assigned to perform this surveillance had not received on-the-j ob training (03T) specifically for this procedure revision. They t
were, however, interim qualified due to their past experience la performing the procedure.
Each technician had successfully performed previous j
revisions of the procedure.
Since 1984, one technician had participated in the performance of this procedure 9 times and the other technician 4 times The technician who had performed the procedure 4 times had not done so since 1988.
j i
i Mr. Charles U. Hzhl, Director U. S. Nuclear Regulatory Commission B13905/Page 3 August 9, 1991
Response
The two assertions are accurate. However, it should be noted that it is not NNECO's expectation that all procedures vill be performed without any questions by all workers. Difficulty may be experienced in performing a task that has not been performed for a period of time. Personnel are expected to have a questioning attitude toward their work and are encouraged to seek assistance from others in the shop.
In the case of the surveillances identified, the results of the work have been reviewed and found acceptable.
The procedures vere completed competently and safely.
The personnel involved in these work activities were both Level 2 qualified which allovs them to vork independently on. the majority of Millstone Unit No. 2 systems. The process for training personnel to work on surveillances is to assign less experienced personnel to work with experienced personnel.
This allows for the transfer of knowledge and experience. The OJT program formally documents the training and evaluates. aspects of this practice.
During implementation of the OJT program, experienced personnel are interim qualified to allow their continued participation prior to conducting the OJT activity.
ISSUE 3:
During performance of modification package PDCE M2-90-032, drawing errors were noted for radiation monitor RM-9095. The errors involve the omission of a terminal board between the 120 VAC power supply and the radiation monitor solenoid valve on drawings 25203-39092 sheet 14a, 25203-31118 sheet 1,
and 25203-32026 sheet 53.
In addition to not identifying the drawing errors, the modification package did not identify the need for an equipment tagout.
Please discuss the validity of the above assertions. Please discuss-actions that have been taken to correct any deficiencies with the modification package and with vork control deficienc2es, in general.
Response
ACP-0A-3.14 " Design Change Notices For Design Documents," and ACP-QA-3.24
" Drawing Change / Submittal Requests," provide the necessary guidance to anyone who feels that a drawing change is necessary.
A. review of the Generation Records Information Tracking System (GRITS) shoved no open change records for any of the reported drawings for this PDCE.
Since the design change package is still open, the necessary As-Built drawings-vill be generated as.part of the closure process.
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Mr. Charles V. Hehl, Director U. S. Nuclear Regulatory Commission B13905/Page 4 August 9, 1991 A review of the reported drawings was performed in order to determine exactly what changes might be required to respond to this assertion. No i
deficiencies were apparent.
Unless more specific identification of the l
missing terminal board can be supplied, no corrective action is believed to be required.
The vork consisted of preparation activities and actual work on installed plant equipment. It is our expectation that the AVO vould not initially specify the need for tagout.
Tagout was added prior to the time actual work on the plant equipment was started.
No work control deficiencies were found during this review.
Our review and evaluation finds that the above assertions did not present any indication of a compromise to nuclear safety. Ve vere not aware of these two issues prior to the receipt of the Staff's letter. Ve appreciate the opportunity to respond and explain the basis of our actions. Please contact my staff if there are any further questions on any of these 4
matters.
i Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY I
k}&*V N E.J.'7~odzka' 37 t
Senior Vice President l
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V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1,. 2,
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C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor l
Projects E. M. Kelly, Chief, Reactor Projects Section 4A I
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KING oF PRUsslA, PENNSYLVANIA 19406-1415 OCT 111991 Docket Number: 50-336 Northeast Nuclear Energy Company ATTN:
Mr. John F. Opeka Executive Vice President - Nu;: ear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
Thank you for informing us of the results of your reviews of the concerns listed in the enclosed table. We have performed veriGeation inspections on selected issues. find your responses generally acceptable, and plan no further actims on these issues at this time. This is not to say that further independent reviews of special anc or contested issues will not take place. You will be kept informed of such veriGcation inspections and independent reviews by the normal inspection report process.
A copy of this letter as well as the referenced correspondence is being placed in the Public Document Rooms and sent to the State of Connecticut. We appreciate your cooperation in these matters.
Sincerely, ds;dik i.
n Edward /Venzinger, C Reactof Projects Branch 4
Enclosure:
Table of NU's Responses cc wl encl:
Public Document Room (PDR)
Local Public Document Room (LPDr )
State of Connecticut bcc w! encl:
Allegation File: As Stated in the Enclosure
- W. Raymond/T. Shed!osky E. Conner's Files G. Kelly 0++&W&?ll
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ENCLOSURE NRC NU
RESPONSE
SUBJECT OF ISSUE NUMBER
RESPONSE
DATE i
91-037-1 & 4 A09556 08/09/91 TORQUE WRENCH USE & MOV TORQUE SWITCH BALANCING 91052-1 to 5 A09559 08/09/91 PROBLEMS %TDI PDCE M2-90-032 91-063 A09569 07/01/91 AUX BUILDING ACCESS CONTROL
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91-064-2 to 5 B13905 08/09/91 QC FIT-UP FOR NEW SJAE I
MONITOR 91-069-3 & 4 A09660 OS/16/91 MODIFICAT!ON TAGOUT &
j REVIEW & RM CALIBRATION 91-082-1 to 3 A09604 08/09/91 SG LOOP FOLDER DRAWINGS &
I INSTRUMENTATION 91-093 A09700 08/16/91 RAD MONITOR SURVEILLANCE 91-109 A09632 07/27/91 RAD MONITOR TAGGING ERROR 91-118-1 to 4 A09657 08/16/91 INADEQUATE WORK CONTROL
.l 91-137 A09658 08/16/91 PERSONNEL SAFETY TAGGING B13926 09/16'91 ERROR l 05,16'91
- B* ACID FEED PUMP TAGOUT 91-135 A09655 91-139 A09658 08/16 91
- B* ELECTRO-HYDRAULIC PUMP TAGOUT 91-140 A09658 08/16/91 MOV Lw1T SWITCH TAGOUT 91-142 A09658 08/16/91 CHILLER COMPRESSOR TAGOUT 91-143 A09716 08/16/91 RAD MONITOR AS-BUILT CONFIGURATION I
91-145 A09661 08/16/91 EEQ PROCEDURES i
91-147 A09658 08/16/91 4160 S%TTCHGEAR TAGOUT l
91-14S A09659 08/16/91 WORK CONTROL i
i 91-149 A09658 08/16/91 MOV SAFETY TAGOUT i
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ALLEGATIONS AND COMPLAXNTS - GENERAL RI 2210.1/1 APPENDIX 4.0 SEE RECORD OF ALLEGATION PANEL DECISIONS SITE:
[d1 sh,tM PANEL ATTENDEES:
ALLEGATION NO.: k N -A-0049 Chairman -
DATE: O ut [ T/
(Mtg.h2345)
Branch Chief -
k bCMNaq<f PRIORITY:
High Medium'h Section Chief (AOC) -
kelly (AjhIk-O/I SAFETY SIGNIFICANCE: Yes No Unknown Others -
CONCURRENCE TO CLOSE0VT: DD BC SC CONFIDENTIALITY GRANTED: Yes No (See Allegation Receipt Report)
IS THEIR A DOL FINDING:
Yes No IS CHILLING EFFECT LETTER WARRANTED:
Yes No HAS CHILLING EFFECT LETTER BEEN SENT:
Yes No HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No ACTION:
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ONG 07 FRusslA. PE%sm ANIA 1M06141s J'JL 0:. El Docket Nos. 50 336 File Number RI A &69 Nonheast Nuclear Energy Company ATTN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group 7
W P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently receised information concermng ac kinn at the Millstone Nuclear Power Facility. Unit 2. The details are enclosed for your reueu and l
follow up.
1 We request that the results of your review and disposition of these maners be subm:tted to Region I within 30 days of the date of receipt of this leuer. We request that your response contain no personal privacy. proprietary. or safeguards inforrqtien so it can be released to the public and p! aced in the NRC Public Document Room. If necessary, such information shall be contained in a Feparate attachment which will be withheld from public disclosure.
The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91'-A-00e9 when presiding your response.
The enclosure to this letter shou!d be contro!!ed and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region 1. The enclosure to this letter is considered Exempt from Public Disclosure m accordance with Title 10, Code of Federal Regulations, Part 2.790y. Howeser, a copy of this letter excluding the enclosure will be placed in the NRC Public Document room.
The response requested by this :etter and the accompanying enclosure are not subject to the clearance procedures of the Of6ce of Management and Budget as required bv the Paperuerk Reduction Act of 19S0, PL 96-511.
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Northeast Nuclear Energy Company Your cooperation with us is appreciated. We will gladly discuss any questions you have concerning this information.
Sincerely.
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.t Cha s W. lie, Director Disision of Reactor Projects
Enclosure:
(10 CFR 2.790(a) Information) cc w/o encl:
Public Document Room (PDR)
Local Public Document Room (1.PDR)
State of Connecticut bec a enc 1:
W. Ray mond, SRI..\\li':3one Allegation Fil:, RI A-0069 J. S:esart E. Ke!:y T. Shed!osky
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y-ENCLOSURE lssue In the past, failure to adequately purge and,'or sample for hydrogen when performing calibration activities on RM 9095 has resulted in hydrogen explosions in the radiation
[
monitor cabinet. Speci6cally, Surveillance Procedure SP 2404AH, Revision 2, does not provide the necessary details to appropriately establish or accomplish a hydrogen j
purge when performing calibrations on RM 9095. Additionally, surveillance procedure SP 2404AG does not mention the need to sample for hydrogen, and this sampling is necessary when the detector is removed from the " pig" a
i Request Please discuss the validity of the above assertions. If deficiencies are identified in the applicable procedures, please notify us of the corrective actions you have taken to 3
prevent recurrence. Please provide us with an assessment of the sieniGcance with regard to safety of any identined deficiencies.
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.. co August 16, 1991 Docket No. 50-336 A09660 i
RE: Employee Concerns t
Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road i
King of Prussia, Penns:ylvania 19406 l
[
Dear Mr. Hehl:
Millstone Nuclear Pover Station. Unit No. 2 RI-91-A-0069 We have completed our review of identified issues concerning activities at Millstone Station. As requested in your transmittal letter, our response i
does not contain any personal privacy, proprietary, or safeguards information.
The material contained in this response may be released to l
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 Itnow" basis during the preparation of this response.
ISSUE:
r In the past, failure to adequately purge and/or sample for hydrogen when performing calibration activities on RH 9095 has resulted in hydrogen explosions in the radiation monitor cabinet. Specifically, Surveillance Procedure SP 2404AH, Revision 2, does not provide the necessary details to appropriately establish or accomplish a hydrogen purge when performing calibrations on RM 9095. Additionally, surveillance procedure SP 24U4AG j
does not mention the need to sample for hydrogen, and this sampling is necessary when the detector is removed from the " pig".
i Request:
l l
Please discuss the validity of the above assertions. If deficiencies are i
identified in the applicable procedures, please notify us of the corrective
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actions you have taken to prevent recurrence. Please provide us with an.
assessment of tha significance with regard to safety of any identified deficiencies.
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Background:
SP 2404AH Revision 2 contains the guidance for purging the radiation monitor pig and for verifying by chemistry sample that no hydrogen is present.
SP 2404AG governs the functional test for the radiation monitor and does not specify removal of the detector from the pig.
If any calibration activities are required as a result of the functional test, the urer is directed to procedure SP 2404AH.
Response
The assertion that the surveillance procedure does not contain the necessary level of detail is not accurate. The required steps are included in the procedure and the level of detail is appropriate for the I&C personnel using the procedure. The actual purging activity is performed by Operations personnel. They are aware of the need to properly purge the system to ensure that all residual hydrogen is removed.
The assertion that SP 2404AG specifies removal of the detector from the pig, and therefore also requires guidance on sampling for hydrogen, is not accurate. The procedure governs functional testing activities which do not include detector removal.
After our review and evaluation, ve find that this issue does not present any indication of a compromise of nuclear safety. We vere not aware of this issue prior to receipt of the NRC letter on this subj ect. Ve appreciate the opportunity to respond and explain the basis of our actions.
i Please contact my staff if there are any further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Mroczka Senior Vice President BY:
V. D. Romberg (s'
Vice President 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 Proj ects E. M. Kelly, Chief, Reactor Projects Section 4A
q o
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UNITED STATES
,y q
g NUCLEAR REGULATORY COMMISSION O
j REGloN 1 0,
c 475 ALLENDALE ROAD d'
KING OF PRUSSIA. PENNSYLVANIA 194:6 1415 OCT 111991 Docket Number: 50-336 Northeast Nuclear Energy Company ATTN:
Mr. John F. Opeka Executive Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
Thank you for informing us of the resuhs of your reviews of the concerns listed in the enclosed table. We have performed verificanon inspections on selected issues, find your responses generally acceptable. and plan no further actions on these issues at this time. This is not to say that further independent reviews of sps :id and/or contested issues will not take place. You will be kept informed of such verification inspections and independent reviews by the normal inspection report process.
A copy of this letter as well as the referenced correspondence is being placed in the Public Document Rooms and sent to the State of Connecticut. We appreciate your cooperation in these matters.
Sincerely, O
p, f2/4Qhf z.
y Edward Nenzinger, C React Projects Branch 4
Enclosure:
Table of NU's Responses cc w/ encl:
Public Document Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut bcc w! encl:
Allegation File: As Stated in the Enclosure W. Raymond/T. Shedlosky E. Conner's Files G. Kelly
- /-=b Zg?
v ':
I h
l ENCLOSURE NRC-NU
RESPONSE
SUBJECT OF ISSUE NUMBER
RESPONSE
DATE 91-037-1 & 4 A09556 08/09/91 TORQUE WPINCH USE & MOV TORQUE SWITCH BALANCING 91-052-1 to 5 A09559 08/09/91 PROBLEMS %TTH PDCE M2-90432 91-063 A09569 07/01/91 AUX BUILDING ACCESS CONTROL
[
91-064-2 to 5 B13905 08/09/91 QC FIT-UP FOR NEW SJAE "GNITOR 91-069-3 & 4 A09660 08/16/91 A JIFICATION TAGOUT &
[
REVIEW & RM CALIBRATION 91-082-1 to 3 A09604 08/09/91 SG LOOP FOLDER DRAWINGS &
(
INSTRUMENTATION t
91-093 A09700 08/16/91 RAD MONITOR SURVEILLANCE 91-109 A09632 07/27/91 RAD MONTTOR TAGGING ERROR 91-118-1 to 4 A09657 08/16/91 INADEQUATE WORK CONTROL P
91-137 A09658 08/16/91 PERSONNEL SAFETY TAGGING B13926 09/16'91 ERROR
{
i l91-]35 A09656 OS'16 91
- B* ACID FEED PUMP TAGOUT 91-13; A09655 05/16,91
- B* ELECTRO-HYDRAULIC PUMP TAGOUT 91-140 A09658 08/16/91 MOV LIMIT SWITCH TAGOUT 91-142 A09658 08/16/91 CHILLER COMPRESSOR TAGOUT 91-143 A09716 08/16/91 RAD MONITOR AS-BUILT CONFIGURATION 91-145 A09661 08/16/91 EEQ PROCEDURES91-147 A09658 08/16/91 4160 SWTTCHGEAR TAGOUT 91-148 A09659 08/16/91 WORK CONTROL 91-149 A09658 08/16/91 MOV SAFETY TAGOUT 4
I
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KING oF PROS $1A. PENNSYLVANIA 19406-1415 NOV 0 S 1991 Docket Number: 50-336 Northeast Nuclear Energy Company ATTN:
Mr. John F. Opeka Executive Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
Thank you for informing us of the results of your reviews of the concerns listed in the enclosed table. We have performed verification inspections on selected issues, find your responses generally acceptable, and plan no further actions on these issues at this time. This is not to say that further independent reviews of these issues will not take place in the future. You will be kept infermed of such verification inspections and independent reviews by the normal inspection report process.
A copy of this letter as well as the referenced correspondence is being placed in the Public Document Rooms and sent to the State of Connecticut. We appreciate your cooperation in these 5 ~c:
f e
3%
Edward Wenzinger, Chiefj 'f Reactor Projects Branch'4
Enclosure:
Table of NU's Responses cc w' encl:
Public Document Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut b
h l
4 i
y ENCLOSURE NRC NU
RESPONSE
SUBJECT OF ISSUE NUMBER
RESPONSE
DATE 91-070-1 A09805 09/27/91 NO PLANT INCIDENT REPORT FOR
- D' CIRCULATION PUMP TRIP 91-070-3B MOTOR HEATERS WERE NOT ENERGIZED ON SPARE BORIC ACID PUMP i
91-079 A09768 09/27/91 GAMMA METRICS PROCEDURES 91-113N &
A09699 09/13/91 ABNORMAL STACK RADIATION 91-136 MONITOR INDICATION 91-114-1 REPETITIVE FAILURES OF VENT STACK HIGH RANGE MONITOR 91-114-2 ACCUMULATOR TANK LEVEL CAllBRATION ERROR 91-116 INADEQUATE RWP/HP CONTROLS i
9:- C CLEAN LIQUID RADIATION i
YONITOR T ACC:'M ERROR a:: GT iE?' ::E :~ \\ ^^
C.% ^ L :
IMPROPER ASSIGNMENT OF ON-CALL I&C TECHNICIAN 91-129 VOLUME CONTROL TANK LEVEL EVOLUTION 91-130 WRONG PART FOR LOCAL PRESSURE GAGE 91-162 A09698 09/09/91 UNCALIBRATED/ UNLABELED EXHAUST VENTILATION DUCT MANOMETER 91-163 A09819 09/27/91 WIDE RANGE NUCLEAR INSTRUMENT UNDOCUMENTED SWITCHES 91-165-1 A09703 09/09/91 UNLABELED CRYOGENIC LIQUID i
NITROGEN CONVERTER VALVES 91-165-2 PERMANENTLY CONNECTED -
NOT DEPICTED PUMP f 91 166 A09701 09/13/91 RECOVERY BORIC ACID TANK l
PUMP ISOLATED SW1TCH
Imt t
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L September 27, 1991 Docket No. 50-336 A09805 RE:
Employee Concerns Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission
'r Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Dear Mr. Behl:
Millstone Nuclear Power Station, Unit No. 2 t
RI-91-A-0070 have completed our review of identified issues cencerning activities at Ve Millstone Station. As requested in your transmittal letter, our response any personal privacy, proprietary, or safeguards contain does not The material contained in these responses may be released to information.
the public and placed in the N"; Public Document Room at your discretion.
The NRC transmittal letter and our response have received controlled and limited distribution on a "need to knov" basis during the preparation of this response. Additional time in which to respond to these issues was granted by the Region I Staff in a telephone conversation on September 19, 1991 ISSUE 70-1:
During a recent condenser backvashing evolution on April 12-13, 1991 the "C" circulating vater pump vas tripped by operators.
Concurrently, the "D"
circulating vater pump inadvertently tripped. A plant incident report was not vritten describing this event.
In addition, during the past refueling outage (October 1990) a similar event occurred with no subsequent plant i
incident report.
Request:
Please discuss the validity of this assertion.
If a plant incident report i
vas required, plerse discuss why one vas not vritten.
Please discuss vhether this incident has occurred previously, and if so, why it vas not documented via a plant incident report.
McAo%cE 9/f
Mr. Cherics V. H:hl, Dirceter U. S. Nuclear R:gulotcry Commissica A09805/Page 2 September 27, 1991
Response
In stating that the
'D' circulating vater pump inadvertently tripped on April 13, 1991, the assertion is valid.
In implying that a Plant Incident (PIR) vas required, the assertion is not valid.
Nor is the Report assertion valid in stating that a similar problem occurred in October 1990.
A plant incident report (PIR) vas not necessary for the April 13, 1991 pump trip as the pump vas restarted and a trouble report was submitted to investigate' the reason for the trip.
In reviewing Shift Supervisor (SS) logs from October 1990, ve find no record of a similar pump trip.
The PIR program at Millstone Station is controlled by Administrative Control Procedure (ACP) ACP-0A-10.01 - Plant Incident Report. The purpose of the PIR is to document any situation that requires the involvement of plant management or reporting to an external agency. The guidance given is that a PIR should be initiated if in the judgment of a plant staff pers n, management action or cognizance is required to resolve the incident.
The underlying theme of the PIR procedure is succinctly phrased in the final sentence of Section 1 of the ACP: "If in doubt, it is better to initiate a PIR than to allow a problem to go unattended." The decision to issue a PIR is sometimes clear cut (as in instances where PORC-approved procedures require that a PIR be vritten) but is frequently a judgment call the part of the on-duty Shift Supervisor. The Shift Supervisor is on assisted in such decisions by the guidance in ACP-0A-10.01 and consultation with the Operations Manager or the Unit Duty Officer.
Relative to the unexpected trip of the "D" cire. pump at 0025 on April 13, 1991, there are two criteria given in the ACP vhich might apply:
i d.
Any near miss that could have resulted in a plant trip / scram...
Recurring failures of plant equipment that have a significant effect on e.
plant reliability or operability.
Clearly these two criteria involve judgment on the part of the Shift i
Supervisor, and it is reasonable for the Shift Supervisor on the mid-shift on April 13,
- 1991, to have decided against a PIR, and to ask the Duty Officer and Operations Manager in the morning whether a PIR vas desired.
A Trouble Report (TR) on the condition was submitted, and the pump trip vas discussed with management the following morning. In response to the TR, a Services.
faulty timer was identified and corrected by Generation Test
Background:
In the refuel outage of 1990, Generation Test Services, during routine
- testing, identified a bad timer in the
'D' circ. pump.
The timer was repaired and since the timers vere starting to fail, replacement timers ordered. The timers ordered in late 1990 vere received in the spring vere1991 and one was used to replace the timer that f ailed in the C pump in of l
i
t 7"
Mr. Charlos V. B-hl, Director
.g U. S.' Nuclear Regulatory Commission A09805/Page 3-September 27, 1991 i
early April 1991.
Vendor information concerning an expected 10-year j
service life which was provided in response to the order, resulted in our ensure that these timers i
establishing a preventive maintenance program to i
are replaced after being in service for 8 years.
i While ve vere aware of the pump trip at issue ve vere not avare that this.
vas a concern until receipt of the NRC transmittal letter.
l ISSUE 70-3b:
I was noted, during a preventive maintenance on the spare boric acid pump It motor located in the varehouse, that the motor heaters were not energized to keep the vindings at least 5 degrees F above ambient as is required on
.j the FM card.
Bequest:
i Please discuss the validity of this assertion.
Please discuss actions taken to ensure the proper performance of FMs on equipment in storage.
l l
t
Response
i The assertion as stated is valid. Ve vere informed of this issue via a l
note on the preventive maintenance (PM) Automated Vork Order (AVO)'vhich vas completed on April 4,
1991. The note indicated that the FM vas unsatisfactory because the motor casing temperature vas not 5 P above the
'[
ambient temperature due to the fact-that the motor heaters vere not j
energized.
i I
On April 8, 1991, an AVO was generated to maxe the necessary connections to energize the motor heaters for the spare boric acid pump motor. The work l
30, 1991. The delay in completing the work resulted i
completed on May vas moving the motors near enough to'a power source that could be used to from energize the heaters.
1 the July 3, 1991, preventive maintenance performed on the spare boric For acid pump motor (AVO M2-90-16027), the motor had been relocated, the motor
-l no I
heaters were energized and the FM vas completed satisfactorily with i
outstanding items.
.6 I
as the pump in question is received on site it is j
Vhen equipment such stored in varehouse facilities qualified for storage of Category I electrical equipment in accordance with the requirements of ACP-0A-4.04-l Instructions for Packaging, shipping, Receiving, Storage, and Handlir.g.
Equipment is placed in the PH program to ensure that the~ proper maintenance l
1s carried out until it is placed in service. That the vindings vere not energized as soon as the pump vas received and placed in storage was an i
oversight which vas corrected by the PM program.
i I
Mr. Charles V. 5:hl, Director U. S. Nuclear Regulatory Commission A09805/Page 4 September 27, 1991 The resistance readings recorded during each of the PM activities indicated that the motor insulation resistance was within specifications. Based on the storage environment and the insulation resistance readings, there is reasonable assurance that there was no deleterious effect on the motor from being stored with its motor heaters de-energized. As can be seen from the ve completed all appropriate actions to ensure the above chronclogy, of the boric acid pump prior to receipt of your letter on this operability matter.
After our review and evaluation of this issue, we find that these issues did not present any indication of a compromise of_ nuclear safety.
Ve appreciate the opportunity to respond and explain the basis of our actions.
Please contact my staff if there are further questions on any of these matters.
Very truly yours.
NORTEEAST NUCLEAR ENERGY COMPANY
/
'ctka 4/
E.J.My/icePresident Senior cc:
V.
J. Eay.ond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Ven::nger, Chief, Irojects Branch No.
4, Division of Reactor Projects E. M. Kelly, Chief, Reactor Projects Section 4A J. T. Shedlosky, NRC, Millstone Nuclear Power Station
F ALLEGATIONS AND COMPLAINTS - GENERAL RI 1210.1/1 APPENDIX 4.0 SE:E RECORD OF ALLEGATION PANEL DECISIONS SITE:
\\
S es L PANEL ATTENDEES:
ALLEGATION NO.: @ ld l-4-007O Chairman -
CATE: /7 dpr 9I (Mtg. h 3 4 5)
Branch Chief -
E c Wem ;a-c,<.4 PRIORITY:
High Medium Low Section Chief (AOC) -
kdd9 SAFETY SIGNIFICANCE: Yes No Unknown Others -
tida4E (1) 5k 0 l7, CONCURRENCE TO CLOSEOUT: DD BC SC CONFIDENTIALITY GRANTED: Yes No (See Allegation Receipt Report)
IS THEIR A DOL FINDING:
Yes No IS CHILLING EFFECT LETTER WARRANTED:
Yes No HAS CHILLING EFFECT LETTER BEEN SENT:
Yes No HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No ACTION:
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NOTES:
A4-1
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AUG 1 1991 Docket Number:
50-336 File Number:
RI-91-A-0070 Nonheast Nuclear Energy Company ATTN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received information concerning activities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and followup.
We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the date of receipt of this letter. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such information shall be contained in a separate attachment which will be withheld from public disclosure. The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information is included. Please refer to file number RI-91-A-0070 when providing your response.
The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public Document room.
The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
I OFFICIAL RECORD COPY
. }D9b30(0l D
.i Northeast Nuclear Energy Company 2
Your cooperation in this matter will be appreciated. We will gladly discuss any questions you have concerning this information.
Sincerely, t
Charles W. Hehl, Director Division of Reactor Projects
+
Enclosure:
10 CFR 2.790(a)Information Issues and Requests cc w/o encl:
Public Document Room (PDR)
Local Public Document Room (LPDR) l State of Connecticut bec w/ encl:
W. Raymond, SRI, Millstone Allegation File, RI-91-A-0070 E. Conner E. Kelly T. Shedlosky EG&G Idaho Representative (KIDO) i i
k Concurrence:
RI RP l
RI:DRP I:DRP P
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UNITED STATES f
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=E
- j REGloN 1 0,
c 475 ALLENDALE ROAD
,e*
KING OF PRUSSIA. PENNSYLVANIA 19406-1415 AUG 141991 Docket Number:
50-336 File Number:
RI-91-A-0070 Northeast Nuclear Energy Company ATTN:
Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received information concerning activities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and followup.
We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the date of receipt of this letter. We request that your_ response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such information shall be contained in a separate attachment which will be withheld from public disclosure. The affidavit required by 10 CFR 2.790(b) must accompany your response if proprietary information'is included. Please refer to file number RI-91-A-0070 when providing your response.
The enclosure to this letter should be controlled and distribution limited to personnel with a-
"need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code viFederal Regulations, Part 2.790(a). However, a copy of this letter excluding the encbsure will be placed in the NRC Public Document room.
The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
A
_go lt3Df01 g c
j
t-r 1
Nonheast Nuclear Energy Company.
.2 Your cooperation in this matter will be appreciated. We will gladly discuss any questions you have conceming this information.
Sincerely, f
v' Ch
- s W. Hehl, irector Division of React r Projects
Enclosure:
10 CFR 2.790(a) Information Issues and Requests I
cc w/o encl:
i Public Dc.cument Room (PDR)
Local Public Document Room (LPDR)
State of Connecticut
_ dee w/ encl:
W. Raymond, SRI, Millstone Allegation File, RI-91-A-0070 E. Conner E. Kelly T. Shedlosky EG&G Idaho Representative (KIDO)
?
i e
LIMITEllDISTRIBUTION<NOT-FOR2UBLIC DISCLOSURES v
-t ENCLOSURE l
Issue 70-1:
l During a recent condenser backwashing evolution on April 12-13, 1991 the "C" circulating water pump was tripped by operators. Concurrently, the "D" circulating water pump inadvenently tripped. A plant incident report was not written describing this event. In addithn. During the past refueling outage (October 1990) a similar event occurred with no i
subsequent plant incident report.
f Request:
Please discuss the validity of this assertion. If a plant incident repon was required, please discuss why one was not written. Please discuss whether this incident has occurred previously, and if so, why it was not documented via a plant incident report.
Issue 70-3b:
It was noted, during a preventive maintenance on the spare boric acid pump motor located in the warehouse, that the motor heaters were not energized to keep the windings at least 5 degrees F above ambient as is required on the PM cara.
t Request:
Please discuss the validity of this assertion. Please discuss actions taken to ensure the proper performance of PMs on equipment in storage.
t 1
l i
Enclosure Page I LIMITED DISTRIBUTIONyNOT FOR PUBUDDISCLOSURE/
s-s_-
n-t
r-s
'd 19
-s L
NORTHEAST UTILITIES Genem on<ces. semen suen seoin. connecucur em0,u,w m we
}
, u. : w w~
P O BOX 270 e.-.m*****
HARTFORD. CONNECTICUT 06141-0270
$2[-$2,$~~,
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L J
September 27, 1991 Docket No. 50-336 A09805 RE: Employee Concerns Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 1
Dear Mr. Hehl:
Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0070 Ve have completed our review of identified issues concerning activities at Millstone ' Station. As requested in your transmittal letter, our response does 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 transmittal letter and our response have received controlled and limited distribution on a "need to know" basis during the preparation of this response. Additional time in which to respond to-these issues was granted by the Region I Staff in a telephone conversation on September 19, 1991 ISSUE 70-1:
During a recent conuenser backvashing evolution on April 12-13, 1991 the "C" circulating water pump was tripped by operators. Concurrently, the "D" circulating vater pump inadvertently tripped. A plant incident report was not written describing this event. In addition, during the past refueling outage (October 1990) a similar event occurred with no subsequent plant incident report.
Request:
Please discuss the validity of this assertion. If a plant incident report was required, please discuss why one vas not written.
Please discuss whether this incident has occurred previously, and if so, why it was not documented via a plant incident report.
A
$1b103009L Tf s
f s
Mr. Charles U. Hahl, Director U. S. Nuclear Rrgulatory Commission l
A09805/Page 2
{
September 27, 1991 C
Response
l ll In stating that the
'D' circulating vater pump inadvertently tripped on April 13, 1991, the assertion is valid. In implying that a Plant Incident l
Report (PIR) vas required, the assertion is not valid.
Nor is the l
assertion valid in stating that a similar problem occurred in October 1990.
A plant incident report (PIR) was not necessary for the April 13, 1991 pump trip as the pump was restarted and a trouble report was submitted to l
investigate the reason for the trip.
In reviewing Shift Supervisor (SS) logs from October 1990, we find no record of a similar pump trip.
j i
The PIR program at Millstone Station is controlled by Administrative
{
Control Procedure (ACP) ACP-0A-10.01 - Plant Incident Report. The purpose j
of the PIR is to document any situation that requires the involvement of plant management or reporting to an external agency. The guidance given is that a PIR should be initiated if in the judgment of a plant staff person, l
management action or cognizance is required to resolve the incident.
The underlying theme of the PIR procedure is succiactly phrased in the I
final sentence of Section 1 of the ACP: "If in doubt, it is better to initiate a PIR than to allow a problem to go unattended." The decision to issue a PIR is sometimes clear cut (as in instances where PORC-approved j
procedures require that a PIR be written) but is frequently a judgment call
[
on the part of the on-duty Shift Supervisor. The Shift Supervisor is l
assisted in such decisions by the guidance in ACP-QA-10.01 and consultation j
vith the Operations Manager or the Unit Duty Officer.
Relative to the unexpected trip of the "D" cire. pump at 0025 on April 13, 1991, there are two criteria given in the ACP vhich might apply:
[
d.
Any near miss that could have resulted in a plant trip / scram...
e.
Recurring failures of plant equipment that have a significant effect on plant reliability or operability.
[
Clearly these two criteria involve judgment en the part of the Shift i
Supervisor, and it is reasonable for the Shift Supervisor on the mid-shift l
on April 13,
- 1991, to have decided against a PIR, and to ask the Duty t
Officer and Operations Manager in the morning whether a PIR vas desired. A l
Trouble Report (TR) on the condition was submitted, and the pump trip vas discussed with management the following morning. In response to the TR, a l
faulty timer was identified and corrected by Generation Test Services.
l
Background:
In the refuel outage of 1990, Generation Test Services, during routine
- testing, identified a bad timer in the
'D' cire. pump.
The timer was repaired and since the timers vere starting to fail, replacement timers vere ordered. The timers ordered in late 1990 vere received in the spring of 1991 and one was used to replace the timer that failed in the C pump in
c Mr. Charles V. Hehl, Director U. S. Nuclear Regulatory Commission A09805/Page 3 September 27, 1991 early April 1991.
Vendor information concerning an expected 10-year i
service life which was provided in response to the order, resulted in our establishing a preventive maintenance program to ensure that these timers are replaced after being in service for 8 years.
l vhile ve vere aware of the pump trip at issue ve vere not aware that this was a concern until receipt of the NRC transmittal letter.
ISSUE 70-3b:
It was noted, during a preventive maintenance on the spare boric acid pump motor located in the varehouse, that the motor heaters were not energized to keep the vindings at least 5 degrees F above ambient as is reouired on the PM card.
i Request:
Please discuss the validity of this assertion.
Please discuss actions taken to ensure the proper performance of PMs on equipment in storage.
Response
The assertion as stated is valid. Ve vere informed of this issue via a note on the preventive maintenance (PM) Automated Vork Order (AVO) which was completed on April 4,
1991. The note indicated that the PH vas unsatisfactory because the motor casing temperature was not 5 P above the
~
ambient temperature due to the fact that the motor heaters were not l
energized.
I On April 8, 1991, an AVO vas generated to make the necessary connections to energize the motor heaters for the spare boric acid pump motor. The work i
vas completed on May 30, 1991. The delay in completing the work resulted from moving the motors near enough to a power source that could be used to l
i energize the heaters.
For the July 3, 1991, preventive maintenance performed on the spare boric acid pump motor (AVO M2-90-16027), the motor had been relocated, the motor heaters were energized and the PM was completed satisfactorily with no outstanding items.
When equipment such as the pump in question is received on site it is stored in varehouse facilities qualified for storage of Category I electrical equipment in accordance with the requirements of ACP-0A 4.04-Instructions for Packaging, Shipping, Receiving, Storage, and Handling.
Equipment is placed in the PM program to ensure that the proper maintenance j
is carried out until it is placed in service. That the vindings were not energized as soon as the pump vas received and placed in storage was an oversight which vas corrected by the PM program.
8 l
l
[
I Mr. Charles V. Hehl, Director U. S. Nuclear Regulatory Commission A09805/Page 4 September 27, 1991 j
f The resistance readings recorded during each of the FM activities indicated that the motor insulation resistance was within specifications. Based on the storage environment and the insulation resistance readings, there is reasonable assurance that there vas no deleterious effect on the motor from being stored with its motor heaters de-energized. As can be seen from the above chronology, ve completed all appropriate actions to ensure the operability of the boric acid pump prior to receipt of your letter on this matter.
After our review and evaluation of this issue, we find that these issues did not present any indication of a compromise of nuclear safety.
Ve appreciate the opportunity to respond and explain the basis of our actions.
Please contact my staff if there are further questions on any of these c
matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY l rcM24/
E.J.Mp'cika j/
Senior vice President cc:
W.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor d
Projects E. M. Kelly, Chief, Reactor Projects Section 4A J. T. Shedlosky, NRC, Millstone Nuclear Power Station l
l l
1 A
1 d