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O R 0 9 1331 Docket Nos. 50-336 File Number RI-91-A-0093 Northeast Nuclear Energy Company AlTN:
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 receised information concerning actisities at the Millstone Nuclear Power Facility, Unit 2. The details are enclosed for your review and follow up.
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 i
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 afEdavit required by 10 CFR 2.790(b) must accompany your response if proprietary 1
information is included. Please refer to file number RI-91-A-0093 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 resiewed by SRC Region 1. The enclosure to this letter is considered Exempt from Public Disclosure m 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 Of6ce of Management and Budget as required by the Paperwork Reduction Act of 19SO, PL 96-511.
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HUBBARD92-162 PDR
Northeast Nuclear Energy Company 2
Your cooperation with us is appreciated. We will gladly discuss any questions you hase concerning this information.
Sincerely, rs N ji hhe C
Cha. es W. Heh}i, bwirectori 1
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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
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W. Raymond, SRI,31illstone Allegation File, RI-91-A-OlGP co93 J. Stewart E. Kelly i
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ENCLOSURE Issue l
While performing a review of surveillance procedure SP 2404AG (Waste Gas Monitor Functional Test) data, it was noted that the acceptance criteria contained in SP
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2404AG differs from the acceptance criteria specified in the vendor's technical 1
manual. Specifically, the vendor's technical manual states that correct operation of the upscale check system is determined by obtaining a counting level at least equal to that of the check source. However. section 6.2 of SP :2404AG specifies acceptance criteria as: "The Acceptance Criteria is that the Upscale Check is greater than Background, not that a specific increase occurs." The surveillance is therefore incomplete and the operability of the monitor may be in doubt.
Request l
If any deficiencies regarding the Please discuss the validity of the above assertions.
technical accuracy of procedures or the operability of technical specification radiation monitors are identified, please provide us with the corrective actions you have taken.
to prevent recurrence. Please provide us with an assessment of the significance with l
regard to safety of any identified deficiencies, j
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JUL 0 91991 Docket Nos. 50-336 File Number RI-91-A-0093 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-0093 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 c!carance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
OFFICIAL RECORD COPY k
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Your cooperation with us is appreciated. We will gladly discuss any questions you have concerning this information.
i Sincerely, OrSr:f Signed By
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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-0103 ce 93 J. Stewart E. Kelly T. Shedlosky, Millstone RI:DRP RI:DRP RI:DRP RI:DRP
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,e f}L 60kb k;;g3 W1 Docket No. 50-336 l77 Mr. E. J. Mroczka
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Senior Vice President - Nuclear Engineering and Operations j g 7' Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
Subject:
Millstone Unit 2 Inspection Number 50-336/91-19 This letter refers to the special inspection conducted by Dr. Jason C. Jang of this office on of activities authorized by NRC License Number DPR-65, and to the July 22-24,1991 discussions of our findings held by Dr. Jang with Mr. J. Keenan and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region I Inspection Repon which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and '
4 observations by the inspector.
Within the scope of this inspection, very good routine radioactive gaseous and liquid effluent control programs were implemented by the Chemistry Department. Excellent management support to maintain the radiation monitoring system integrity and operability was also n during this and previous inspections. No violations or deviations.were identified during inspection.
No reply to this letter is required. Your cooperation with us in this matter is appreciated.
Sincerely, 7
es H. Joyner,Ehief.
Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards
Enclosure:
NRC Region I Inspection Report Number 50-336/91-19 9y
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i R. M. Kacich, Manager, Nuclear Licensing S. E. Scace, Nuclear Station Director, Millstone
- F J. S. Keenan, Nuclear Unit Director, Millstone Unit 2 Gerald Garfield, Esquire K. Abraham, PAO (2) -
Public Document Room (PDR)
-l Local Public Docununt Room (LPDR)
NRC Resident Inspector State of Connecticut Nicholas Re nolos Esquire Nuclear Saf ty-In onnation Center (NSIC) f bec w/ encl: -
l Region I Docket Room (with concurrences) 1 Management Assistant, DRMA (w/o encl) t E. Wenzinger, DRP E._ Kelly, DRP W. Raymond, SRI. Millstone J. Shedlosky, SRI, Haddam Neck S. Stewart,- DRP IK'Comner, DRP J. Joyner, DRSS R. Arrighi, DRP R. Fuhrmeister, RA
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Repon Number 50-336/91-19 g
Docket Number 50-336 b
License Number DPR-65 Licensee:
Northeast Nuclear Enerev Comoany P.O. Box 270 Hanford. Connecticut 06141-0270 P
Facility Name:
Millstone Nuclear Generatine Station. Unit 2 r
. aterford. Connecticut W
Inspection At:
Inspection Conducted:
July 22-24.1991
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k Inspector Date J.
. Jang, Sr. Radiation @ialist fluents Radiation Protection Section (ERPS)
I acilities Radiological Safety and Safeguards Branch (FRS&SB)
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R J. Bores,ph(ief, ERPS, FRS&SB Date Division of Radiation Safety and Safeguards S ecial, announced inspection of the licensee's radioactive liquid Insoection Summaty; P
and gaseous effluent control programs including: calibration and functional test of radioactiv liquid and gaseous effluent / process radiation monitoring systems (RMS), and implementati of the Offsite Dose Calculation Manual.
Results:
Very good routine radioactive liquid and gaseous effluent control programs were implemented by the Chemistry Department. A very good program to calibrate the effluent / process radiation monitors was also implemented by the I&C Department. Excellent management support to maintain the radiation monitoring system integrity and operability was also noted during this inspection. Within the areas inspected, no violations or deviations were identified.
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e DETAILS 1.0 IndMduals Contacted 1.1 Licensee Personnel
- J. Becker, I&C Manager R. Crandall, Supervisor, Radiological Assessment Branch T. Itteilag, Unit 2 Chemistry Supervisor J. Kangley, Senior Engineer, Chemistry Department J. Keenan, Unit 2 Director P. Smith, Unit 2 I&C Supervisor 1.2 NRC Personnel P. Habighorst, Resident Inspector W. Raymond, Senior Resident Inspector Denotes personnel who attended that exit meeting on July 24,1991.
Other licensee employees were also contacted or interviewed during this inspection.
2.0 Purpose The purpose of this special inspection was to review the licensee's programs for the areas of liquid and gaseous effluent controls, including calibration of the effluent and process radiation monitoring systems (RMS); implementation of the Offsite Dose Calculation Manual (ODCM); and assessment of environmental impact and public health and safety.
3.0 Calibration of Effluent / Process Radiation Monitorine Systems The inspector reviewed the licensee's most recent calibration and functional test results for the following liquid and gaseous effluent / process radiation monitors, and for the following effluent flow instrumentation to determine the implementation of the Technical Specification (~IS) requirements.
o High Range Stack Gas Radiation Monitor (RM-8186) o Normal Range Stack Gas Radiation Monitor (RM-8132B) o Waste Gas Process Radiation Monitor (RM-9095) o Containment Gaseous Process Radiation Monitor (RM-8123B) o Steam Jet Air Ejector Gaseous Radiation Monitor (RM-5099) o Aerated Liquid Radwaste Process Radiation Monitor (RM-9116)
3 o Clean Uguid Radwaste Process Radiation Monitor (RM-9094) o Steam Generator Blowdown Uquid Process Radiation Monitor (RM-i 4262) l o Waste Neutralization Sump Radiation Monitor (RM 245) o Reactor Building Closed Cooling Water Uguid Process Radiation Monitor (RM-6038) o Effluent Flow Instrumentation
- Stack Flow Instrumentation (F-8412)
- Aerated Uguid Flow Instrumentation (F-9118)
- Clean Uquid Flow Instrumentation (F-9050)
Waste Neutralization Sump Flow Instrumentation (F-246)
The I&C Department had the responsibility to perform electronic and radiological calibrations for the above monitors, and to perform calibrations of the above effluent flow instrumentation. All reviewed results were within the licensee's acceptance criteria. The licensee performed calibrations and functional testss for the above radiation monitors more frequently than required by the TS as shown the following table.
RMS/ Flow Inst. TS Reauirement Ucensee's Performance Calibration Functional Test Cahbration Functional Test RM-8186 Refueling Monthly Refueling Monthly RM-8132B Refueling Quarterly Quanerly Monthly RM 9095 Refueling Quanerly Quarterly Monthly RM-8123B Refueling Quanerly Annually Monthly RM-5099 Refueling Quarterly Quanerly Monthly RM-9116 Refueling Quarterly Quarterly Monthly RM-9094 Refueling Quarterly Ouanerly Monthly 1
RM-4246 Refueling Quarterly Quarterly Monthly RM-245 Refueling Quanerly Quarterly Ouanerly RM-6038 Refueling Quarterly Ouanerly Monthly F-8412 Refueling Not Required Quarterly Ouarterly F-9118 Refueling Quarterly Quarterly Quarterly F-9050 Refueling Quarterly Quarterly Quarterly F-246 Refueling Quarterly Quarterly Quarterly During the review of the high range stack gas radiation monitor calibration results, the inspector noted that the licensee upgraded Procedure SP 2404AR, " Unit 2 E
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Stack Gaseous High Range Radiation Monitor, RM-8186, Functional Test" on July 12,1991. Therefore, the licensee will determine the accuracy between meter, computer, and chart recorder rather than chart recorder during the monthly functional test. This item was recommended by the Radiological Assessment Branch (RAB), Nuclear Engineering Department during the RMS Phases I and II Audits conducted in December 1988 and November 1989, respectively. Based on these audits, the RAB and the licensee issued the Radiation Monitor Manual (see combined Inspection Report Nos. 50-245/90-18,50-336/90-20, and 50-423/90-18 for details). The inspector noted that calibration (performed on January 12, 1990) and functional test (perform on June 26,1991) results for the high range stack gas radiation monitor were within the licensee's acceptance criteria. The inspector stated that the determination of the accuracy between meter, computer and chart recorder will be reviewed during a subsequent inspection. The inspector also noted that this monitor was out of senice as of July 16,1991 due to failure of the power supply. The licensee stated that the replacement power supply was delivered on July 23,1991 and will be installed within a week. The licensee also stated that the reliability and operability of the high range stack gas radiation monitor will be followed closely. It should be noted that this high range stack radiation monitor was installed to monitor potential releases in the event of an accident. All Unit 2 gaseous effluents are released through the Unit I stack i
during any accident.
The inspector noted that the licensee's calibration technique for the above radiation monitors was excellent. Radiological calibrations of these monitors were performed as the primary calibration (same monitoring geometry with National Institute of Standards and Technology traceable radionuclides: Cs-137 for the liquid monitors and Kr-85 for the gaseous monitors). The inspector discussed with the licensee the benefit of the current calibration technique versus using solid sources (button sources), because the primary calibration technique requires many extra steps during the calibration. The inspector stated that using button sources is very common after the primary calibration (See ANSI N13.10-1974,
' Specification and Performance of On-site Instrumentation for Continuously Monitoring Radioactivity in Effluents' for details) and is acceptable to the NRC.
i Based on the above review. the inspector determined that the licensee conducted an excellent program to calibrate the effluent / process radiation monitors.
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Or>erability and Reliability of Radiation Monitoring Systems (RMS) 4.0 Contamination of the liquid effluent monitor sample chamber is a generic problem throughout the nuclear industry. Radioactive materials will plate out on the sample chamber resulting in increased background levels. Currently there is no optimum solution. The most common practice throughout the industry is flushing the sample chamber using clean water after radioactive liquid releases to reduce background. Occasionally the sample chamber is cleaned using decontamination solution, or the chamber is replaced if the background level is too high to obtain 4
the required monitor sensitivity. During cleaning or replacement of the chamber, additional grab samples are taken and analyzed to satisfy the TS requirement for sampling liquid effluent prior to release.
The inspector reviewed the licensee's draft investigation results regarding a high background level [as high as 12,000 counts per minute (CPM)] for the steam generator blowdown radiation monitor on May 13, 1991. The investigation results i
demonstrated that the actual background level (electronic noise in the RMS, ambient background, and contamination of the sample chamber) was 5,500 CPM and the actual blowdown activity was 6,500 CPM. The licensee also calculated and demonstrated that 6,500 CPM correlated well with the latest monitor calibration curve and measured blowdown grab sample activity of about 10E-5 microcuries/cc (uCi/cc) during that time period. Based on the above licensee's investigation results, the inspector had no further questions in this matter.
Although the calibration results were within the acceptance criteria, one should perform the systematic trending analysis (RMS results versus measured effluent sample activity) to assess the RMS reliability. To track the reliability of radioactive liquid and gaseous efDuent monitors, the RAB and Chemistry Department initiated the trending analysis in late 1990. The inspector conducted an independent evaluation during this inspection to determine the reliability. The
.l inspector observed the actual radioactive liquid release process performed by the Operations and Chemistry (Liquid Dis:harge Permit Number 2283) on July 23, 4
1991. A grab sample counting result using a Ge gamma spectrometry system was 4.03E-5 uCi/cc for activation / fission products (about 2% of total activity and dominated by Sb-124) and 1.79E-3 uCi/cc for noble gases (about 98% of total activity and dominated by Xe-133). The inspector expected the RMS response would be higher than the grab sample result due to the contribution of noble gases (98%) and small contribution of Cs-137 activity (about 4.5% of total activation / fission products). The licensee used Cs-137 for the calibration. The net radiation monitoring result (RM-9094) was 27,000 CPM. The inspector converted this net monitoring result to activity, as uCi/cc, using a conversion factor
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6 (CPM /uCi/cc) of RM-9094 and compared the result to a grab sample result. The comparison between the monitoring results and the grab sample indicated that the monitoring result was higher by about a factor of 2, as expected). The inspector also compared gaseous effluent monitoring results against grab sample measurement results for 1991 and the comparisons were good.
Based on the observation and independent evaluation, the inspector determined that the RM-9094 was operable and reliable. The inspector stated that the licensee's trending analysis was an excellent tool to trend the operability and reliability of the RMS.
5.0 R.sdioactive Liouid and Gaseous Effluent Control Programs The inspector reviewed selected licensee's procedures and radioactive liquid and gaseous discharge permits to determine the implementation of the TS and the Offsite Dose Caiculation Manual (ODCM). The selected radioactive liquid and l
gaseous discharge permits were completed and dose projections were made prior to discharge as required. The inspector also determined that the reviewed discharge permits met the TS requirements for sampling and analyses at the frequencies and lower limit of detections established in the TS.
t Based on these reviews, the inspector deten lined that the licensee has conducted an effective radioactive liquid and gaseous effluent control programs.
6.0 Assessment The licensee has experienced daily routine difficulties, such as high background problem for the effluent monitors, purchasing of monitoring system components, and procedure upgrading in the effluent control programs. Despite of all these daily routine dif5culties and corrective actions, and based on this inspection results, the inspector determined that the licensee has conducted an excellent effluent control program and there were no impacts on either the environment or the public health and safety.
7.0 Exit Interview The inspector met with the licensee representatives denoted in Section 1.1 of this inspection report at the conclusion of the inspection on July 24,1991. The inspector summarized the purpose, scope, and findings of the inspection.
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g (203) 665-5000 w w w., e-w.s u-August 16, 1991 Docket No. 50-336 A09700 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
Dear Mr. Hehl:
t Millstone Nuclear Pover Station, Unit No. 2 RI-91-A-0093 t
t Ve have-completed our review of the identified issues concerning activities f
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 this response may be released to I
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 knov" basis during the preparation of this response.
ISSUE:
While performing a review of surveillance procedure SP 2404AG (Vaste Gas Monitor Functional Test) data, it was noted that the acceptance criteria contained in SP 2404AG differs from the acceptance criteria specified in the vendor's technical manual. Specifically, the vendor's technical manual states that correct operation of the upscale chsck system is determined by_
obtaining a counting level at least equal to that of the check source.
- However, Section 6.2 of SP 2404AG specifies acceptance criteria as: "The' Acceptance Criteria is that the Upscale Check is greater than Background,,
not that a specific increase occurs." The surveillance is therefore
'I incomplete and the operability of the monitor may be in doubt.
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Mr. Charics V. B;hl, Dircetor y
U. S. Nuclcar R:gulatory Commission A09700/Page 2 August 16, 1991 Request:
Please discuss the validity of the above assertions.
If any deficiencies regarding the technical accuracy of procedures or the operability of technical specification radiation monitors are identified, please provide us with the corrective actions you have taken to prevent recurrence.
Please provide us with an assessment of the significance with regard to safety of any identified deficiencies.
Response
This question was reported to us via an Interoffice Memorandum dated May 4, 1991.
The question was answered by a memorandum dated May 14, 1991. The acceptance criteria vere reviewed and found acceptable for a source check type of surveillance. This issue had been addressed previously with NRC reviewers as part of the implementation of the Radiological Effluent Technical Specifications. The acceptance criteria vere developed based on these discussions. The PORC-approved procedure takes precedence over the vendor technical manual.
The technical manual contains generic recommendations that, in this case, are not applicable and have been superseded by the PORC-approved procedure. Additional review by the NUSCO Radiological Analysis Branch confirmed this assessment. There vere no deficiencies identified as a resul sf this review.
After our review and evaluation, we find that this issue did not present any indication of a compromise of nuclear safety. Ve received this issue from one of our employees, evaluated the situation and provided a response to the employee within 10 calendar days. Technical specialists from NUSCO vere involved in the preparation of the response. 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 matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY POR:
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 Projects E. M. Kelly, Chief, Reactor Projects Section 4A l
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KING OF PRUSSIA, PENNSYLVANIA 19406 1415 OCT 111991' Docket Number: 50-336 Northeast Nuclear Energy Company ATTN:
Mr. John F. Opeka Executive Vice President - Nuc? ear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 061a1-0270
Dear Mr. Opeka:
Thank you for informing us of the resu:s of your reviews of the concerns listed in the enclosed table. We have performec verificatica inspections on selected issues, 6nd 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 special and/or contested issues will not take place. You will be kept informed of such veri 6 cation 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, E,a///h#.
n 8 Edward Venzinger, 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!cncl:
Allegation File: As Stated in the Enclosure Y'
Raymond/T. Shediosky E. Conner's Files G. Kelly E-%( '.h (f
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l ENCLOSURE NRC NU
RESPONSE
SUBJECT OF ISSUE NUMBER
RESPONSE
DATE
'l-037-1 & 4 A09556 08/09/91 TORQl'S WRENCH USE & MOV TORQUE. ;WTTCH BALANCING 91-052-1 to 5 A09559 08/09/91 PROBLEMS WITH 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 MONITOR 91-069-3 & 4 A09660 08/16/91 MODIFICATION TAGOUT &
f REVIEW & RM CALIBRATION 91-082-1 to 3 A09604 08/09/91 SG LOOP FOLDER DRAWINGS &
INSTRUMENTATION 7
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A09700 08/16/91 RAD MONITOR SURVEILLANCE T1 A09632 07/27/91 RAD MONITOR TAGGING ERROR 91-118-1 to 4 A09657 08/16/91 INADEQUATE WORK CONTROL 91-137 A09658 08/16/91 PERSONNEL SAFETY TAGGING B13926 09/16/91 ERROR 91-13F A09655 CEr16'91
- B' ACID FEED PUMP TAGOUT 91-139 A09655 05/16:91
- B* ELECTRO-HYDRAULIC PUMP TAGOUT 91-140 A09658 08/16/91 MOV LIMIT SWITCH TAGOUT i
91-142 A09658 08/16/91 CHILLER COMPRESSOR TAGOUT 91-143 A09716 08/16/91 RAD MONITOR AS-BUILT l
CONFIGURATION l
91-145 A09661 08/16/91 EEQ PROCEDURES i
91-147 A09658 08/16/91 4160 SWITCHGEAR TAGOUT 91-148 A09659 08/16/91 WORK CONTROL 91-149 A09658 08/16/91 MOV SAFETY TAGOUT I
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MAR 2 51991 Docket No. 50-336 EA No.91-034 Nonheast Nuclear Energy Company A'ITN: Mr. E.J. Mroczka Senior Vice President - Nuclear Engineering and Operations P.O. Box 270 Hanford, Connecticut 06141-0270 Gentlemen:
Subject:
NRC Region I Inspection No. 50-336/91-05 This letter transmits the NRC report of our special inspection conducted by Mr. D. Dempsey of this ofnce on February 12 - March 13,1991, at the Millstone Nuclear Power Station, Unit 2, Waterford, Connecticut, and to the discussions of our findings by Mr. Dempsey with Mr. S.
Scace and others of your staff at the conclusion of the inspection.
Based on the results of this inspection, several apparent violations were identified and are being considered for escalated enforcement action in accordance with the " General Statement of Policy 3
and Procedure for NRC Enforcement Actions" (Enforcement Policy),10- CFR Part 2, Appendix C (1990). The apparent violations involve the incorrect installation of a Raychem environmental qualification splice on the quick-open solenoid valve of the #2 steam generator atmospheric dump valve and the failure of independent quality control and supervisory oversight to detect or prevent the incorrect installation. Accordingly, no Notice of Violation is being issued for these inspection findings at this time.
An enforcement conference has been scheduled for March 27,1991, at 9:00 a.m. to discuss the apparent violations, their cause and safety significance; to provide you the opportunity to point out any errors in our inspection repon; to provide an opponunity for you to present your proposed corrective actions; and to discuss any other information that will help us determine the appropriate enforcement action in accordance with the Enforcement Policy. You will be advised by separate correspondence of the results of our deliberations on this matter at a date subsequent to the enforcement conference. No response regarding the apparent violations is required at this time.
OFFICIAL RECORD COPY ol i
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In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will.be placed in the NRC Public Document Room.
Your cooperation with us is appreciated.
Sincerely, QRIGINAL SIGNED BY:
Charles W. Hehl, Director Division of Reactor Projects
Enclosure:
NRC Region 1 Inspection Report No. 50-336/91-02 cc w/ encl:
W.D. Romberg, Vice President, Nuclear Operations D.O. Nordquist, Director of Quality Services R.M. Kacich, Manager, Generation Facilities Licensing S.E. Scace, Station Director, Millstone J.S. Keenan, Nuclear Unit Director, Millstone Unit 2 Gerald Garfield, Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Senior Resident Inspector State of Connecticut OFFICIAL RECORD COPY
Nonheast Nuclear Energy Company-3 bec w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enclosures)
J. Joyner, DRSS C. Anderson, DRS D. Holody, ORA C. White, 01 E. Kelly, DRP J. Shediosky, SRI, Haddam Neck W. Raymond, SRI, Millstone M. 'Boyle, PM, NRR G. Vissing, PM, NRR D. Jaffe, PM, NRR K. Brockman, EDO bec w/ Report Cover Sheet and Executive Summary only:
W. Hehl, DRP J. Wiggins, DRP W. Hodges, DRS J. Durr, DRS
' L. Bettenhausen, DRS M. Knapp, DRSS R. Cooper, DRSS J. Stolz, NRR/PDI-4 RI:I D
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No..
50-336/91-05 License No.:
DPR-65 Licensee:
Northeast Nuclear Energy Company P.O. Box 270 Hartford, CT 06141-0270 Facility:
Millstone Nuclear Power Station, Unit 2 Location:
Waterford, Connecticut Inspection Dates:
February 14 through March 13, 1991 Inspector:
D. Dempsey, Resident Inspector Millstone Unit 1 Reactor Projects Section 4A, DRP Approved by:
O Eugene Kelly, Chief [/
Dat Reactor Projects Section 4A Division of Reactor Projects Areas Inspected:
Events and documentation related to the discovery by the licensee, on October 27, 1990. that a Raychem (EQ) splice on the quick-open solenoid of the #2 steam generator atmospheric dump valve had been installed improperly. Emphasis in this inspection was placed on the control of work, quality assurance program controls, and subsequent corrective actions.
Results:
See Executive Summary I
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h TABLE OF CONTENTS 1.0 PRINCIPALS CONTACTED....
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2.0 OVERVIEW....
1 3.0 S YSTEM DESCRIPTION..................................
1 4.0 REQUIREMENTS AND PROCEDURES..........................
1 4.1 Regulatory Requirements 2
i 4.2 Procedure Requirements.
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- l 5.0 SEQUENCE OF EVENTS.....
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i 6.0 LICENSEE CORRECTIVE ACTIONS 4-7.0 INSPECTOR FINDINGS 6-
8.0 ASSESSMENT
AND
SUMMARY
OF NRC CONCERNS 6
9.0 MANAGEMENT MEETINGS 7.
ATTACHMENT - Documents Reviewed
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EXECUTIVE
SUMMARY
Millstone Nuclear Power Station, Unit 2 l
NRC Region 1 Special Inspection No. 50-336/91-05 l
1 Maintenance and Surveillance A Raychem EQ splice kit was installed improperly on the quick-open solenoid valve of the #2 i
steam generator atmospheric dump valve, 2-MS-190B, on August 17, 1990. The discrepant condition was discovered in response to a concern expressed by an employee to his supervisor.
Upon identification, the condition was corrected promptly. Causes contributing to the condition were failure to follow procedures, ineffective quality control verification, and inadequate oversight by the job supervisor.
Safety Assessment and Ouality Verideation Good licensee responsiveness to the original safety concern raised by an employee was evidenced.
The safety significance of the discrepant condition was minimal. However, failure of the independent quality verification process to identify the condition is a safety concern.
Documentation of the work performed on August 17, 1990, was poor with respect to both its accuracy and completeness.
.j Licensee corrective actions were considered to be insufficient to preclude the existence of further examples of similar problems.
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DETAILS 1.0 PRINCIPALS CONTACTED l
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NORTHEAST NUCLEAR ENERGY COMPANY r
S. Scace. Director, M01 stone Nuclear Power Station R. Laudenat, Staff Assistant, Millstone Station i
J. Riley, Supervisor, Maintenance. Millstone Unit 2 W. Varney, Manager, Plant Quality Services T. Sullivan, Supervisor, Quality Services Department r
2.0 OVERVIEW i
On October 27,1990, as a result of a concern expressed by an employee to his supervision; the -
licensee inspected a Raychem (EQ) splice installed on the quick-open solenoid valve of the #2 steam generator atmospheric dump valve, 2-MS-190B. The splice was subsequently found to be deficient. The solenoid valve and splice had been replaced on August 17,1990, because of prior damage. This solenoid valve is included in the Millstone Unit 2 Environmental Qualification Master List (EQML) as requiring environmentally qualified (EQ) electrical terminations.
3.0 SYSTEM DESCRIPTION l
The steam generator atmospheric dump valves (ADVs) provide a means to cool down the plant if the main condenser is unavailable as a heat sink. In combination with the turbine bypass system, they are designed to dissipate the stored energy and sensible heat in the nuclear steam suppiy system such that primary and secondary code safety valves will not lift in ne event of a simultaneous reactor trip and turbine trip from full power.
There is one automatically actuated ADV in the main steam line of each steam generator. They are located just outside of the primary containment in the enclosure building, adjacent to the
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secondary code safety valves. Each ADV is rated to relieve 7.5% of full system load (2700 l
M W t). At 905 psig, the valves quick-open to exhaust excess steam to the atmosphere. In the -
automatic mode of operation, the valves can be automatically modulated to maintain a main steam system pressure selected by the operator. The valves may also be operated manually to assist the turbine bypass valves in maintaining reactor coolant system cooldown rate at low.
temperatures.
4.0 REQUIREMENTS AND PROCEDURES The ADVs are not included in Millstone 2 technical specifications and are not credited in the accident analyses presented in the final safety analysis report. However, they are referred to in the plant emergency operating procedures (EOPs) either as a means to restore or maintain reactor -
coolant system average temperature in conjunction with the turbine bypass system or as a
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2 contingency if the main condenser is unavailable as a heat sink. Although the licensee is considering removal of the ADV solenoid valves from the EQML, environmental qualification l
controls presently are required.
!l 4.1 Regulatory Requirements Millstone 2 technical specification 6.8.1.a requires, in part, that written procedures'shall be
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implemented covering applicable procedures recommended in Appendix A of Regulatory Guide l
1.33, Quality Assurance Program Requirements (Operation), dated February 1978. Pursuant to this requirement, the following licensee procedures apply to ADV solenoid valve maintenance-activities.
ACP-QA-2.02C, Work Orders, revision 24, dated June 20,1990 MP-27:0R2, Raychem Splice Installation and Removal (EQ), revision 2, l
change 4, dated August 30, 1989 MP-2720R6. Terminal Lug Inspection, Selection, and Installation (EQ),
revision 1, dated December 30,1989 l
Also,10 CFR Part 50.9 requires, in part, that information required to be maintained by a licensee shall be complete and accurate in all material respects.
i' 4.2 Procedure Requirements Licensee administrative control procedure ACP-QA-2.02C defines the process for controlling work which is important to safety, reliability and quality.
The procedure defines the.
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responsibilities oflicensee personnel and provides detailed guidance concerning the work order system at Millstone Station. The inspector considered the sections of the ACP that follow to be relevant to the work performed on valve 2-MS-190B on August 17,1990. (Specific procedure steps are included in parentheses.)
i The job supervisor is the lead person actually performing work in the field. (4.10) In part, he is responsible for performing the work in accordance with the work package, notifying the appropriate inspection depanment at each hold point, and ensuring that the environmental qualification of equipment is maintained (5.9). A " hold point" is a point in a work package where activities cease until appropriate inspections are performed (4.8 and 6.6.31). The quality services department inspector is required to inspect or witness the work in order to identify and document conditions adverse to quality (6.6.32.2 and 6.6.32.4). Finally, the job supervisor's.
j signature in the " work complete" block of an automated work order signifies that all work is complete and that all quality control requirements have been met (6.6.40).
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Maintenance procedure MP-27:0R2 contains the detailed guidance for installation of Raychem EQ splices on valve 2-MS-190B. Before installing the splice, the cable is prepared by removing all non-qualified or braided jacketing material (5.1.3 and 5.6.1). This is necessary since braided i
jacket material does not provide an acceptable sealing surface (4.3). The particular Raychem kit, i
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i terminal hardware, lugs and crimping tool to be used are selected using a worksheet (Figure 8.1) on which is recorded cable O.D., nominal wire size, terminal lug manufacturer, color code, crimping tool catalogue number, and insulation strip lengtn. Material for the splice is obtained l
based on the information developed on the worksheet. This is a quality control hold point (5.2.18). The Raychem kit, hardware. and worksheet are required to be reviewed by a quality control (QC) inspector who signs the worksheet (5.2.19).
Major splice installation steps include installation of the sealing breakout, make-up of the conductor connections, installation and heat shrinking of the breakout body shim, and installation and heat shrinking of the splice cap. Selection and instaliation of the conductor connections is controlled by maintenance procedure MP-2720R6. This procedure contains a hold point after j
selection of the terminal lug crimping tool (5.3.7).
Finally, the quality control inspector is ~ quired to witness the installation of the splice and documem on maintenance form MF-272vR2-2 satisfactory completion of the quality attributes i
associated with major procedure steps.
5.0 SEQUENCE OF EVENTS r
i On August 14,1990, pursuant to automated work order (AWO) M2-90-08571, licensee contractor t
and instrumentation and controls personnel performed diagnostic tests of valve 2-MS-190B.
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Installation of test equipment disturbed the integrity of the ADVs solenoid valve EQ terminations. Therefore, on August 15, AWO M2-90-08697 was originated to re-terminate the valve in accordance with MP-2720R2, using Raychem splice kits. Since the electrical cable on the solenoid valve coil was too short to accommodate the new splices, a replacement coil with j
long leads was procured. The new coil was installed and the valve was tested satisfactorily on August 17.
On approximately October 24. based on a concern expressed by an employee to his supervision regarding the adequacy of the Raychem splice installed on August 17, the Millstone 2 maintraance manager directed that the splice be opened and inspected. The basis of the concern -
was that braided jacket material might not be pulled back from the sealing an of the splice.
AWO M2-90-12648 was originated to control this activity. Upon opening one of the splices on October 27, the braided material was found to extend into the seal area, thus invalidating the environmental qualification of the splice. Both splices (one for each lead from the coil) were replaced on October 29. The licensee documented the discovery of the discrepant splices in Plant Incident Report 90-143 and Nonconformance Report 290-362, dated October 30 and 31, respectively. Following satisfactory post-maintenance testing, valve 2-MS-190B was returned to service on November 5.1990.
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6.0 LICENSEE CORRECTIVE ACTIONS i
f On November 30,1990, in response to Plant Incident Report 90-143, the licensee performed a f
reportability evaluation of the event. Failure of the splices under harsh environmental conditions would have eliminated the quick-open response capability of the ADV. However, since the valve is not credited in Millstone 2 accident analyses, the licensee concluded that the condition was not reportable to the NRC pursuant to 10 CFR 50.72 or 50.73. This is because the solenoid splice in question only affects the ADV quick-open function (and not the normal modulating function referred to in the EOP), even though the entire ADV is Q-listed. Inadvertent opening of an i
ADV is a safety consideration. The licensee also determined that the possibility of spurious l
actuation of the ADV due to a short circuit to another power source was not possible. The l
inspector had no questions regarding these conclusions, but the safety function (including l
qualification) will remain unresolved pending further understanding of the inclusion of the j
solenoid in the EQML (50-336/91-05-01).
The NRC became aware of the non-qualified splice on November 5. Based on initial discussions with licensee personnel involved in the work on August 17, the NRC concluded that followup was warranted in order to assess the adequacy oflicensee's corrective activities. NRC concerns were turned over to the licensee for resolution, and a licensee representative was assigned to this function. Based on their initial findings, the licensee responded to the NRC in a letter dated December 21, 1990. On January 4,1991, the licensee investigator interviewed Millstone 2 maintenance department personnel who had knowledge of the ADV work, and received from quality assurance management the results of its interview with the QC inspector. The licensee provided supplementary information to the NRC in a letter dated January 31,1991. The licensee also has updated the NRC periodically regarding its findings in this matter.
In its letter to the NRC, the licensee stated that the event had been discussed with the job supervisor, who was counseled on the need to exercise care in the performance of EQ work.
At this point, the licensee concluded that, based on the quality of previous performance and training, no review or inspection of past EQ work was considered to be necessary. At a meeting with the inspector on February 14, 1991, licensee management reaffirmed this position.
The licensee interviewed the QC inspector on November 13,1990, and determined that, contrary to the requirements of MP 2720R2, the QC inspector had not witnessed the braided jacket material being pulled back from the splice area. Rather, the QC inspector had signed off the witness point 5.1 of maintenance form MF-2720R2-2 based on a discussion with the job supervisor.
The QC inspector was counseled by licensee management concerning the requirement to follow procedures strictly and the need to perform and document accurately all witness and hold points. Formal disciplinary action was also taken against the QC inspector by the licensee. A special meeting was conducted by quality assurance department management with the Millstone station QC staff to emphasize these considerations. The inspector acknowledged
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5 their corrective actions, but questioned the licensee's conclusion that, based on previous performance, no inspection of past work by either the QC inspector or job supervisor was deemed to be necessary.
Through interviews with Millstone 2 maintenance department personnel, the licensee has attempted to develop a thorough understanding of the maintenance activities which took place l
on valve 2-MS-190B on August 17. By comparing security personnel access logs with the statements of the personnel involved, the licensee has concluded, preliminarily, that other i
procedure sign-offs may not have been performed properly.
The inspector independently reviewed the licensee investigator's information, the access logs, and.
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AWO documentation, and agreed that inconsistencies exist regarding what work actually was
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performed in the presence of the QC inspector. For example:
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-- Safety tags for the job were hung at 12:10 p.m. Two individuals stated that they entered the I
job area, found no one present, and observed that the Raychem sealing breakout was slid onto I
the conductors, which were crimped and bolted together. Access logs indicate that the job supervisor and a co-worker were in the enclosure building (EB) from 12:30 p.m. to 1:00 p.m.,
j and that the other individuals left the EB at 1:04 p.m. The QC inspector did not enter the EB until 1:33 p.m. The QC inspector and the co-worker stated that they were present during the.
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entire evolution and that they saw no one else at the job site. Thus, it is possible (but not i
conclusive) that no QC inspector was available at the job site to witness portions of the work.
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-- The inspector noted that on August 17, the QC inspector signed _ off as satisfactory on I
maintenance form MF 2720R2-2 two steps relating to positioning and application of shims. Step 5.6.2 of MP-2720R2 states that using Raychem splice kit NPKV-2-14, shims are not required i
if cable diameters are between 0,10 and 0.20 inches. MP-2720R2, Figure 8.1, Splice and -
Connecting Hardware Selection Worksheet, shows the cable diameters to be 0.15 and 0.118 i
inches. Thus, shims would appear not to have been necessary. Further, the maintenance form completed on October 29 for the same cables and splice kits indicates that these steps were not i
applicable.
-- Step 5.2.19 of MP-2720R2 is a QC hold point which requires that the splice kits, hardware, and Figure 8.1 worksheet be reviewed by a QC inspector to ensure that the correct hardware and equipment have been selected and obtained. The step includes a requirement that QC sign the worksheet. The inspector noted that the AWO was signed off as completed on August 17, but j
the QC inspector did not sign off the workseet until August 20.
-- The inspector noted that the following information was not recorded on Figure 8.1 as required t
by step 5.2 of MP-2720R2: terminal lug part numbers, type of compression, type of crimping tool, crimping tool model number, tool color code, and insulation strip length.
l The inspector was concerned that the licensee's investigation, begun In November 1990, apparently had not identified these discrepancies as of the end of this inspection, I
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7.0 INSPECTOR FINDINGS f
a The inspector found that on August 17, 1990, the Raychem EQ splice was installed on the solenoid valve of #2 steam generator ADV with the braided jacket material not pulled back from the sealing area. This is contrary to the requirement of MP 2720R2, step 5.1.3.
The QC inspector assigned to witness the installation of the splices signed off, as satisfactory, witness point 5.1 of maintenance form MF 2720R2-2. But in fact, the braided material had not been pulled back and (as ascertained by the licensee's interviews with the QC inspector) this attribute had apparently not been witnessed. This is contrary to the requirements of ACP-QA-2.02C regarding performance and documentation of QC inspections, and MP 2720R2, step 5.6 - NOTE.
In so doing, an inaccurate record of this maintenance activity was created, contrary to the requirements of 10 CFR 50.9. Finally, the job supervisor signed off the AWO signifying that work was complete and that all QC requirements had been met when, in fact, all QC requirements had not been satisned. This is contrary to the requirements of ACP-QA-2.02C step 6.6.40.
i These activities constitute several apparent violations of NRC requirements (50-336/91-05-02).
S.0 ASSESSMENT AND
SUMMARY
OF NRC CONCERNS t
Since the steam generator ADVs are not credited in the Millstone 2 accident analyses presented in the final safety analysis report failure of the quick-open feature of valve 2-MS-190B (if challenged) has minimal apparent safety significance. Moreover, during the period from August 15 to October 29,1990. when the unqualified splice existed, the reactor was shut down for most of that period (September 15 - November 1) in a refueling outage.
However, the NRC is concerned regarding the apparent multiple breakdowns of programmatic l
j controls, designed to assure the quality of work performed under the EQ program, which were l
exhibited during this. maintenance activity. Specifically, performance and' oversight of the l
activity by the job supervisor were inadequate. Independent quality control verification was ineffective. Weaknesses in documentation were evidenced by the lack of information on a
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i worksheet, a questionable QC hold point sign-off, and indications that an activity which was i
apparently not performed being signed off as satisfactorily witnessed. Finally, the inspector j
observed that, but for the concerns of an employee unconnected with the work, the improper splices would not have been discovered.
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Regarding corrective actions, the mspector was concerned that, until questioned by the hTC in a meeting on February 14, 1991. the licensee had made no effort to review or inspect other activities performed by the personnel involved in this activity. Thus, there is insufficient assurance that the failures illustrated during this activity are an isolated case.
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-l The inspector considered that the licensee's inspection activities on Octob
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good regard for and sensitivity to an employee's safety concern. Also, ex i
ll i thelicensee'sindependentinvestigation of the circumstances surrounding theimproper l of Raychem splices on August 17 was satisfactory.
9.0 MANAGEMENT MEETINGS
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The inspector met with the Millstone Site Director and other management re l
conclusion of the inspection on March 13 to discuss the preliminary inspection l including the apparent violations. No proprietary information was covered' the inspection, and no written information was provided to the licensee.
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ATTACHMENT o
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i Documents Reviewed ~
AWO M2-90-08697, Terminate EQ connections on #2 steam i
generator atmospheric dump valve solenoid valve
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AWO M2-90-12648, Inspect and re-terminate solenoid connections on #2 steam generator atmospheric dump valve
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ACP-QA-2.02C, Work Orders, revision 24, dated June 20,1990
!q MP-2720R2, Raychem Splice Installation and Removal (EQ),
l revision 2, change 4, dated August 30,1989
-j MP-2720R6, Terminal Lug Inspection, Selection, and -
f Installation (EQ), revision 1, dated December 30, 1987 Millstone Unit 2 Final Safety Analysis Report, Chapters 10.3, 7.4, and 14.2 i
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1 RECORD OF ALLEGATION PANEL DECISIONS
/7.-f!q on d PANEL ATTENDEES:
SITE:
ALLEGATION NO. :- f-1-93 0c 9 i Chairman -- 7. T Ncseit%S l
DATE: 8 M'(9d (Mtg. I 2 3 4 S)
Branch Chief - b. C Wenaiherr PRIORITY:
High Medium Low Section Chief ( AOC) -T.141. l/c y l
SAFETY SIGNIFICANCE: Yes. No Unknown Others - C. W. dt he
[2. C ira /y CONCURRENCE TO CLOSE0UT: DD BC SC 5.O.Cul otai 2.2.b < rdbr h.(. $c a 3.5. $heio3 CONFIDENTIALITY GRANTED: Yes No (See Allegation Receipt Report)
IS THEIR A DOL FINDING:
Yes No j
l IS CHILLING EFFECT LETTER WARRANTED:
Yes No i
l HAS CHILLING EFFECT LETTER EEEN SENT:
Yes No i
HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER:
Yes No-lfwas"p aa ! b :
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Docket No. 50-336 A
h Mr. E. J. Mr
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Senior Vice President - Nuclear Engineering and Operations
- )Q M
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Nonheast Nuclear Energy Company V
d P.O Box 270 Hanford, Connecticut 06141-0270
Dear Mr. Mroczka:
Subject:
Millstone Unit 2 Inspection 91-18 This refers to the routine safety inspection conducted by Mr. P. Habighorst of this office on June 23 through August 14. 1991, for Millstone Unit 2 in Waterford, CT. The preliminary Endings were discussed with Mr. J. Smith and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection are described in the enclosed report. Within these areas. the mspection focused on issues important to public health and safety, and consisted of performance observations of ongoing activities, independent verification of safety system status and design contiguration, interviews with personnel, and review of records.
Oserall operation of the facility contmued to be satisfactory. Your emergency response organization displayed good teamwork, technical support, and management decision-making during the loss of annunciators on July 26.
Your cooperation with us is appreciated.
Sincerely, c
y 4c'1 Edward C.,
7enzinger, Chief Projects ch No. 4 Division of Reactor Projects
Enclosure:
NRC Inspection Report 50-336/91-18 t
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report /
Docket No.:
50-336/91-18 License No.:
DPR-65 Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, CT 06141-0270 Facility Name:
Millstone Nuclear Power Station, Unit 2 Inspection At:
Waterford, CT Dates:
June 23 - August 14, 1991 inspectors:
P. J. Habighorst, Resident Inspector, Unit 2 W. J. Raymond, Senior Resident Inspector, Millstone L. E. Briggs, Senior Operations Engineer, DRS G. S. Vissing, Project Manager, NRR/PDI-4 I
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Approved by:
[,y _
ate
-tM Eugene M. Kelly, Chief Reactor Projects Section 4A Scope: Routine NRC resident inspection of plant operations, radiological controls, maintenance, surveillance, licensee self-assessment, and periodic reports.
Routine review of plant operations was conducted during periods of backshifts (evening shifts) and deep backshifts (weekends, holidays, and midnight shifts). Inspection coverage was provided for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> during backshifts and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> during deep backshifts.
Results: See Executise Summarf i
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e 10 of the spent fuel pool area. The friskers are verified to be in place periodically, and the unit at the 38-ft SFP frisking booth was in place when checked by & vrsonnel on July 5.
NNECO investigation could not identify when or why the fris.
- eestion was removed.
The failure to have a frisker in the frisking booth at the 38-ft elevation did not violate NRC requirements or Millstone station procedures. Signs posted at he 38-ft elevation state frisking is required upon completing work in the spent fuel pool area. The inspector noted friskers i
were in place at exits from the spent fuel pool area, including at the normal PAB exit point at the 14-ft 6-in elevation. The availability of friskers at the spent fuel pool area exits and at the PAB exit points were sufficient to check for personnel contamination. Worker initiatives j
and HP supervision actions to place a frisker closer to the SFP work site were acceptable to address the initial concern about a missing frisker. The inspector had no further questions in l
this area.
5.0 MAINTENANCE / SURVEILLANCE (IP 61726,62703)
I 5.1
- Observation of Good Workmanship Inspection Activities The licensee has initiated a program to perform " Good Workmanship" inspections of completed maintenance activities. The work packages selected for inspection are picked by the maintenance depanment. They are selected from completed work activities that involved either corrective maintenance or EQ equipment. Packages from either category must also require Quality Control (QC) involvement and have inspectable attributes. Approximately ten percent of the work orders fWO) completed during 1989,1990. and 1991 were selected to be inspected.
P A standard list of the attributes to be inspected were developed by the Unit 2 engineer. The attnbutes are modified to suit the specific work activity to be inspected. The selected attnbutes are then approved by the Unit 2 Engineering Manager and the Supervisor, Quality Services Depanment (QSD). The inspection team normally consists of two maintenance personnel, two QC inspectors, and one Unit 2 engineer. The following good workmanship t
inspections were observed by the NRC inspector to determine the ;evel of detail of the inspections performed by the licensee.
l WO M2 9105:96, inspection of the "A" Emergency Diesel Generator (EDG) Air l
Start Header Solenoid Operated Vent Valve l
The electricians removed two pull boxes to inspect the electrical connections of the solenoid. The taped connections in the first pull box were determined to be unacceptable because the tape was not wound tight enough. NCR 291-183 was i
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i issued to resolve the tape problem. The connections in the second pull box were acceptable and had not been disturbed during the earlier solenoid replacement.
l Other physical attribute:; were also inspected by the licensee and found acceptable.
The solenoid was replaced under WO M2 9105942 which also replaced the taped connection with dedicated wire nuts (MP2-0268).
i WO M2 9103544, Inspection of "A" EDG EG-A Woodward Speed Controller Box in Panel C-38 This inspection consisted primarily of verifying the physical installation of the control box and inspection of the terminal lugs. Actual disconnection of 25 percent of the lugs was required because they were oriented toward the back of the cabinet which prevented a visual inspection. One lug was determined by QC to be unacceptable because the insulation sleeve pan of the lug had been cut or punctured through the lug and the wire insulation to the copper conductor. Since the lugs had not been replaced during the controller installation and the lug in question was a different type than those used at the site and had a different style crimp, the licensee's inspection team determined that the lug had been installed at the factory.
The QC inspector noted that an NCR (291-184) would be issued to resolve the problem. This item was dispositioned by engineering to be use-as-is. Justification j
was provided that the lug was the correct size, it was securely crimped to the wire, and that the cut did not impair the _ insulating quality of the lug barrel or the ability of the insulation to stay in place. The NRC inspector discussed the engineering disposition with one of the involved QC inspectors. The QC inspector agreed that because of the lug location that the disposition was technically acceptable: however.
replacement would have made the installation 100 percent correct.
WO M2 9105268, inspection of Controller B6202 in Motor Control Center (MSS)
B-62Z2 There were no deficiencies in workmanship identified during this inspection.
WO M2 9105305, Inspection of 2-CS-16.l A, Containment Sump Outlet Header A Motor Operated Valve (MOV)
This inspection did not identify any workmanship problems within the motor operator terminal box; however, the EQ boundary was broken to perform the inspection. The QC inspectors issued NCR 291-188, which describes the broken EQ boundary including rust on the seating surface and that a flex conduit entering the top of the termination box has been repaired with electrical tape.
WO M2 9103545. Inspection of 2-CS-4.l A, "A" Containment Spray Header Isolation Valve Motor Operator
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12 This inspection documented the following findings on NCR 291-173: 1) six lug connections were found to have Raychem material applied over the braided insulation; 2) one cover bolt was found missing; and,3) the cover gasket was found damaged. The inspector did not observe the inspection in progress, but reviewed the documentation concerning the NCR disposition and discussed the decisions which were made with licensee personnel.
The engineering disposition for these items required repair by replacing both the missing bolt and the damaged cover gasket. There was no required rework specified for the observation of Raychem material being placed over the braided wire insulation because it was not intended to be the environmentally qualified barrier.
The Raychem material which was installed over the wire and the barrel of the i
terminal lug provided additional electrical insulation and physical protection for both the wire and the terminal.
A design change, made in 1989, replaced connections made with Thomas and Betts nylon wire caps with a Marathon Type 300 terminal block, which was qualified for the post-accident atmosphere. The inspector reviewed the documentation for the design change, PDCE Mp2-89-014, and the implementing work order M2-89-01059.
This included the engineering analysis for the qualification of the terminal blocks which were installed. The inspector concluded that the installation which was documented as part of NCR 291-173 was that specified to be installed through the i
design change, and it corresponded with that described within the engineering safety evaluation.
5.2 Main Turbine Maintenance Activities During this inspection period, the main turbine was taken off-line in three separate instances to investigate de5ciencies associated with the turbine hydraulic control system.
Background
On July 6,1991, the licensee identified during a weekly surveillance that the "A" master trip solenoid valve (MTSV) would not trip from the tested configuration. The MTSV converts electrical trip signals to hydraulic trip signals. There are two normally energized MTSV and both must deenergize to cause a turbine trip. Notwithstanding a malfunction of the MTSVs, a backup mechanical trip would trip the turbine if an electrical trip were to occur.
On July 10, 1991, NNECO elected to take the turbine off the line to replace the "A" MTSV.
Visual inspection of the valve identified grit and score marks in the actuating cylinders.
Based on this evidence of foreign material in the system oil, the licensee replaced the discharge filters downstream of the electro-hydraulic control _(EHC) pumps and established i
daily sampling of the oil for viscosity water acidity, chlorine. resistivity, and particulates.
i
r (oS
\\
MEMORANDUM TO: FILE November 27, 1991 FROM:
TOM SHEDLOSKY j
SUBJECT:
ALLEGATIONS INVOLVING NON-RADIOLOGICAL OSHA SAFETY ISSUES ON ELECTRIC PANEL CLEARANCES Both allegations RI-91-A-070-2 and RI-91-094-2 document the same i
issue, failure to comply with the National Electric Code and have a thirty-six inch working space in front of the same two panels (Panels No. 3& 4) located in the Millstone Unit-2 Maintenance Shop.
A representative of the U.
S.
Department of Labor (DOL)
Occupational Safety and Health Administration (OSHA) Hartford Area l
Office conducted an on-site inspection (Number 100976687) of the penel installation on July 11, 1991 in response to an employee allegation (Complaint No. 073850059).
A letter from the Area Office, dated October 31, 1991, identified a violation of the l
Occupational Safety and Health Act of 1970 and 29 CFR 1910.303(g)(1)(i); there was no civil penalty.
i The Millstone Station Director responded to the Citation by letter dated November 25, 1991.
The letter informed the OSHA Area Office t
that the violation was abated during the week following the July 11, 1991 inspection.
I think, it would be redundant to refer this to issue OSHA again as j
these allegations were received on April 15, 1991 and May 7, 1991, i
respectively.
I recommend that we inform the alleger that an OSHA on-site inspection was made on July 11, 1991; a citation iesued; and i
corrective actions taken. And that, we plan no additional actions.
I I
also recommend that we do not transmit the attached r
correspondence to the alleger.
\\
Attachments:
- 1) OSHA Complaint No. 073850059 j
- 2) U.
S.
DOL OSHA Hartford Area Office letter to Northeast Nuclear Energy Company, dated October 31, 1991 l
- 3) OSHA Citation for violation of 29 CFR 1910.303(g)(1)(i)
I
- 5) Copy of 29 CFR 1910.303(g)(1)(i)
Allegation File RI-91-A-070-2 cc:
l Allegation File RI-91-A-094-2 E. Kelly, RPS No. 4A, DRP R. Barkley, RPB No. 4, DRP E. Conner, TSS, DRP
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.a cenmiomces semen sweet.semn. Connecticut NORTMEAST UTILITIES ro c.cu, m
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P.O. BOX 270 1
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HARTFORD. CONNECTICUT oB141-c270
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(203) 665-5000 C$ [",L",",","
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J John J. Stanton, Jr.
U. S. Depanment of Labor Federal Office Building - Room 508 450 Main Street Hanford CT 06103 Citation Resulting From Inspection 100976687, July' 11,1991 Re:
Dear Mr. Stanton:
inspection This letter is in response to a violation noted during the recentThe specific referenced above of the Milistene Unit 2 maintenance shop.
violation was the failure to maintain a working space of more ' than 36 inches in front of two (2) electric panels.
The The violation was abated during the week following the inspection. rem was abated by As a result, adequate work space clearances in excess of the minimum violation Table S-1 were established.
panel.
required by 10 CFR 1910.303 (g) (1) (i)
Please contact me if you have any further questions on this matter.
Sincerely.
k3es//
W Stephen E. Scace Director, Millstone Station bec J. F. Opeka W. D. Romberg D. E. Welch J. F. Follett R. Voigt List D
Occuptional Safety and Health Administration u.
U.S. Department of Labor a
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te U.S. Department of Labor Occupational Safety and Health Administration f Y **.
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Reply to the Attention et If you cacice to reauest an informal conference, please complete tna atta:hed nctics at the bottom cf this letter anc post it next to th-citations as scen as tr.e time,
- cate, anc placs cf the inic.a.ai c:nference have been cetermined.
Ee sure to bring te the conference with you any anc all supporting cccumentation cf existing cer.ci ti ons as well as of any abatement sters taken thus far.
If c;ncitions warrar.,
we can Enter Inte i
an inf:rmal settlement ag eement wnich amicaci res:1ves this mattar without liti;atior, or contest.
Eincerely, a,m d.
< n-3:A
- 3. Etanton, Jr.
Aree Direct:r Encicsures f
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Occupational Safety end Hw.tth Administration V
- 3. issuane. Date
- 4. inspecim wunen l
l M V S,'
Citation and Notification Of Penalty 10/31/91 100976687 l
U.S. Department of Labor
- 5. Reporung ID
- 6. CSHO ID l
Federal Office Building - Roos 508 0112000 Y4553 I
p,,,%
450 Main Street 73, g,%33,% in,
- 7. Optenal Report No.
- 8. Page No.
l Are Due curred on or about the day the 604 1 of 1 l
withm 15 R2rtford, CT 06103 cnaten are alieged to have oc.
DWs of inspection was made unless g
Rece@t otherwise indicated within the 10. Inspecton Date(s):
l et Th5 j
a Nottfes5en desenption grven below.
7/11/91 - 7/11/91 l
unies:
Other 01
- 11. Inspecten Site:
[
centested
$3,o MILLSTONE WCLEAR POWER PLANT i
Bmme0 g 7,.
WATERFORD, CT 06385 I
NORTHEAST NUCLEAR E}ERGY COMPANY I
Ny7 I
Detached and its successors j
ge l
P.O. BOX 128 WATERr0RD, CT 0638s THE 1.AW REQUIRES that a copy of this Citaton be posted immediately in a promment place at or near the locaten of Cnaton must remam posted untti the violatons cited below have been abated, or for 3 workmg cays (excluding weekends and
{
This Cnaten describes viotations of the Occupational Safety and Health Act of 1970. The penany(ies) listed below are based la longst.
~
j absts the violatons referred to in this Cnaten by the dates hsted below and pay the penanes proposed. unless withm 15 workin and Federal hondays) from your receipt of this Cnaten and penany you mail a notco of contest to tne U.S. Department of Lab shown above. (See the enclosed booklet whch outimes your nghts and responsibdstes and should be read m conjunc r
notified that unless you inform the Area Director in writmg that you intend to contest the Citation or proposed penalties within this Citaten and the preposed penatt+es will become a fmal orcer of the Occupatonal Safety andi court or agency. fssuance cd ter in the Act or, if contested. unless the Citat;on is a* firmed by the Review Commsson.
- 15. Date oy Whch j
- 16. Penalty l
i i
V,olaten Must
- 12. Item Number Be At;ated l
- 14. Desenpton
- 13. Standard, Regulaton or 4
Secten of the Act Volated I
0.00 11/19/91 1
The dimension of the working space in the I
29 CFR 1910.303(g)(1)(i):
direction of access to live parts cperating at 600 volts or less and I
l likely to require examination, adjustment, servicing, or maintenante I
while alive was less than indicated in Table S-1:
I I
I THE WORKING SPACE I
NORTHEAST CORNER OF THE LNIT 2 MAINTENANCE SHOP:
IN FRONT OF THE TWO (2) ELECTIRC PANELS WAS LESS THAN 36 INCHES WID 1
1 I
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f 0.0Cl J
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John 3. Stanton, Jr.
(
, w, NOTICE TO EMPLOYEES - The law gives an empNyee el EMPLOYER DISCRIMINA g
Tetar his representative the opportunity to object to any abate-filing a complaint or for exercising any rights under th:s Act. l -
C:tation ment date set for a violation if he believes the date to be An employee who believes that he has been disenminated l
- unreasonable. The contest must be mailed to the U.S.
against may file a complaint no later than 30 days after the mn.ro,e.,
. Department of Labor Area Office at the address shown disenmination with the U.S. Department of Iabor Area Of-l
.QM.,
abovs within 15 working days (excluding weekends and fse at the address shown above.
[.
Fed:ral holidays) of the receipt by the employer of this Cita-l
- =o.co tion and penalty, iblities and l.
a.a.n.n W8H (MR RIGHTS AND RESPONSIBILITIES - The enclosed booklet outlines employer rights and respons t
._n Occupational Safety and Health Administration
',,,-.o, 4
U.S. Department of Labor f Y *,
\\ E.,*l Reply to the Attention of:
U2IIEE 10 E 2LOYEEE An infcrc61 cor.ference has teen scheduled w:tn CEnA tc ciscuss the cita-
- or.s issued cr. 10/31/91. Tr.e csnference w:ll te held at tne 05HA cffi:a located at Fecers.1 Cifice Ecilding - F.cor, 503,
- Hartford, CT 01103 or, at _ _
e 9
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Occupational Safety and Health Adrninistration
/.,,y *t U.S. Department of Labor 4
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- Reply to the Attention of:
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U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY & HEALTH ADMINISTRA TION 1
GUIDELINES FOR PREPARING AN ADEQUATE ABA TEMENT LETTER 4
Abatement letters must specify action taken to correct citation items and the date stated corrections were completed. Please use the following guidelines forassistance l
in completing an abatement letter. IN ADDITION, IFNO SE1TLEMENT A GREEMENT IS REACHED AND YOU DO NOT CONTEST, PENALTIES ARE DUE 15 WORKING DAYS AFTER RECEIPT OF CITATIONS, AFTER WHICH THEY ARE CONSIDERED DELINOUENT AND YOU MA Y BE SUBJECT-TO INTEREST AND ADMINISTRA TIVE i
FEES.
State the Citation Number, the item Number (s) and the Instance letter. Enter date of completion and the spccific corrective action taken, including any applicable dimen-l sions, phohtographs, materials, specifications, personalprotective eqbipment, engin - --
eering controls, measurements or readings. If overexposure to an air contaminant or
}
noise has been cited, sampling results need to be reported to verify compliance and document effectiveness of controls.
3 i
Examole:
Citation # 1, Item # 1, Instance (a) - Date: 00/00/00 A guard was installed on the Black and Decker table saw.
l i
We cannot close your file if the abatement letter does not give abatement date and specific corrective action taken.
If an informal conference is scheduled, you may wish to bring the abatement Ic!!er to the meeting.
i Thank you.
p.
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- gn..
.:5.-
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P y
' Noisce of Anegeo dately or r1e 1 taa7arnn U.S. Departmeqt,o1 LaDor -
Occupa!cna: Sawy anc g. terwrrstaton f
- 1. Compant Numner >073850059 MDD Dre 17- // - 9/
- 2. Ernpoter f4ame CONN. LIGHT & POWER CO.
MILLSTONE NUCLEAR POWER PLANT WATERFORD.
CT 06385
- 3. Sne Lacson (Sveet Cey Sze. ZIP)
- 4. Mahng todress (if d$ere'TJ (Street Cry. State, ZlP) a w35NEM1 20 L Manageme1 Offcal ROBERT A. AYALA
- 7. Type of Busmess POWER GENERATION
- 8. Hazard Descnpton. Descnbe ty#y Ms hazard (s) **uch you beieve eust irclude the approorna:e turnber d empayees WM to or thrsgened by each hazarc.
SAFE WORKING SPACE / CLEARANCE DISTANCE AROUND ENERG12ED ELECTR 1.
15 NOT MAINTAINED.
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7 Admin., Laba
<J-ational Safety and Health f.
v
. ;. a zatio.
id I 1910.1001 h43 hbpart shall be acceptable only if ment. '.
.....m gs shall be prov -
be id n
or ed giving voltage, current, wattage,
-~. w ark-r participa-tion, instcIlation, and other ratings as necessary. The ming s
<m
- 'tCr?
- red, to tramination-
'["-~~ G'weno e/* Qed / 3 traminaof equipment-41) shall be
'dW
,*p cal equipmenthazards i
lved.
rided prior free withstand the environment invoIdentification LSsignment that are
""" 8%, g W disconnect-fler.
,'dhe Q recognized harm to employees. Safetyto cause death or serious phys
<5M,
means und circuits. Each (f) f 3 shall be of
%ces e D"-%.
,,,,,(
ing means required by this subpart or f*****~ de av.,M[/k ppment shan be deterrnined using r
ibly h the em-motors and appnances shall be leg L
.it l ss
. The em-Am are marked to indicate its purpose, un e u'
$*j heme = oya [*Q* aeem.s,following considerations:
is I '*PIOF-and doxw N) Suitability for instanationconformity with the provisions located and arranged so the purposc and U.
- feeder, oe ated 7'g===*'and w,,,,7$ in ane f equip-Each service, circuit, at its disconnecting
- s9tnis subpart. Sultability oose may be evident.
mm,.3 g
w 8 W8=sh t ll be means or overcurrent device, sha tuizat!'@gggenced by listingII~ My W1 for an idenMed purp or labeling for branch Her roou,,
legibly marked to indicate its purpose.
!n smok.
the unless located and arranged soevident. These c$1 stren th and durabil.
- . tremo.
iogjte in l
h ery elee
'Iit.instauf)Ik,"c t
MT including, for parts designed to en.
i utilizatio durability to darch 15,19f2, the purpose is
- #ICP'F and protect other equipment, shall be of sufficientwithstand the e lved.
manner usey of the protection thus pro-unent. modification
- less-(l)
- sbestos, t
(g) 600 rofts, nominn, or Utation, after March,1, 2AI i
tinobte.
Working space obout electne equ p-Art of any electrie hatjoa(d' ulation.
I king trations I before March is 19f2 "h*U.tili) Electrical nsNv) Heating effects under conditions i
ment. Sufficient access and worshaU be p 1 or utilization i to as-ent to 1.or ac-tained about all electric equipmtion and 7 with the proy N#Ikuse.
space 1910.308;*n
'tr) Arcing effects, type, size, volt-permit ready and safe operamaintenan 302 through
- 2 difkstkma, hvi) Classification bySM h current capacity, spwhich contribut is and s --f*.-d-ecific use, De em-
' " Major replacem (1) Working clearances.
e in this
~ to that intch'ed wh*" ""'N82til Other factors f em-oc rehabditatto i the practical safeguarding oor likely to come in con-quired or permitted elsewhersubpart, t
.ntho-rking imple-facility is built, a nei d'"*4 m em i
.:fp, byees us ng i ment.
d or la-ntire floor is renovated less and VISI US apply to 1:t with the equ p~ M2)1nstcHatton and use. ListeU be used or in-space in the direction parts operating at 600 volts orlikely to t
ppro The fonowing d
ed after Apra. kled equipment sha
' aquipment insgst ! s and utafza.
with any instruc-while
- c utilization s ment, servicing, or maintenance y' ~8~4 % sons included in the listing or label-d in {
g p, caned in accordance anye may not be less than indicate 81:
n Table S-1. In addition to the dime -
and ih',;
Conductors shan be ace sions shown in Table S-1, worksp stec-7** " 'P"*E**:=%'. %! iced or joined with splicing devices
$vN t b Splices.
or by brazing.
wide in umqe g,
may not be less than 30 inchesfront n of
'" swrwN* ietal or alloy. Soldered spM 1eiding. or soldering use c.'nitable for the Uces shaU iam%A, the live re-l 3*Fx%
c,w,,,, yQata.
tances shan be measured fromfrom the fon:
c d as to be parts if they are exposed, oropening if the live
- ** **h@ Yftst be so spilced or joine i
in-8' ecure 05cnemun. 3D'*'""i 4.WM' cechanically and e!cetricany sJrithout solder and then s brick, or d All enclosure front or parts are enclosed. Concrete, round-dn-tile wans are considered to be g
- "* %"* *% "rdlices and joints and the i ed in
- o aag. so C.*
in-ed. Working space is not requ r
,25GX5L.- comes,, m 41 : %nductors shallbe covered with anwith an insul t
py back of assembIfes such as dead f t to that of the con-one t
ters
- es
' wW <.rdation equivalen switchboards or motor control cen or ad-if-where there are no renewablejus
- tactors or
- oswa ~~~ DQ**" 'NN a drdtable f or the purpose. Arcing parts Parts of electricordinary oper-h Ma
'?
u connec-e.
N
- no or cm. iwd... i,sequipment which ine arcs, sparks, flatnes, or es on the back and where aare a M (d)
D
- m aaet 1-molten metal shall be enclosed or sep*d from all combusti-other than d
. (($,8ption pro uc
'" ""** *v'*%
me tions Y
405a. Jan.16.1P81; 46 FR 40!EQ, rated and isolate F
p Afarking. Electrical equipmentot be used unless the m e material.
- p. Isan 2
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(e)
Cmeral requirementa. GTQ' /.
other de-
/turer's name, trademark, orW scriptive marking by which the o Approecl The conductors iind ( tay n t
3.303
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pment required or pennittedty; f 659 sg A, M,7
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Potional Sofety and Health Admin.
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29 CFR Ch. Xyli (y,g,gg
{ 1910.303 ti n of a qualified person at all are <
g is M (A) By location in a roo Mp TAstI S&Womwa CLE ARAwcts such 9 astcUnfi ns c.ceezrible to quali-J similar enclosure that J
- esegg, persons M4 Electrical installa-trol :
0 w,r w ves o w = w only to qualiDed persons.
T rD; (B) By suitable permantht. SubstaFi g having exposed hve pktts shall news >
T wm.nw voemae e rww p geessible to qualified persons onlyfuse!
m m i e tial partitions or scree Mi jgd shat] comply with the applicable wher 4
that only qualified pe
% hase}
'3 3
kccess t.0 the Epact, ecit in the p p 51sions of paragraph (IS3) of this 3
'3 !
frorr; Whe l
odh
\\[
'N-
'l live parts. Any openings in gglon' 8,
f
"# "#####0l# IO *** on d tions or streens shan be so "D8 '
JIU I"##
- umum em, esiances mn t,e a w 5 nenn tw located that persons are Pagrted persus. Electrical installa.
entit
^k msmum tun re m Am 16. e ps that are open to unqualified per-S i,M.=N.$.*N.p.8," gee a$Ds,s on ccme into accidental con ing i
me or ow ts 1 Aos shall be made with metal-en. shal.
live parta or to brinc co d"Uth* 8N os a me ve o
.TT.MYe.N. no rouno.ocUY on, =
fLhQ goed equipment or shall be enclosed o'n= -oeg J
ow dom seco e sovev osooo tv www NS$C) B. locat no a s dtable halceb r
8 a vault or in an area. access to 1r TAsc I
- U **
ny, ga3ery. or platform so dml M I# #
il o
on nom.oo cm., o. i we p.o one n.
ons on o.ia e. wave.o a canoam Lea -im and arranged as to exclude 4 AM84 & eclosed equipment is h.x abed so that t w.o.e-
.o u
e o
m to ut !
ce bottom of the enclosure is less j,
. m o.-
a ceaw ta*"
persons.
M y
(D)B e1evation of B feet be mort
- tsn 8 feet above the floor, the door d
(11) CZcar spaces. Working space re-a ove t e floor or other won,M agg. cover shall be kept locked. Metal-:c os d
be 9
quired by this subpart may not ace.
y used for storage. When normany en.
(11)ln locations shere electric asquipg y ggg p.g %
eggg p
closed live parts are exposed for in.
ment would be exposed to Dhyskal A 'g.ses, and other similar associated sme m
l j34 spection or servicing, the working damage, enclosures or guardstalbef gggwggg, s et space, if in a passageway or general so arranged and of such streng%.gg@
hpriate caution signs. If equipment sa ta g.ej open space, shall be suitably guarded.
prevent such damage, u A, a rrposed to physical damage from ve-
^""*'
(111) Access and entrance to working (iii) Entrances to rooms and etbee$ h tW Mm ph M u 7 d
- j 4
yd space. At least one entrance of suff. guarded locations containing eWM hrided to prevent such daman,Ven-
.fsting or similar openings in metal-g*
cient area shan be provided to g1re c
y d
ydosed equipment shall be designed access to the working space about elec-jcu wa g
i tat u eq foreign objects inserted j M
4
- - ~
tric equipment, qualified persons to enter'noN+ ab. 40. n a thatrough these openings wiu be deflec F
dv) front working space. Where y
om Over 600 rolts, (h) gl rd Conductors and eqh.on nrdts eneek M Wr dirom energized j
d there are live parts normally exposed 3
nominal shall comply with all apptktd (1) Workspace about equ
.i.no on the front of switchboards or motor Mtat space shall be provided and g y
control centers. the working space in g
front of such equipment may not be g
gg nintained about electric equipment ro, through ig) of this section andM b permit rekdy and r,afe operation y less than 3 feet' on.. Illumination shall yg y
maintenance of such equipment.
(v) Uluminati gg p
Mg,7 rEtre energized parts are exposed.
U g
be provided for all working spaces th W about s mice equipment. switch-M paragraphalMA 4 minimum clear workspace may not tiot 3
(h X3), and thK 4) of this section de'BetW less than 6 feet 6 inches high spa p
'("
boards, panelboards, and motor con-trol centers installed indoors.
apply to equipment on the suppWMM ed vertically from the floor or Ugl 3
4 4W rm), or less than 3 feet wide the j
[,
tvi) Hecdroom. The minimun head' M tM ervice conductors.
{
room of working rpaces about sernee (2) Enclosure for cIcetricaliinstallationadfg depth shall be as required in wg asured parallel to the equipment). ma 2
switchboards.
panel-tions. Electrical boards, or motor control centers shall vault room. closet or in an arWM g, S 2. The workspace shall be ade-oth '
equipment, rounded by a wall. screen,-
g, f t at I t 0 egree tro j f
f be 6 feet 3 inches.
Access to which is controlled Mr M are Now As used in this section a motor con-and key or other approved m A gr nP space. The minimum an'
~f trol center is an assemtdy of one or more en-considered to be accessible to 3.g working space in front of electric sr PQ' closed sections having a common poacr bas 4
{
and prmcipally contaming motor control-persons only. A rail. screend gPment such as switchboards, con-I e
pg DEnels, switches. circuit breakers l
less than B feet in height is D ered to prevent access unl gf r controUers, relays, and similal PC units.
wo I t
(2) Guarding of lit e parts. d) Except other features that pro a:'.ifment may not be less than speci-I as required or permitted elsewhere in isolation equivalent to ig 10 Table S.2 unless otherwise ele,'
Ta I
this subpart, live parts of electric The entrances to all ed in this subpart. Distances equipment operating at 50 volts or or enclosures contairing e be measured from the live parts l
more shan be guarded against acciden-parts or exposed con Eey LPe exposed, or from the enclo-e l
tal contact by approved cabinets or at over 6DO volts n ndet front or opening if the live parta r
'j other forms of approved enclosures, or kept lockei or shall g
661 e
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'l by any of the fonowing means:
?
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