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TO-4 0 The NRC Region 1 office has completed its followup of the concerns that you brought to our attention on April 9,1991 regarding: 1) harassment related to your 1990 performance appraisal;
- 2) improper controls associated with a "fitup" inspection of the steam generator air ejecter radiation monitor housing; 3) inadequate training for technicians performing fire protection surveillance and monthly function surveillance SP 2410A; 4) drawing omissions associated with modification package PDCE M2-90-032; and 5) " unrelated, obscene criteria" on two Millstone l
Unit 3 PORC approved IC procedures. Our resolution of these concerns is discussed below.
j As stated in our acknowledgement letter to you, dated May 17,1991, we referred your concerns 2,3 and 4 to Nonheast Utilities. We evaluated the enclosed licensee *s responses. Concems 2 and 3 were substantiated. Regarding Concern 2, the licensee characterized this as a one time l
lapse in attention to detail in documentation of fitup inspections on non-QA Category I structural installations. Regarding Concem 3 the iicensee determined that the procedures were completed l
competently and safely. Concem 4 was not substantiated, since no work control deficiencies were found. Additionally, we received no funher information from you regarding Concem 4 We consider Concerns 2,3,4, and 5 to be resolved and we plan no funher actior. Thank you for informing us of your concerns.
i Sincerely, 4
i ward Wenzinger, Chi
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Reactor Projects Branc. 4 Enclosures-i NU Ixtter A09594, dated July 10,1991 NU Letter B13905, dated August 9,1991 Informatica in this retcrd rm ce,yed in accordance,Wth t';e FreW: cf inferaation 9303220162 921217 Act, enmms 6/76 l
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August 9, 1991 Docket No. 50-336 B13905 r
Mr. Charles V. Behl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I i
475 Allendale Road King of Prussia, Pennsylvania 19406 l
Dear Mr. Hehl:
f Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0064 have completed our review of identified issues concerning activities at Ve Millstone Station. As requested in your transmittal letter, our response any personal
- privacy, proprietary, or safeguards f
does not contain i
The material contained in these responses may be released to information.
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 i
response.
i 10, 1991 (A09594) addressing Issue 1 of RI-91-A-0064, In our letter of July addressed the technical aspects of the prefabricated structure for the
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ve steam jet air ejector monitor.
Ve vould like to supplement that information at this time with additional background.
l new NU vas avare of the situation throughout the entire process. The inspector l
vho questioned. the fit-up inspection, documented the condition on a
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Non-Conformance Peport on March 28, 1991 in. accordance with our. quality program.
Functional line and station management became. involved in the i
resolution and recommended corrective action options on April 2, 1991.
This is the same date on which the Nuclear Safety Concerns Program (NSCP)
The NSCP also contacted on a confidential basis regarding this issue.
vas 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 sanagement review of this situation for generic implications was completed on May 17, 1991, two weeks before the NRC Staf f's letter was issued to NNECO.
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0 Mr. Charles U. Behl, Director U. S. Nuclear Regulatory Commission i
B13905/Page 2 August 9, 1991 t
of our ongoing information to assure you provide the above background efforts to bring all concerns to prompt and thorough resolution.
Ve ISSUE 2r assigned fire On April 8, 1991, a NNECO technician and a contractor vere protection surveillance, IC-2439A.
The NNECO technician had never been trained on the surveillance procedure.
On April 3,
1991, another technician vas performing monthly function surveillance SP-2410A for the associated with the pressurizer relief valves.
This was the first time the technician had performed the acoustic valve monitoring system since the last major revision and again, there had been no on the conduct of the procedures with the incorporated revisions.
surveillance technicians experienced difficulty in completing the training In both cases, the procedures and numerous questions vere raised.
discuss the validity of the above assertions.
Please discuss training prior to performance of complex surveillances especially Please to first time assignment and performance subsequent employee in cases involvingPlease discuss any corrective actions that you have taken the surveillances are completed major revisions.
or vill take in these cascs, to ensure that competently and safely.
Background:
I&C Procedure SP-2439A A review of the completed data sheets indicates that the Instrumentation and Controls (I&C) procedure was performed competently and safely. The technician assigned to this work had worked on various components of the 13 times since February 11, 1987, with fire protection system a total of the most recent vork effort being May 23, 1991. While working on the system the technician has demonstrated to his management his competence an understanding of the system and individual components.
This technician has worked on the fire protection system both alone and i
Vhen questions have arisen in the past he with other members of the shop.
has not been reluctant to stop and resolve those questions before the decision to assign him All of the preceding facts led to the performance of IC 2439A continuing.
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perform the procedure in question.
there vere no unresolved questions that were brought to the attention of to i
I&C supervision.
l I&C Procedure SP-2410A had not received perform this surveillance Both technicians assigned to on-the-job training (0JT) specifically for this procedure revision. They vere, however, interim qualified due to their past experience in performing the procedure.
Each technician had successfully performed previous Since 1984, one technician had participated in revisions of the procedure.
the performance of this procedure 9 times and the other technician 4 times.
4 times had not done so The technician who had performed the procedure since 1988.
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V we, Mr. Charles V. Hahl, Director U. S. Nuclear Regulatory Commission B13905/Page 3 August 9, 1991 I
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Response
The two assertions are accurate. However, it should be noted that it is NNECO's expectation that all procedures vill be performed without any questions by all workers.
Difficulty may be experienced in performing a l
not task that has not been performed for a period of time. Personnel are to have a questioning attitude toward their vork and are expected encouraged to seek assistance from others in the shop.
the case of the surveillances identified, the results of the work have In been revieved and found acceptable.
The procedures vere completed coepetently and safely.
The personnel involved in these vork activities were both Level 2 qualified allows them to vork independently on the majority of Hillstone Unit which The process for training personnel to work on surveillances No. 2 systems.
is to assign less experienced personnel to work with experienced personnel.
allows for the transfer of knowledge and experience. The OJT program t
This 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:
M2-90-032, draving arrors During performance of modification package PDCE noted for radiation monitor RM-9095. The errors involve the omission of a terminal beard between the 120 VAC power supply and the radiation vere 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 deficiencies, in general.
Response
Documents," and ACP-0A-3.24 ACP-0A-3.14
" Design Change Notices For Detign "Draving Change / Submittal Requests," provide the necessary guidance to anyone who feels that a drawing change is necessary. A review of the Generation Records Inforration Tracking Sy s t em (GRITS) shoved no open for this PDCE. Since the change records for any of the reported drawings 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. Behl, Director U. S. Nuclear Regulatory Commission B13905/Page 4 August 9, 1991 A review of the reported dravings was performed in order to determine exactly what changes might be required to respond to this assertion. No deficiencies vere apparent.
Unless more specific identification of the 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 l'
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 vork control deficiencies vere found during this reviev.
I Our review and evaluation finds that the above assertions did not present indication of a compromise to nuclear safety. Ve vere not avare of l
these two issues prior to the receipt or the Staff's letter. Ve appreciate any 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, NORTEEAST NUCLEAR ENERGY COMPANY l
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E. J.. fbc:ka-jf Senior'%
Vice Tresident cc:
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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 F
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July 10, 1991 l
Docket No. 50-336 j
A09594 Mr. Charles V. Behl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I j
475 Allendale Road i
King of Prussia, Pennsylvania 19406 i
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Dear Mr. Hehl:
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Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0054, Item 1
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-i Ve have reviewed the identified issees concerning activities at' Millstone i
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, we asked for additional time to respond to the issues contained in your. letter of May 22.
1991, (File Number RI-91-A-0052).
An extension to July 26, 1991,
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vas 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 i
May 22, 1991, letter (RI-91-A-0052). The review of the training issue in.
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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 l
Additional time is needed to review the close out documer.tation prior
- t out.
to responding.
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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.
i Ve nov ask that the extension be granted, however, because of the close
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relationship to issues that vill be addressed in our response to
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RI-91-A-0052 and the need for more time to permit us to address those
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issues adequately. The basis for this additional-extension vas discussed with the NRC Staff on July 10, 1991.
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Mr, Charles U. B:bl, Director U.S. Nuclear R gulatory Commission A09594/Page 2 l
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 QC inspector was called by Generation Construction to i
perform a final veld inspection of a prefabricated structure for the new steam jet air ejector monitor. The final inspection was part of procedure l
GVS-006.
After the inspection, the OC inspector questioned if a " fit-up"
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inspection had been completed, as required by procedure. The fabrication and assembly of the structure vere non QA, 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 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 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 docucented on the Inspection Plan. The velder then finishes the veld.
using the fit-up information to ensure correct final veld dimensions.
Vhen the OSD inspector was called for the final visual inspection, no objective evidence was available to demonstrate that the fit-up had been performed.
The fit-up vas, in fact, signed off three days later, by the Job Supervisor.
Follov-up discussions with all personnel involved could neither clearly substantiate nor disprove the performance of the fit-up inspection, since the fit-up signature was dated three days af ter 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 taken to destroy the support (vitnessed by OSD) and rebuild it.
3 r., Charles V. Behl, Director l
M U. S. Nuclear Regulatory Commission A09594/Page 3 l
l July 10, 1991 Heetings vere held with the departments involved with this vork. The responsibilities of each department vere reviewed. The need to follov i
procedure requirements and the requirement of the job supervisor to document' actual fit-up inspections on non-0A Category I structural 4
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 vere avare of the procedure requirements and thought that they vere in full compliance vith them.
Inattention to detail by a failure to document a fit-up I'
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 corrective action is appropriate.
i After our review and evaluation, ve find that this item does not present i
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 s
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E. J.
.r.z y.a Senior Yice President cc:
V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, I
and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor Projects I
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Dear!
hjW N' The NRC Region I office has completed its followup of the concerns that you brought to our attention on April 9,1991 regarding: 1) harassment related to your 1990 performance appraisal;
- 2) improper controls associated with a "fitup" inspection of the steam generator air ejector radiation monitor housing; 3) inadequate training for technicians performing fire protection surveillance and monthly function surveillance SP 2410A: 4) drawing omissions associated with modification package PDCE M2-90-032; and 5) " unrelated. obscene criteria" on two Millstone Unit 3 PORC approved IC procedures. Our resolution of these concerns is discussed below.
As stated in our acknowledgement letter to you, dated May 17,1991, we referred your concerns 2,3 and 4 to Northeast Utilities. We evaluated the enclosed licensee's responses. Concerns 2 and 3 were substantiated. Regarding Concem 2. the licensee characterized this as a one time lapse in attention to detail in documentation of fitup inspections on non-QA Category I structural installations. Regarding Concern 3, the licensee determined that the procedures were completed competently and safely. Concern 4 was not substantiated, since no work control deficiencies were found. Additionally. we received no further information from you regarding Concern 5.
We consider Concerns 2,3,4. and 5 to be resolved ar.d we plan no further action. Thank you for informing us of your concerns.
Sincerely.
Original $;gngg By Edward Wenringer, Chief Reactor Projects Branch 4
Enclosures:
Irfm stian in this record r!.s de'eted NU Letter A09594, dated July 10,1991 n accctdm er th tSe freedom of in%rmation NU Letter B13905, dated August 9,1991 A:teua;tras__lf_2C FD;4-93 -/4;?.
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