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UNITED ST ATES
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NUCLEAR REGULATORY COMMISSION y*
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475 ALLENDALE ROAD
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8 KtNG OF PROS $tA. P[NNSYLVANIA 19406 1415 J41141932 I am responding to the concerns that you provided to us on April 11 and 12,1991, assertin that Surveillance Procedure SP 2404AH does not establish a purge path and Surveillance Procedure SP 2404 AG does not mention the need to sample for hydrogen when performing calihation activities on RM 9095.
These concerns were referred to Nonheast Utilities (NU) for their evaluation; attached for your information is their response. We have evaluated their response and determined th your concerns were not substantiated. The calibration procedure, SP 2404 AH, incorpora the steps to purge the radiation monitor pig and leaves the actual purging activity to the Operations Department personnel, who are trained on the systems involved. Since the functional test procedure. SP 2404AG, uould not be used to remove the detector from the pig, no hydrogen samp!ing requirement is needed for that evolution. Therefore, no further action is planned by the NRC in these matters, and we consider these concems to be resobed.
We appreciate you informinF us of your concerns and feel that we have been responsive.
Should you have any additional questions regarding these matters, please call me collect at (215) 337-5225.
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Edward Wenzinger, ief Reactor Projects Branch 4
Attachment:
NU Response Letter A09660 of August 16, 1991.
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J August 16, 1991 Docket No. 50-336 A09660
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t RE:
Esployee Concerns l
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Mr. Charles V. Behl Director Division of Reactor Projects
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U. S. Nuclear Regulatory Commission l
Region I 475 Allendale Road l
King of Frussia, Pennsylvania 19406 l
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Dear Mr. Hehl:
i Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0069 l
have completed our review of identified issues concerning activities at Ve 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-the public and placed in the 57C Public Document Foom at your discretion.
The S?C le:ter and our respense have received controlled and limited dir:rdbution en a "need to krev" tasis during the p:eparation of this response.
ISSUE:
In the past, failute to adequately purge and/or sample for hydrogen when performing calibration activities on P3 9095 has resulted in hydrogen explosions in the radiation monitor cabinet. Specifically, Surveillance Pruedure SP 2404.B, Revision 2, does not provide the necessary details to l
appropriately establish or accomplish a hydrogen purge vhen performing calibrations on RM 9095. Additionally, surveillance procedure SP 2404AG dees not rention t'..e need to sample for hydrogen, and this sampling is i
necessary when the jetector is removed from the " pig".
i Request:
discuss the validity of the above assertions.
If deficiencies are Please identified in the applicable procedures, please notify us of the corrective actions you have taken to prevent recurrence.
Please provide us with an assessrent of-the significance with regard to safety of any identified deficiencies.
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U. S. Nuclear Regulatory Cossission l
A09660/Pege 2 s August. 16, 1991 i
Backgrounds l'
SP 2404AH Revision 2 contains the guidance for purging the radiation i
monitor pig and for verifying by chemistry sample that no hydrogen is i
present.
SP 2404AG governs the functional test for the radiation monitor and does not specify renoval of the detector from the pig.
If any.
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calibration activities are required as a result of the (unctional test, the user is directed to procedure SP 2404AB.
Response
The assertion that the surveillance procedure does not contain the necessary level of detail is not accurate. The required steps are included in the procedure and the level of detail is appropriate for the I&C l
j personnel using the procedure.
The actual purging activity is performed by
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Operations personnel.
They are avare of the need to properly purge the-l system to ensure that all residual hydrogen is removed.
4 The assertion that SP 2404AG specifies removal of the detector from the pig, and therefore also requires guidance on snepling for hydrogen, is not The procedure governs functional testing activities which do not-accurate.
inclade detector re= oval.
After our review and evaluation, ve find that this issue does not present any indication of a compromise of nuclear safety. Ve vere not svare of f
this issue prior to receipt of the NRC letter on this subject.
Ve i
appreciate the opportunity to respond and explain the basis of our actions.
1 Please contact ey staf f if there are any further questions on any of these catters.
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Very truly yours, i
4
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NORTBEAST NUCLEAR EST.RGT COMPANY j
2 3
POR:
E. J. Mtoczka l
Senior Vice President
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4 BY:
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V. D. Romberg L/
Vice President i
ect V.
J. Raymond, Senior Resident Inspector, Millstone' Unit Nos.
1, 2 j
and 3 E.
C. Venzinger, Chief.
Projects Branch No.
4, Division of Reactor i
2, Projects
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E. M. Kelly, Chief. Reactor Projects Section 4A
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- i M M ! 4 1992 e
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i WDear' f
I am responding to the concerns that you provided to us on April 11 and 12,1991, asserting f
J that Surveillance Procedure SP 2404 AH does not establish a purge path and Surveillance Procedure SP 2404AG does not mention the need to sample for hydrogen when performing _
calibration activities on RM 9095.
i These concerns were referred to Northeast Utilities (NU) for their evaluation; attached for j
your information is their response. We have evaluated their response and determined that-l your concerns were not substantiated. The calibration procedure, SP 2404AH, incorporates the steps to purge the radiation monitor pig and leaves the actual purging activity to the l
Operations Department personnel, who are trained on the systems involved. Since the j
functional test procedure, SP 2404AG, would not be used to remove the detector from the pig, no hydrogen sampling requirement is needed for that evolution. Therefore, no further j
action is planned by the NRC in these matters, and we consider these concerns to be j
resolved.
We appreciate you informing us of your concerns and feel that we hase been responsive.
3
.i Should you have any additional questions regarding these matters, please call me collect at (215) 337-5225.
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Sincerely, Ortginal S:gned By I
Edward Wenzinger, Chief Reactor Projects Branch 4 4
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Attachment:
NU Response Letter A09660 of August 16, 1991.
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F0lA-p OFFICIAL RECORD COPY f
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l Allegation File: RI-91-A-0069 E. Conner's files l
1 W. RaymondlT, Shediosky Contractor's office files (Meeker) 4 i
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ALLEGATION RECEIPT REPORT ate / Time J
Receivec:
pri l 15, 991 2:000M.
Allegation No. EI-A 00 70 (leave blank)
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Name:
Address:
q Phone:
City / State / Zip:
h
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Confidentiality:
No !
'i Vas it requested?-
Yes Vas it initially granted?
Yes No i
Vas it finally granted by the allegatien panel Yes No _
i Does a conficer.tiality agreerrent need to be sent j
to alleger?
Yes
_ No
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"as a c nfidentiality agreerent been signed?
Yes No i
Veio coeurenting.my it was granted is attached?
Yes No j
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$$$e$ [JtJE80 pesitionnitie:_
i Facility: NRt.$TOGE.1 Docket No.: 50436 j
( Allegation Sumeary (trief description of concern (s): 1) Fan DBE D f uMR A
I P-. 2 DSM 00aEPJJs_ UOT hff?_0PelttTEbl3 40DWGED
.d Peaveultwo %oTrwxe mostens i
Number of Concerns:
3
-i Eeployee Receiving Allegation:
I d hdl6bb6L (first two initials anc last name).
l Type of Regulated Activity (a) [ Vendor (d) _ Other:$afeguards Reactor (b) _ Materials (e) _
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(c) _
(5pecify) t Materials Licer.se No. (if applicable):
I V
Furctional Ares (s): _ (a) Operations (e) Emergency Preparedness i
[{c) Construction
'(f) Onsite Health and. Safety b
( ) Safeguards (g) Offsite Health and Safety:
(c) Transportation (h) Other (NRC Region I form 207 Infor:5. ion h this recq:j ::: deb'.:d Revised 10/89)-
in a::: i:r.ce with the firefn o! In!arnat;an j
Act. e;;ccstscs _ M ?k F0JA.7# -/67-g 97 i-
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DESCRIPTION OF ALLEGATION:
- 1. The alleger became aware that during recent condenser backwashing evolution ( April 12-13), the "C" main circulating water pu=p was tripped by the operators concurrently the D" circulating water pump inadvertently tripped.
The alleger stated no plant incident report was written discribing this event.
In addition, the alleger became aware through discussions with an engineering technician that during the past refueling outare (C+ctcber, 1990) this same event occurred, with no subsequent plant incident report.
The alleger's concerns is that: e) NNECo did not follow the administrative control procedure en issuance of a plant incident report; b) the operations superviecr is trying to ccncel this iesue; and, c) inadequate ccrrective actions for the previous event were manifested in the recent backwashing evolution.
I INSPECTOR RE00!JfENDATION: At the April 15, afterncen planning meeting NUSCo Generatien Test Services was reviewing the sequence of evente report of the circulating water pu=p trip, and prelirine.rly detemined that potentially a timing relay is inoperative in the pu=p.
Inspector review of control room activities, prier to the allegation deter =ined a troublereport is en the circulating water purp.
Turn over to the licensee.
- 2. The alleger submitted on April 3. four (4) stop cards to i
NNECo management for disposition. The stop cerd copies are included. The issue concerns inadequate NNECo response to the elleger s identification of potential OSHA /NEC violations.
INSPECTOR RE0rlNDATION: Inform OSM.
- 3. During recent preventative maintenance activities in early April the alleger identified the follouing issues:
- a. The electrical connection bor. to the "A" char 6 ng pu=p i
motor did not have a casket for the access cover. The "A '
charging pu:p motor is a category I. EEQ component. The alleger based on experienced believed this violate the EEQ configuration for the motor. He consulted EEQ engineer, who told him that the conficaration was acceptable without the gacket, and that it did not violate the EEQ configaration.
The alleger, still believes this is in violation of EEQ
~. I configurations.
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QPR.15'. ' 91 15: 57 HRC MILLSTONE OFFICE PO4 INSPECTOR ASSESSMENT: Turn over to the licensee.
- b. During preventative maintenance work cn the spare boric acid motor in the warehouse, the alleger noted that the motor heaters were not energized to keep the windinga et least 5 degrees F above e.=bient, as the PM card states. The l
alleger notified NNECo management of this issue, approximately two weeks ago and nothing has been done to correct the condition.
INSPECTOR ASSESSMENT: Inspect not only this particular issue on completion of PMa but the generic progra==atic issue on control of CA-CAT I motors in storage.
'I INSPECTOR ASSESSENT:
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4 DESCRIPTION OF ALLEGATION:
- 1. The alleger became aware that during recent condenser l
backwashing evolution (April 12-13), the "C" main circulating water pu=p was tripped by the operators concurrently the D'*_ circulating water pump inadvertent 1_y j
L; tripped.
,f The alleger stated no plant _ incident report was written discribing this event.- In addition, the alleger became eware through discussions with an engineering technician that during the past refueling outage (October,1990) this~
same eUent occurred, with no subsequent plant. incident n },
The alleger ~a concerns is that; a) NNECo did not follow the'-
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administrative control procedure on issuance of a, plant f
incident report; b) the operations eupervisor is trying to
/
concel this issue; and, c) inadequate corrective actions for the previous evens were canifested in the recent backwashin[
l evol'ution.
INSPECTOR RECOt2iENDATION: At the April 15, afternoon planning meeting NUSCo Generation Test Services was reviewing the sequence of e>ents report of the circulating water pump trip, and preliminarly determined that j
potentially a timing relay is inoperative in the pa=p.
- )
Inspector review of control room activities, prior to the l
allegation determined a troublereport is on the circulating l
water pump.
[l Turn over to the licensee.
- 2. The alleger eutaitted on April 3,,four14) etop cards to j
NNECo managenent for disposition. The step card copies are included. The issue concerna inadequate NNECo reepense to _
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the alleger s' identification of potential OSHA /NEC _
a vi61&tierr 7
i INSPEC10R RECOttiENIATION: Inform OSHA.
-r
- 3. During recent preventative maintene.nce activities in early April the alleger identified the fo11 cuing issues:
L
- a. The electrical connection box to the "A'_' charg_ingjust
,i motor _did not have a gasket for th( eccess cov_er.
The "A" i
charging pump motor is a category I, IfQ componint. The
-l alleger based cn experienced believed this viol _at.e_the._EEQ, i
configuration for the motor. He consulted EEQ_ engineer,_who
~ told _him that the configaration was acceptable without the gasket, and that it did not vi late t5e~EM confisuration.
. j still belieyes th_ie.is_in violation _of_EEQ, ne_allegeru configurations.-
Ir.formatica in this re:Ord m; Meed in 2:::rdnce with e f:eedo c! Mrmation -
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Ad, Exemptior.s _
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.a RPR 15 '91 15:57 HRC MILLSTONE OFFICE PO4 t
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INSPECIDR ASSESSMENT: Turn over to the licensee.
- b. Daring preventative ceintenance work on the epare boric acid motor in the warehouce, the alleger noted that the motor heaters were not energized to keep the windinge at i
least 5 degrees F above ambient, as the IM card states. The alleger notified NNECo manaEccent of this issue, approximately two weeks ago and nothing has been done to
-i correct the condition.
INSPECIDR ASSESSMENT: Inspect not only this particular issue on completion of IMa but the generic programmatic issue on control of CA-CAT I motore in storago.
l INSPECIDR ASSESSMEhT:
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