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63 DEC 171991 i
I am responding to the concerns for Millstone Unit 2 that you prov;ded to us on July 12,1991, asserting that: (1) acceptance criteria for the Gammametrics wid nuclear instrumentation procedures are unclear; (2) thermocouple troubleshooting difficulties with the audio monitoring system on the p nuclear instrumentation inoperability on April 22,1991.
These concerns were referred to Northeast Utilities (NU) for their your information is their response. The procedure upgrade program in progress stat:
at Millstone addresses your first concern, although procedures ised for use should n confused with procedures being reviewed. The troubleshooting actions taken in ref items (2) and (3) above were apparently reasonable and appropriate. Therefore, no action is planned by the NRC in these matters, and we consider your first three con be resolved.
Regarding wide range nuclear instrumentation, while your concern for operability in question has not been substantiated, this is a subject that we have addre correspondence (Attachments 2 and 3). Similar concerns for this instrumentation were stated in those letters, inspected approximately one year ago. Because of your continue concern for the problem with " spiking" on channel "C", we have conducted independ inspections of the Unit 2 wide range nuc! car instrumentation. We will inform you o findings from those inspection efforts, and our assessment of their significance, wh report 91-29 is issued. The report will also address related concerns under file number 170.
We appreciate you informing us of your concerns and feel that we have been res a
those concerns. Should you have any additional questions regarding these mat call me collect at (215) 337-5225.
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Sincerely, Inforrnetion in this recc d reas c'Q'ed C"M"' 9Nd Cy in attordante rhth
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Edward Wenzinger, Chief -
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Reactor Projects Branch 4 Attachments:
(1) NU Response Letter A09768 of September 27,1991 (2) NRC Letter dated January 14, 1991
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(3) NRC Irtter had April 10, 1991
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DEC 171931 Dear I am responding to the concerns for Millstone Unit 2 that you provided to us on April 30 and July 12,1991, asserting that: (1) acceptance criteria for the Gammametrics wide range nuclear instrumentation procedures are unclear; (2) thermocouple troubleshooting did not consider electrical environmental qualification (EEQ) checks; (3) there were troubleshooting difficulties with the audio monitoring system on the pressurizer safety valves; and, (4) nuclear instrumentation inoperability on April 22,1991.
These concerns wtre referred to Nonheast Utilities (NU) for their esaluation. Attached for your information is their response. The procedure upgrade program in progress station-wide at Millstone addresses your Grst concern. although procedures issued for use should not be confused with procedures being reviewed. The troubleshooting actions taken in reference to items (2) and (3) abose were apparently reasonable and appropriate. Therefore. no funher action is planned by the NRC in these matters, and we consider your Erst three concerns to be resobed.
Regarding wide range nuclear instrumentation, while your concern for operability on the date in question has not been substantiated. this is a subject that we base addressed to you in past correspondence (Attachments 2 and 3). Similar concerns for this instrumentation were. as stated in those letters, inspected approximately one year ago. Because of your continued concern for the problem with
- spiking" on channel "C", we have conducted independent inspections of the Unit 2 wide range nuclear instru nentation. We will inform you of the findings from those inspection effons. and our assessment of their signi6cance. when NRC repon 91-29 is issued. The repon will also address related concems under Ole number 91 170.
We appreciate you informing us of your concerns and feel that we have been responsive.o those concerns. Should you have any additional ques; ions regarding these matters, please call me collect at (215) 337-5225.
Sincerely,
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informaton in this reter:! was aMed in acccr6nce with the freefc n ciinfcrrnation Act, mm tns jd_4 p Edward W nzinger, Chief F014_
J.;/M Reactor P ojects Branch Attachments: (1) NU Response Letter A09768 of September 27,1991 (2) NRC Letter dated January 14, 1991 (3) NRC Letter dated April 10,1991
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Docket No. 50-336
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A09768 r
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Employee Concerne f
Mr. Charles V. Hehl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission l
Region I l
475 Allendale Road I
King of Prussia, Pennsylvania 19406 I
Dear Mr. Hehl:
l Hillstone Nuclear Power Station, Unit No. 2
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RI-91-A-0079
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Ve have completed our review of identified issues concerning activities at f
Millstone Station. As requested in your transmittal letter, our response.
does not contain any personal privacy.
-proprietary, or safeguards.
Information.
The material contained in these responses may be released to the public and placed in'the NRC Public Document Room at your. discretion.
The NRC transmittal letter and our response have received: controlled and j
limited distribution on a "need to knov" basis during -- the preparation of f
this response. Additional time in which to respond to these issues vas granted by the Region I Staf f in a' telephone conversation on September 19, l
1991.
ISSUE 79-1:
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Procedures being issued in. the 1&C department are inadequate in that acceptance criteria are not being' established for required measurements.-
Specifically a draft copy of procedure IC 2416G vas-provided for review and' it had not incorporated.several comments.that vere raised on previous j
revisions.
These comments included:
- 1) ' An acceptance criterion for-the output' of. the pulse. height discriminator was not. established;
- 2) A precaution vas not added to check the pover supply output _of.the NLV-3'
'draver if the ;Cammametrics pover: supply drops belov 15 volts;- The-l:
Gammametrics ~and~ NLV-3 dravers-share the same'_ pover_ supply and the j'!
Gammametrics output: acceptance criterion is 15 ' + 1.5 VDC vhile = the NLV-3 l_[
output acceptance criterion is 15'+ 0.0075 VDC. Therefore the Gammanetrics 1
draver may be in -specification while the NLV-3'is _out of specification;~ 3)
The proposed acceptance criterion for the discriminator bias voltage vas inadequate at.9 + l VDC; Cammametrics recommends 0.8 to 1.0 VDC.
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A09768/Page 2 Septeaber 27, 1991 i
In addition PORC teeting 2-89-123 authorized change No. 3 to procedure IC 24171-1. The change authorized new settings for NLV-3 draver discriminator.
l voltage.
Section 5.4 of IC-2417I-1 should have also been changed at this tiae, and a discussion section on NLV-3 discriminator settings should have
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been added.
Request 79-1:
Please discuss the validity of the above assertions. Vas the procedure released for use, and if so, was it unusable in this field? Please state whether or not the procedural changes vere required to satisfy regulatory j
requirements, and discuss the review process for procedures and hov comments raised during the procedure reviev are addressed.
Response 79-1:
The assertion that inadequate procedures are being issued in Millstone Unit-No. 2 Instrumentation and Controls (I&C) is not valid.
l The change number and Plant Operations Review Committee (PORC) meeting number stated in the assertion are for a change to the I&C Porm and not the j
procedure as stated.
I6C Porm 24171-1 Section 5.4, was in f act changed in July 1989, to authorize new settings for the NLV-3 draver discriminator voltage.
Discussion sections are not typically added to I&C data sheets l
and none vas added in this case.
Discussion sections are more appropriately included in the body of the procedure.
In this case, a discussion section on the discriminator settings was judged to -not const.itute necessary information.
Ve vere previously aware of the need for revisions' to the procedure at issue and I&C procedure IC 2416G Vide Range Discriminator Adjustment, is currently in the revision process.
The review process for procedure revisions includes incorporation of format changes as required by the procedure upgrade group; a review by the person responsible for the procedure, typically an instrument specialist; and independent reviev and validation activities as deemed necessary. The person responsible for the procedure coordinates the resolution of comments raised through the reviev-process.
Engineering input is solicited as required to resolve issues.
The procedure is then reviewed by the departaent head and presented for PORC approval.
The draft revision has incorporated many changes of both a technical and format nature. The copy referenced has not been issued for use in the field. Comments are still being researched and information is still being l
incorporated.
The changes being made include guidance from Cammametries, the vendor presently responsible for support of the system. When all the 1
existing comments have been resolved the procedure vill be re-routed for r
final comments.
Vhen comments on the final draft are resolved, the r
procedure revision vill be taken to PORC for reviev and approval. The l
procedure vill then be issued for use in the field. This procedure change t
is intended to enhance the use of the procedure in the field and the changes being incorporated vere not the result of any regulatory requirements.
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Mr. Charles V. Behl, Director U. S. Nuclear Regulatory Commission A09768/Page 3 September 27, 1991 P
r ISSUE 79-2:
L disabled ICC thermocouple, it was noted that a troubleshooting a Vhile connector used to perform the troubleshooting was identical to Litton Veam vhat is installed in the ICC system.
The connector used for the Vork troubleshooting vas obtained from the NNECO varehouse and was not E0 order AVO M2-90-13287, used for the troubleshooting, did not reference procedures IC 2421C and IC 2821E, which provide guidance to personnel for t
vorking on Litton-Veam connectors that are E0 I&C department supervisors this section of the ICC systes cabling vas EO. Also the vere unavare that loop folders which vere being used for this work vere out of date.
Request 79-2:
Please discuss the validity of the above assertions. If valid, please discuss actions taken to ensure that EQ requirements vere met in this case.
Response 79-2:
The assertion as stated is not valid. Ve vere made avare of this issue the Automated Vork during performance of troubleshooting activities under Order (AVO).
Troubleshooting is a logical approach to solving a problem.
It is not unusual to use similar, but not qualified, equipment during troubleshooting because this equipment is not left installed in the system.
i The original issue of the AVO did not reference the Electrical Envirenzental Qualification (EEO) maintenance procedures but did contain the inf ormation that the vork vas on an EE0 system. There are no special activities required to maintain the EE0 boundary of this maintenance The procedures centioned in this assertion contain information equipment.
the reactor vessel head cabling removal and testing (2421C) and head on area cabling support system connector assembly (2421E).
The connector assembly procedure (2421E) does not contain maintenance guidance for testing or troubleshooting existing connectors and vas not considered relevant to the AVO. Procedure 2421C contains maintenance information and this reference was added to the AVO job description in response to the l
specialist's questions during the work activity.
The assertion that the loop folders are out of date is not valid as there 7
are no loop folders for the ICC thermocouples.
ISSUE 79-3:
- Recently, a PDCR vhich installed an audio monitoring system on the safety valves was authorired.
The audio system did not pressurizer Also the vire hookup contain a spare hookup as shovn on the PDCR drawing.
in the PDCR shoved two different setups. These problems caused the job to I
be delayed resulting in excessive radiation exposure of the workers.
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wemn%~ aws us Mr. Charlos V. Behl, Director U. S. Nuclear Regulatory Commission l
A09768/Page 4 l
September 27, 1991' i
t Request 79-3:
Please discuss the validity of the above assertions.. If valid, please discuss the methods used to ensure that procedures are technically correct prior to performance and what preparations are performed to ensure worker.
I radiation exposure is minimized.
Response 79-3:
The assertion concerning excessive radiation exposure is not valid. The l
total radiation exposure for the job amounted to 0.24 manrem.
The work i
scope accounted for in this total included construction and removal of l
The extra time in l
staging to accomplish the work on the shield assemblies.
the area that can be attributed to the confusion caused by the drawings and r
procedure figures is approximately 1 manhour, and approximately 0.019 l
manrem.
Vhile any unnecessary exposure is undesirable, this is not j
l considered to be excessive.
Valve Monitoring System (AVMS) installed at Millstone f
Acoustic Flov The 2 utilizes two shield assemblies as was noted in the original and Unit No.
latest revision of the maintenance procedure. The vender drawings shov, l
and technical information states, that the system can be supplied with up i
three charge converters in one shield assembly. The plant drawings and l
installation and maintenance procedure IC 2417T, figures and attachments, to developed from the vendor information and made reference to a third j
converter as being there but not used. A note in the body of the j
vere charge j
procedure states that only two charge converters are used at Unit No. 2.
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The "vire hockup...
setup" refers to the vendor dravings which shov l
different methods for different signal conditioning equipment.
The PDCR correctly referred to the proper method for the equipment installed at l'
Millstone Unit No.' 2.
?
vere made avare of this issue during vork performed under an AVO in May l
Ve 1991.
The installation and maintenance procedure, IC 2417T Eev. 1, has been changed to clarify the internal part arrangement shown in Figure 8.2 and the number of preamplifier assemblies described in Attachment 10.2 to t
indicate that two charge converters are installed.
Also NUSCO drawings 25203-28500 sh. 193, 194, 298, 299, have been revised, via Desi g Change Request (DCR) No. M2-P-015-91, to remove any reference to a spare charge-converter.
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ISSUE 79-4:
On April 22, 1991 the "B" and "D" battery chargers vere removed from their.
normal power supply. Later, a technician performing.a surveillance on the I
"C" train Nuclear Instrument placed the instrument into Test due to a spiking problem.
This action rendered three trains of nuclear I
instrumentation inoperable.. Since the plant was in Bot Standby at the time of the test,- two trains of nuclear instrumentation vere required to be operable. A Plant Incident Report (PIR) vas initiated to document the but the PIR vas later canceled based upon'an interpretation of occurrence the Technical SpecifJeation requirements.
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Mr. Charics V. E;hl, Dirceter
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U. S. Nuclear Regulatory Consission A09768/Page 5 September 27, 1991 Request 79-4:
Please discuss the validity of the above assertions.
Please discuss the basis for the decision not to document the occurrence, if substantiated, with a PIR.
Response 79-4:
The conditions described in the assertion are confusing and could not be substantiated as vritten.
"D" battery charger supplies the turbine battery, has only one power The supply, and has nothing to do with nuclear instrumentation.
There is no entry in the Shif t Supervisor's log that any electrical bus alignments related to nuclear instrumentation vere changed on April 22, 1991.
The nuclear instruments (RPS) are povered from vital 120 vac distribution panels, which are in turn supplied by inverters povered from the vital station batteries. The station batteries each have a dedicated
- charger, and there is a "sving" (backup) charger. None of these systems vere realigned on April 22, 1991.
The Production Maintenance Management System (FMMS) history was reviewed and no work vas found to have been performed on any battery chargers on April 22, 1991, or for a fev days on either side of April 22.
On April 26, performed on the
'C' battery charger, which is the maintenance was non-dedicated charger and vould not have affected the operability of any DC busses.
There is no entry in the Plant Incident Report (PIR) log to suggest that a PIR vas " initiated" on any related topic on April 22, 1991, and neither the Administrative Control Procedure (ACP-0A-10.01) nor NNECO practice allows for PIRs to be " canceled".
Ve vere not avare of this issue as a concern prior to receipt of the NEC transmittal letter.
our reviev and evaluation of these issues, ve find that these issues After did not present any indication of a compromise of nuclear safety.
Ve appreciate the opportunity to respond and explain the basis of our actions.
Please contact my staff if there are further questions on any of these l
matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMTANY E.J./troczka
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Senidr Vice President cc: See Page 6 i
i Mr. Ch:rles V. Echl, Director U. S. Nuclent Regulatcry Commission A09768/Page 6 September 27, 1991 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 J. T. Shedlosky, NRC, Millstone Nuclear Pover Station i
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NUCLEAR REGULATORY COMMISSION g
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Allegations Concerning (1) Wide Range Nuclear Instrumentation
Subject:
l Operability, (2) Operator Attentiveness, and (3) Alignment' of-Reactor Ccolant flow Transmitters,
_l The Regie-1 of fice "as c: pleted its folho in res : se to the concerns you
- ur atte t';n c-Cct;ber 8. :':?: E-d C::::4- :E. :??O allegirg v at.
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(1) wide -a,ge nuclear instrumentation was not cperable as recuired by technical-specifications. (2) rersennel were not attentive to cut es or were sleeping,.
and (2) a'.istrent' of t e reactor coolant fica transmitte-s was rot acccrplisne:
properly.
i We found your allegation concerning the operability of wide range nuclear instrumentation to be unsubstantiated and have documented our findings in NRC 50-336/90-22, section 5.3.3.
We ccnciuded that.at least inspection report, two of the four instru.erts were operable during fuel 0.ement, although one.
channel.as spiking.
We also found your allegation concerning two licensee.:ders who were l
reportedly found asleep to be unsubstantiated and have d:cumented our findings in section 3.7 e i the above noted report. We were unable to confirm that the individuais.ere inattentive or that they cc ;romised w:rk control.
i Finally, we f: na your allegation _ corcerr.ing tne M;r:;t* ali;rment of f react;r coolant flow t.ansmitters to be unsubstantiat2d and deca ented our findings in section 5.3.1 of the above noted report. We concit.ce: that the alignments were completed adequately although a proposed revision to the.al4gnment procedure provided more detailed instructions for use of an improved test rig.
Copies of the above noted reports are attached for your information.
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We' appreciate your informing us of your concerns and feel thatLour actions in this Should you.have any additional matter have been responsive to those concerns.
questions, or if I can of of further assistance in this ratter, please call me
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S ncerely,
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Donald R. Haverkamp, ef l
Reactor Projects Sect on 4A.
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Division of Reactor Projects J. Stewan (2) 7 M. Perkins ORC 1
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NUCLEAR REGULATORY COMMISSION 3'
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KINO oF FRU$stA. PENNSYLVANIA It4M Dociet No. 50 245; 50-336; 50 423 y
License No. DPR-21; DPR-65; NPF-.t9 EA No.90-219 Nonheast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations P.O. Box 270 Hanford, Connecticut 06141-0270 f
Gentlement S;5;ec:
NRC Region 1 Combined lasyction Nos. 50-245;90-20, 50 3M 90-22, 2-d 5 ?.0 90-20 THs :e:te-t'a smi:s the NRC repen of our routire safety inspection that was conducted by.
Ness s D. Dempsey. P. Heicherst,2.c K. Kola zyk of this office on September 15 -
Nosembe: 15., October 2 - Nosernber 15 (and continued December 3-13 to evaluate funher one of tre significant issues descr; bed f.erein), and 0:tober 16 - Nosember 15,1990. for W!s:ene Dus 1,2, and 3, respectisely. At the conclusion of the inspection the findings were diseassed by the above inspectors with Mr. S. E. Scace and other members of your s'aff.
Areas curred during the inspection re descnbed in the NRC Region I inspection repon, w hich is e c:esed with this letter. Wuhin these areas, the inspection consisted of obsersation t
of activities, interviews with personnel, and document reviews.
s Based on me results of this inspection, two apparent violations were identified at Millstone Una : and are te.n; considered for esca'ated enforcement action in accordance with the
' General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Poliep.10 CFR Pan 2, Appendix C (1990). The apparent violations involve the loss of conta mment integrity control as a result of personal errors and are discussed in the Unit 2 operanens and outage sections of the enclosed repon, Specifically, the apparent violations invoh e the loss of containment integrity due to the inoperability of the containment purge valve isolation s,s stem, and in a separate event, the loss of containment integrity via the No. I steam generator atmospheric dump vahe. Accordingly, no Notice of Violation is presently being issued for these inspection findings. Please be advised that the number and characterization of apparent violations described in the enclosed inspection repon may change-as a result of funher NRC review.
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OEc 2 61990 Nonheast Nuclear Energy Company An enforcement conference to discuss these apparent violations at Millstone U scheda!ed for January 15, 1991. De purposes of this conference are to discuss uolations, their causes and safety significance; to provide you the oppodunity to any enors in our inspection repon; to provide an opponunity for you to present preposed correctne acnons; and to discuss ;my c. der information that w You will be the appropnate enforcement action in accoroance with the Enforcement Po adsised by separate conespondence of the results of our deliberations on thi response regarding these apparent violations is required at this time.
The enc:osed report addresses your performance during the recent refi eling and outage on Millstone 2. Overall, we found the control of outage activ> ties effectise management of planned activides and aggressive followup t.f problems i
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thorough evaluation of unplar.ned esents, the extensive suppon by (orporate eng ne d
vendors to disposition of these issues, and the effective interface between site an engineering were notab?e s:rengths. Your assessment of the pesonne l i I
i these oer:s was reps:ed r cur lener to you cated Noserber 5,1990, enc os ng nspect o Reper:.WM 90-1L No:w ?.randing ec tMme cer:Ssion rega d! g genera!!y good performance, we not oc:s c... te to poc~c' ener hat apparer$ resulted from prceedure chah:y a-d adhererae weaknesses. Funher, de faire to sat;sfa:tonly comp r.a a r c :
i fhi 3xp d.mr.g the rep:acement ef i -ccre instrumems that resched in the dropp ng instrument suppon p!a:e was signiEer.t (see section 9.2 of de enclosed repon). O assessment was dat the hft Icel ins'2'!ation ener resulted from a combination o in procedure details. personnel experience, and supenision of the work activ de ens?res the reed f0, g ea:er d::!gence in the review pro:ess for 'tried and prov proced_res :o e! tma:e 2ny oser-re::rce or persenre'. exper;erae for critica Based on the reiuits of this ir.specdon at Mil:s:ene Unit 1, cen2in of your activitie f
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to be m siolation of NRC requirements, as speci6ed in the Notice of Violat on enc ose We are con cmed about the viciation because it invohed the berew:2 as Appendix A.
p r cf W:s:ene 1 with rcn-censersatise setN nts on the steam jet air eject i
You are requaed to resynd to this violation and should follow the instructions specified in Appendix A when preparing your response. In your response momter i
dccument the specific actions taken and any additional acdons you plan to prevent rec After reviewing your response to Appendix A, including your proposed conectiv the results of future inspections, the NRC will determine whether further NRC enf action is necessary to ensure compliance with NRC regulatory requirements.
In addition. cen2in of your activities at Mills?one Unit 2 appeared to be in devia your w-itten commitments, as specified in the Notice of Deviation enclos Appendix B. We are concerned about the deviations because they involv 2
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N Nonheast Nuclear Energy Company reactor protection channels and to operale the loose pans monitor in accordance w Safety Anaj sis Report commitments. You are requested to respond to these de y
should follow the instructions specified in Appendix B in preparing your response.
In accordance with 10 CFR 2.790 of the NRC's
- Rules of Practice," a copy of this letter its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notices are not subject to procedures of the Of5cc of Management and Budget as required by the Pa Act of 1980, Pub. L. No. 96.511.
Your cooperation with us is appreciated.
Sincerely, i
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L t' nm Ch ;es W. Hehl, 3 recter hi -ision of Re2chrirojects '
Enc:cs,.res:
- 1. Appendix A. Notice of Violation
- 2. Appendix B. Notice of Deviation 50-245/90-20;
- 3. NRC Region 1 Combined inspection Repon No.
50-33P90-::: 50 423!90-20 cc w! enc?s:
W. D. Romberg. Vice President, Nuclear Operations D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing l
S. E. Sra:e. Station Director, Millstone H. F. H -pes. N :cler Unit D; rector, Mil: stone Unit 1 J. S. Keenan, Nuclear Unit Director, Millstone Unit 2 C. H. Clement, Nuclear Unit Director, Millstone Unit 3 l
Gera',d Garneld, Esquire Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety information Center (NSIC)
NRC Senior Resident Inspector Sia:e of Connecticut i
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U.S. NUCLEAR REGULATORY COMMISSION REGION I 50 245/90 20; 50-336/90-22; 50 423/90-20 Report No.:
Docket No.-
50-245; 50-336; 50-423 License No.-
DPR-21; DPR-65; NPF-49 Northeast Nuclear Energy Company Licensee:
P O. Box 270 Hanford, CT 06141-0270 Millstone Nuclear Power Station, Units 1,2, & 3 Facility Name:
Inspection At:
Waterford, CT Sep: ember 18 - November 15,1990 (Millstone 1)
D res O.:ober 2 Naenier 15. and Decer.ber 3 - 13,1990 (Mills:cne 2) 0:tober 16 - November 15,1990 (Mdistone 3)
Repo-':np D. A. Dempsey, Resident inspector, Unit i inspe;:ers:
+
P. J. Habighorst, Resident Inspector, Unit 2 K. S. Kolaczyk. Resident inspector, Unit 3 W. J. Raymond, Senior Resident Inspector Inspe : ors:
D. A. Dempsey, Resident inspector, Unit 1 P. J. Habighorst, Resident inspector, Unit 2 K. S. Kolaczyk, Resident Inspector, Unit 3 J. S. Stewan, Senior Project Engineer A. Vegel, Reactor Engineer sWlf/
/2/2,!('$ cs
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<n Apprc'.ed bi:
Donald R. Haverkamp, Chief f Date Reactor Projects Section 4A Division of Reactor Projects Lnrection Summarv: Repon 50-245/90-20; Report 50-336/90-22; Report 50-423/,
instected; Routine NRC resident inspection of plant operations, radiological cont,rols,
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main:enance, surs eillance, security, outage activities, licensee self-assessment, and pe reports.
Results: See Executive Summary i
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.w-J 31 inspector concluded there is no present operability concern with the RPS channels of intert st (RCS flow, RCP speed and zero mode bypass). The functiona] test should be changed to comply with IEEE 338 (1971) for the reasons stated above.
The failure to test the RPS channels as close to the sensor as practicab d nag the monthly funcuonal test is a devianon from a licensee commitment. This is the second of two deviations identified during this inspection (50-336/90-22-03).
5.3.3 Wide Rance Nuclear Instrumentation Ot'erability - Unit 2 Inspector review of refueling activides on October 8,1990, noted that reactor engineering and operations personnel were using wide range nuclear instrumentadon (WRNI) channels A, B, and D, for core monitoring during fuel moves. Channel C was available for indication but was not used to mcet technical specification 3.9.2 requirements.
A tough channel A " spiked" periodically, it was considered by the hcensee to be operable and providing an accurate indicadon of core condinons. It tracked fuel moves and correlated with other monito Operability was demonstrated by completion of the normal sua e;1 ances.
Inspector review of a computer generated plot of the three channels for the day shift showed stable indications for the period with the exceptio of two " spikes." Reactor engineering personnel responded to the spik by treanng them as salid t:ntil prosen spurious by comparison to omer chanr.e!s.
In addition to monitoring count rue during core alterations, data from the WRN] was used to comp!ete 1/M plots for each core insertion.
Inspector review of the WRN1 tabulated data and the 1/M plots showed that at least two channels (more often three) were a! ways available dmn; core aheranons. The spikmg problem on channel A did not preclude using the data to track core conditions during fuel moves
. The mspec:or noted that high reactor boron concentrations (greater than 1950 ppm) resulted in low counts from all WRNI channels (in the range from 1 to 6 cps). The resulting large scatter in the data made the 1/M plots acceptable but minimally effective.
Based on the above, the inspector concluded that the technical specification requirements were being met and that core conditions were being monitored adequately by the licensee during core alteradons.
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UNITEo STATES
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7, NUCt. EAR REGUL.ATORY COMMISSION -
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478 ALLENDALE ROAD I
KING OF PRUSSIA. PENNSYLVANIA 194D6 8Pfl101931 t
The Region I office has completed its followup to the concems that you brought to our i
attention on the dates described. Relevant documentation such as letters from the licensee are attached to this letter. A synopsis of these concerns and our subsequent actions and regulatory conclusions are detailed below.
j On October 8, and October 11,1990, you provided to us a number of concerns associated with Wide Range Nuclear Ir.strument operability. You further discussed this issue with me m i
January,1991. Additionally you provided to us on the same dates, a concern that you were -
r.ot consulted during a recent procedure change associated with surveillance procedure SP-1 2417H, and that this omission was contrary to station procedures. We provided these issues ;
to your employer in a letter dated October 26,1990 and they responded in a letter dated December 21,1990 (attached). Additionally, we inspected the issue of wide range nuclear instrument operability and provided you the results of our investigation in a letter dated January 14, 1991.
Your assertions that spiking hac occurred on the channel "A" of the instrument were true, but inoperability and violations of technical specifications have not been substantiated. With regard to SP-2417H, the licensee admitted that you were not consulted for the procedure change, but no violation of procedures occurred and your allegation appears to be.
unsubstantiated. Furthermore, the procedure change was determined to be adequate. The-NRC is satisfied that the licensee addressed your concems, and we plan no further action in these matters.
i 1
On August 8,1990, you provided us with concerns asserting that (1) work associated with the overhaul of the containment radiation monitor was improperly controlled and (2) a'-
1 bypass-jumper tag was improperly controlled during the maintenance of work ' order M2-90--
08033. We provided these concerns in a letter to the licensee dated October 2,1990 an' the d
licensee responded in a letter dated December 3,1990 (attached).
We note from the licensee response that some problems were identified in the control of work l
associated with the radiation monitor, but it appears from the licensee's assessment that at least one monitor was operable during the times in question in your assertion.
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We note that the licensee identified the problems described in your concern and took proper corrective actions. Further the licensee is implementing additional controls to establish better-
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2 coordination of activities between operations and maintenance. Your allegation that there were problems associated with the control of maintenance is substantiated; however, the NRC considers the problems minor with respect to nuclear safety and notes that appropriate corrective actions have been taken. With regard to issue (2), the pin connector in question was not connected to anything, therefore a bypass tag or a work order would not be appropriate. Your allegation may be true, but is of no consequence. In any case, we are satisfied with the licensee's response and plan no funher actions in these matters.
On November 9, and November 11, 1990, you provided to us (1) a description of events associated with the main turbine stator cooling troub!eshooting, (2) a question as to the propriety of completing the thermal margin low pressure surveillance in Modes 3 and 2, and, (3) a question regarding the testing of the control element withdrawal prohibit alarm. We provided these issues to your employer in a letter dated December 6,1990, and received their response in a letter dated January 4,1991 (attached).
Your assertions regarding issue (1) were determined to be true, but appear to be of no consequence to nuclear safety. He problems had previously been identified by the licensee and appropriate corrective actions appear to have been taken. With regard to issue (2), it appears no violation of technical specifications occurred, and your allegation appears to be unsubstantiated. With regard to issue (3), the alarm testing was determined to be adequate and your allegation appears to be unsubstantiated. We are satisfied that the licensee answered your concerns and we plan no further action in these matters.
On September 28,1990, and in several discussions with NRC personnel during the recent refueling outage, you asserted that there were violations of the ovenime policy at Millstone j
Unit 2. We investigated your assertion and discussed the issue with unit management, but could not substantiate your claim. To enable funher evaluation, more specific details are needed. We note that you have recently provided us a similar concern that overtime restrictions may not have been complied with, and we are inspecting this concern. We will inform you of the results of our inspections when complete.
On September 28,1990, and in a November 5,1990, memorandum to our resident inspector, you provided the NRC with seven concerns involving: (1) the procedural adequacy and implementation of IC 2419C section 5.5.6 which involve the heated junction thermocouple inspection; (2) the instrument calibration review that you initiated; (3) the instrument calibration review that had been initiated associated with test voltages being out-of-specification; (4) a red tag that was improperly hung on the Weidmuller Block TDD; (5) an assertion that an annunciator window change had been improperly handled by the licensee; (6) an assenion that surveillance procedure SP-24011 had not been implemented when an instrument and controls technician tumed in the paperwork without restoring the bypass key; and, ('7) an assenion that you had received harassing mail from a co-worker.
1 3
We refened issues 1 thru 6 to the licensee in a letter dated November 11,1990 and received their response in a letter dated December 21,1990 (attached). We note that the licensee was aware of the discrepancies that you identified in your assertions and had taken actions to correct the deficient conditions when originally identified.
In regard to issue (1), the procedure was written for a skilled instrument and controls technician with experience in this type of maintenance; however, you made no assertion that maintenance was improperly or incompletely performed to the extent that operability of essential equipment was affected. In any case, your allegations appear to be substantiated but of minor significance with respect to nuclear or personnel safety. With regard to issue (2),
the licensee provided us a copy of the instrument calibration review (ICR) and we are
[
providing this copy for your review. Please inform us if you have further questions regarding this matter. With regard to issue (3), the licensee had taken action to address the problem that you described and we have not been informed of any inoperabilities that resulted from the corrective actions. With regard to the drawing concern of issue (3), more information is needed to adequately address your concems. Please inform us of any additional details or further questions that you may have in this matter. With regard to issue (4), a minor tagging discrepancy had been previously identified and was promptly corrected.
Further, guidance on the tagging of Weidmuller blocks was to have been provided to operations personnel. Your allegation in this case appears to be substantiated, but is of little concern with respect to nuclear safety. With regard to issue (5), no prcblems were identified, and no corrective actions were warranted. With regard to issue (6), we note that operations personnel identified the condition that you asser ed and took prompt actions to restore the channel. The technician in this case appears not to have exceeded Unit 2 I
Technical Specification limitations. However, your allegation regarding implementation of the surveillance procedure was substantiated by the licensee. We are satisfied with the licensee responses to these six issues and plan no further action in these matters.
Finally, with regard to issue (7), the NRC cannot take action based on co-worker harassment, especially if the alleged harassment is anonymous. If you feel that you are being harassed by l
your employer, we again remind you to take these issues to the Department of I2bor.
l On September 14,1990, you provided us a three concerns detailing: (1) failure of operators to note that the steam jet air ejector may not be working properly; (2) the failure of your supervisor to respond to one of your questions; and, (3) the failure of another instrument and i
controls technician to follow an unspecified department instraction requiring that a trouble report sticker be attached to an instrument after a problem was identified. We provided your cencerns to the licensee in a letter dated October 4,1990, and they responded in a letter
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dated December 7,1990 (attached).
t With regard to issue (1), the licensee identified no inoperability associated with the radiation monitor, but has identified that upgrade of the system is warranted. The licensee plans to l
replace the monitor in 1991. Your concerns therefore have some validity. With regard to 3
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issue (2), communication between you and your supervisor appears to have been either misunderstood or incomplete. We could not determine the validity of your complaint. With regard to issue (3), the licensee determined that the orange sticker was properly placed for operator information and that work was properly controlled by the applicable work documents. Your concerns in this case appear to be unsubstantiated. We are satisfied with the licensee response to the concems as presented, and the NRC plans no further action with regard to these matters.
We appreciate you informing us of your concerns and feel we have been responsive to those coacems. Should you have any additional questions or if I can be of further assistance, please call me collect at (215) 337-522.5.
Sincerely; I
Am Edward C. Wenzinger, Chief Reactor Projects Branch 4 Attachments: As stated bec:w/o enclosures qj_go.g,yy c(.3.a M. Moore DRMA (6) g g _ gg _g,7,9 g,gg,s J. Stewart ($ t I#*
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W. Raymond R i A - I?L c lo s ted R I A - 150 dor *d R t A -t W cleacc4 i
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Da te/Tirr.e Received: d:tI't1 1:M E.,i, Allegation No. 61-9 f-s9 - e o 82 (leave blank)
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Docket No.: 56 '53 L (Allegatien Summary (brief description of concern (s): (B 40%. Leo FMei
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(d) Transportation-(h) Other:
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