ML20080K689

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Discusses Review of RI-91-A-0231 Re Various Activities at Millstone Unit 2.W/related Matl
ML20080K689
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/23/1991
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20079Q807 List:
References
FOIA-92-162 A10020, NUDOCS 9503010223
Download: ML20080K689 (30)
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Text

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?- NORTHEAST UTIMTIES o.n.,.i c%c.. . s.io.n su . B.n.n. Conn.ci,cui 5 )s.Y E Ib 2.7ac $ *~*

m ee n. . co.**' P O BOX 270 k k J C IC 2.7, 7 HAATFORD. CONNECTICUT 06141-0270 (203) 665-5000 December 23, 1991 Docket No. 50-336 A10020 Re: Employee Concerns Mr. Charles W. Hehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 i

Dear Mr. Hehl:

Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0231 We have completed our review of identified issues concerning activities at Millstone Unit No. 2. As requested in your transmittal letter of November 19, 1991, our responses do not contain any personal privacy, proprietary, or l 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 responses have received controlled and limited distribution on a "need-to-know" basis during the preparation of these responses.

ISSUE 02: . .c "P' ant Operation Review Committee (PORC) actions are superficial. There are different calibration accuracy requirements between the Steam Generator radiation monitor functional test procedure (SP 2404A1), recently reviewed by the PORC, and a referenced source. Procedural problems also exist in the RBCCW [ reactor building closed cooling water] radiation monitor calibration procedure, which was also recently reviewed."

REQUEST:

"Please discuss the validity of this assertion. Please provide assurance that h the calibration accuracy requirements are correct and consistent and that procedural problems in the RBCCW are resolved."

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~t Mr. Charles W. Hehl A10020/Page 2 December 23, 1991

RESPONSE

Without knowing the identification of the " referenced source," it is difficult to determine the validity of the assertion.

The procedure at issue is a functional test procedure rather than a calibra-tion procedule so the reference to " calibration accuracy" is unclear. For the ,

purpose of this response we have assumed the assertion was made in connection with a change made to Instrumentation and Controls (I&C) Form 2404Al-1 which is the form used by the procedure at issue.

Technicians performing this procedure in late October 1991 stopped when they noted that the procedure data sheet specified a high/ fail / alert bistable set point tolerance different from the Operations Department calculation on OPS Form OP2383C-1. I&C Form 2404AI-1 specified a flat + 20 percent toler-ance, while OPS Form 2383C-1 provided a tolerance that depended on the posi-tion of the set point within the decade (on a logarithmic scale). Both methods are acceptable to the NUSCO Radiation Assessment Branch (RAB) and yield tolerances that are within the 20 percent values that are expected for the radiation monitor. The I&C form was changed on October 23, 1991, to coincide with the operations specified values. Following the change, the procedure was completed satisfactorily.

There is no safety or generic significance to this assertion. We were not l aware of this concern prior to receipt of notification from the NRC. I Our response to issue RI-91-A-0238 dealt with Procedure SP 2404AW for the RBCCW liquid radiation monitor. '

ISSUE 04:

"The RBCCW radiation moniter (RM 6083) sample valves are not labeled.

Additionally, the piping and instrumentation drawing (P&ID) 25203-26022, Sheet No. 1, does not reflect the actual installed configuration of the sample lines. (This concern is similar to issue 210-1 referred to you by letter under File Number RI-91-A-0210, dated August 22,1991.)"

REQUEST:

"P? e >.se discuss the validity of this assertion. Please provide assurances l that the RBCCW radiation monitor (RM 6083) sample valves will be labeled in i the future and that piping and instrumentation drawings will reflect actual  ;

conditions."

i i

h Mr. Charles W. Hehl A10020/Page 3 December 23, 1991

RESPONSE

With respect to the valvo labeling issue, this assertion is a statement of fact describing the normal operating practice concerning the labeling of valves internal to vendor-supplied eauipment.

~

The ra'dIationmonitoratissue is a " skid-mounted" piece of equipment which senses radiation levels in the RBCCW process fluid and provides local and remote annunciation on high radiation. It is our standard practice that valves internal to the radiation monitor skid are not assigned unique numbers and labeled during installation. These valves are not used to operate the equipment, therefore, there is no requirement that we provide Millstone Unit No. 2 specific valve numbers or show the valves on applicable P& ids. The valves external to the radiation monitor skid were labeled as part of our ongoing labeling project for Millstone Unit No. 2.

With respect to the PSID sheet, this assertion is is a true statement but does not represent a valid safety concern. The drawing at issue has been checked against actual syste m and the installed configuration of the sample lines was correct. However, a difference was found in that the lead brick shielding, which was removed when the monitor was upgraded to a unit not requiring additional shielding, is still shown on the drawing. A drawing change has been issued to eliminate the lead bricks shown on the P&ID.

We were not aware of this concern prior to notification by the NRC.

ISSUE 06:

"I&C technicians incorrectly started the Steam Jet Air Ejector (SJAE) radia-tion monitor (RM 5099) with the sample pump inlet valve shut. Subsequently, the motor failed to re-start. The sample pump was started by I&C Department personnel. It should have been operated by Operations Department personnel."

pef}UEST:

"Please discuss the validity of this assertion and provide assurances that the stated problems with regard to the SJAE radiation monitor system operation are resolved with regard to safety requirements."

GENERAL REQUEST:

"Please provide your review of the above assertions. If the above conditions are valid, notify us of the corrective actions you have taken to prevent recurrence. Also provide us with an assessment of the safety significance of any identified deficiencies, including generic considerations."

N Mr. Charles W. Hehl A10020/Page 4 December 23, 1991

RESPONSE

This assertion is not valid. A review of work performed on this radiation monitor over the last six months was conducted. No documented instance of the above alleged activities by I&C technicians was found. Discussions with I&C and Operations Department staff personnel identified no similar concern or generic problem. The operation of the RM-5099 radiation monitor is indepen-dently verified by the performance of Surveillance Procedure SP2404AT, " Steam Jet Air Ejector Radiation Monitor (RM-5099) Functional Test," prior to return-ing to service. Operations Procedure OP2383A also verifies proper start-up and operation of the sample pump, and it is performed by Operations department personnel.

We were not aware of these assertions prior to receipt of notification from the NRC. .

After our review and evaluation of these issues, we find that these issues did not present any indication of a compromise of nuclear safety.

We appreciate the opportunity to respond and explain the basis of our actions.

Please contact my staff if there are further questions on any of these matters.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY d

h J. F. Opeka

-h w Executive Vice President cc: W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 E. C. Wenzinger, Chief Projects Branch No. 4, Division of Reactor Projects E. M. Kelly, Chief, Reactor Projects Section 4A J. T. Shedlosky, U.S. Nuclear Regulatory Commission, Millstone

i SAMPLE RECORD OF ALLEGATION PANEL DECISIONS SITE: M' N"' E PANEL A'ITENDEES:

ALLEGATION NO.: 9i- A L023 Chairman - Wa>4'O

! DATE: F ltfI MI (Panel No.12-74 5) Branch Chief -

PRIORITY: High @ ediU D 1A w Section Chief (AOC) - 6 KSIIe 1 SAFETY SIGNIFICANCE: Yes No@ Sr. Allegation Coord (SAC) E W rhe.--

1 CONCURRENCE 01 Reoresentative - J. to lle cr TO CLOSEOUT: DD BC SC (Other) D . 4, t.A 1

CONFIDENTIALITY G (See Allegation Receipt Report)

ED: Yes No p g'/ gg l IS THERE A HARASSMENT / DISCRIMINATION

ISSUE: Yes No l IF YES, <

l 1) has the individual been informed of the DOL

! process and the need to file a complaint within 30 days Yes No

2) has the individual filed a complaint l with DOL Yes No

! 3) has a letter been sent to the complainant seeking Yes No -

l any safety concerns  ;

IS A CHILLING EFFECT LETTER WARRANTED
Yes No 1 IF YES, HAS IT BEEN SENT Yes No l HAS THE LICENSEE RESPONDED TO THE CHILLING EFFECT LETTER: Yes No ACTION:

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NOTF3:

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llT ALLEGATION MANAGEMENT SYSTEM ALLEGATION NUMBER - RI-91-A-0232 RUN DATE: 09/11/91 DOCKET / FACILITY / UNIT: 05000336 / MILLSTONE 2 /2 DOCKET / FACILITY / UNIT: / /

DOCKET / FACILITY / UNIT: / /

DOCKET / FACILITY / UNIT: / /

ACTIVITY TYPES-- REACTOR MATERIAL LICENSES -

FUNLTIONAL AREAS -

OPERATIONS DESCRIPTION - 1) RCP OIL LEVEL INSTRUMENT PROBLEMS

2) INADEQUATE MAINTENANCE ON WAREHOUSE STOCK PARTS
3) LOOP FOLDERS MAINTAINED BY I&C ARE INADEQUATE CONCERNS - 4) I&C WORKLIST INPUT SHOWING STATUS OF ALLEGATIONS MADE TO 4 NRC SOURCE - LICENSEE EMPLOYEE CONFIDENT - NO RECEIVED - 910821 BY - JT SHEDLOSKY / RI ACTION OFFICE CONTACT - EM KELLY - (FTS)346-5183 SAFETY SIGNIFICANCE - UNKNOWN BOARD NOTIFICATION - NO STATUS - OPEN SCHED COMPLETION - 911231 DATE CLOSED -

ALLEGATION SUBSTANTIATED - ALLEGER NOTIFIED -

OI ACTION - OI REPORT NUMBER -

REMARKS - RECEIVED AT RESIDENT OFFICE BY MEMO, WITH SUBSEQUENT UPDATE.

PANELED 28AUG91.

SUPPORT OFFICE: RPS-4A ACTION PENDING: REFER TO LICENSEE DOCUMENTATION:

ALLEGER LAST CONTACTED: 22AUG91

REFERENCE:

KEYWORD: INSTRUMENTS, MAINTENANCE ENTERED SYSTEM - 910903 CLOSED SYSTEM - RECORD CHANGED - 910903 v 1

I ,

it LIMIT E ENCLOSURE Concerns RI-91-A-0232-01 and RI-91-A-0263-01:

There were two examples of alleged inadequate control and maintenance of equipment spare parts. First, that a spare power supply in the warehouse (SPM 798, revision 16, item 34) for the "B" RCP lower oil reservoir level alarm unit allegedly did not receive a capacitor change out, as did the in-service power supply units. Allegedly, PMMS item M2-02-ENV-PWR-X-20 (Serial No.10521) typified a maintenance history record for a power supply replacement. Second, that an RPS spare component, the Auxiliary IAgic Drawer identified in Concern RI-91-A-0263-02, allegedly lacked a modification (three versus four amber indicating lamps).

Concern RI-91-A-0263-02: .

Allegedly, a spare RPS Auxiliary legic Drawer allegedly was used to support troubleshooting, on or about October 1,1991, of a power supply relay failure within the same drawer in RPS channel "D," but was not installed in place of the failed drawer.

Allegedly, the spare RPS Auxiliary logic Drawer lacked some original parts (three lamps).

Concern RI-91-A-0232-02:

On or about August 16, 1991, Loop Folders for the "B" RCP oil reservoir alarm instruments allegedly did not reflect the actual physical location of specific power supplies. Allegedly, some boards had five separate power supplies within the power supply unit.

Concern RI-91-A-0232-03:

On or about August 16, 1991, Loop Folders for the "B" RCP allegedly did not provide information regarding which additional instrument loads powered from each power supply. For example, power supply X-21 supplied several other instrument loops in addition to the "B" RCP upper and lower oil sump levels. "The individual doing the work believed this information was considered essential to preclude the loss of power to other instrumentation when performing maintenance on an instrument loop component.

.O TRIBUT . .' T FOR PUBLIC DISCLOSURE i

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-NOTFO BLIC CLOS Concern RI-91-A-0232-04:

On or about August 16, 1991, Instrument Record Sheets for the "B" RCP upper and lower oil reservoir level transmitters (LT-176 & LT-177) allegedly were missing from the Instrument loop' Folders.

t Concern RI-91-A-0232-05:

There were allegedly nuisance alarms, associated with the "B" RCP upper and lower oil reservoirs, caused by mechanical action within the RCP oil reservoirs (reference AWO M2-91-08614).

Request:

Please provide your review of the above assertions. If the above conditions are valid, -

notify us of the corrective actions you have taken to prevent recurrence. Also provide us with an assessment of the safety significance of any identified deficiencies, including generic considerations.

In addition to the above general request. please provide your review of the following specific questions. Are spare parts, that are either located in the warehousets) or used for troubleshooting, controlled and maintained in accordance with the NU QA Program?

Is there a mechanical problem with RCP oil sump levels? Does Unit 2 administratively control I&C documentation in a manner consistent with the methodology used for Units 1 and 3 and with the NU QA Program? Is Departmental Instruction 2 I&C-10.03, Establishing and Maintaining Instrument Records, adequate for administrative control of I&C documentation? In general, do loop folders adequately identify instrument loads for each power supply?

_ LIM IS fl . NOTFO PUBLIC SCLOS l l

,- i 1- q h UTION - DISC RE l l

ENCLOSURE o

Issue 230-1: -

i Two (2) examples were found in which the calibration conversion factor for the condensate demineralizer waste neutralization sump radiation monitor were incorrect. The deficiencies i were found during the performance of surveillance SP-2404AP, Waste Neutralization Sump '

Radiation Monitor (2-CND-RM-245) Functional Test; these deficiencies were documented on '

Instrument Calibration Review (ICR) Forms91-065 and 91-066, which were dated August 12 and 16, respectively. They both reference automated werk order (AWO) M2-91-06944. >

-i Request:

Please discuss the validity of this assertion and discuss actions taken to prevent occurrences -l ,

such as these in the future.

P Issue 230-2: i Discovery of a non-metallic "o"-rings used with fittings on the turbine hydraulic control-valves. Although recognized as improper material, the "o"-rings were reused pending l further investigation.

1 Request: l Please discuss the validity of this assertion. Please discuss actions taken to prevent the reuse f of "o"-rings of improper material in the turbine hydraulic control system.

LIMITED DI - NOT F UB DISCLOS l

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AlL.L!E G A T I O N M A N A G E.M E'N T SYSTEM

^

ALLEGATION, NUMBER - RI-91-A-0230 RUN DATE: 09/11/91-DOCKET / FACILITY / UNIT: 05000336 / MILLSTONE 2 / 2L

/

-DOCKET / FACILITY / UNIT: / -'

DOCKET / FACILITY / UNIT: . / /

DOCKET / FACILITY / UNIT: / /  ;

ACTIVITY TYPES - REACTOR-e MATERIAL LICENSES -  ;

FUNCTIONAL AREAS- -

OPERATIONS t

DESCRIPTION - EXAMPLES. GIVEN OF 2 OCCASSIONS WHEN THE CALIBRATION "

CONVERSION FACTOR FOR THE CONDENSATE DEMINERALIZER WASTE NEUTRALIZATION SUMP WAS FOUND TO BE INCORRECT. ALSO GAVE i CONCERNS - EXAMPLE OF REUSE OF IMPROPER O-RINGS IN TURBINE EHC SYSTEM.

2 -

t SOURCE - LICENSEE EMPLOYEE CONFIDENT - NO ,

RECEIVED - 910820 BY - JT SHEDLOSKY / RI l t

ACTION OFFICE CONTACT - EM KELLY -

(FTS)346-5183 .t SAFETY SIGNIFICANCE - UNKNOWN BOARD NOTIFICATION - NO STATUS-- OPEN SCHED COMPLETION - 911231 DATE CLOSED -

ALLEGATION SUBSTANTIATED - ALLEGER NOTIFIED - l I

.OI ACTION - OI REPORT-NUMBER - l REMARKS . RECEIVED AT RESIDENT OFFICE BY MEMO, WITH SUBSEQUENT UPDATE.  !

PANELED 28AUG91. j i

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SUPPORT OFFICE: RPS-4A i ACTION PENDING: REFER TO LICENSEE j DOCUMENTATION: j ALLEGER LAST CONTACTED: 22AUG91  ;

REFERENCE:

KEYWORD: RAD MONITOR, EHC [

ENTERED SYSTSM - 910903 CLOSED SYSTEM - RECORD CHANGED - 910903  ;

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ALLEGATION NO.: 1-9 ' O Y O N Chairman - NeIt f DATE: M ME (Panel No. 1 2 3 4 5) Branch Chief -

PRIORI?Y: High Medium h Section Chief (AOC) - 6 SAFr' SIGNIFICANCE: 'Yes h Unkn Sr. Allecation Coord (SAC) east f.d CONCURRENCE TO CLOSEOUT DD BC SC OI Reoresentative - V i CONFIDENTIALITY GRANTED:

(See Allegation Receipt Report)

Yes h (Other)

J ISSUE: ?es N IS THERE A HARASSMENT / DISCRIMINATION IF YES,

1) has the individual been informed of the DOL Yes No process and the need to file a complaint within 30 days Yes No
2) has the individual filed a complaint with DOL ?es No
3) has a letter been sent to the complainant seeking any safety concerns Yes No IS A CHILLING EFFECT LETTER WARRANTED: ?es No IF YES, HAS IT BEEN SENT Yes No HAS THE LICENSEE RESPONDED TO THE CHILLING EFFECT LETTIR:

RESP ECD ACTION:

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' INST'AUMENTATION .

RADIDACTIVE LIOUID EFFLUENT MONITORING INSTRUMENTATION

_ LIMITING CONDITION FOR OPERATION

'3.3.3.9 _

sh:wn in Table 3.3-12 shall be QPERABLE with applicable ala set to ensure that the limits of Specification 3.11.1.1 are not exceeded.

-described in the ODCM.setpaints shall be determined in accordanceThe with methods and p, w

APPLICABILITY: As shown in Table 3.3-12.

ACTION:

a. With a radioactive liquid effluent monitoring ,

instrumentation channelspecification, above alarm / trip setpoint less conservative than required by the without delay suspend the release of radioactive liquid declare the channel inoeffluents monitored by the affected channel, or acceptably conservative. perable, or change the setpoint so it is b.

With the number of channels less than the minimum channels operable requirement, take the ACTION shown in Table 3.3-12.

Exert best 30 daystoand, efforts restore the inoperable monitor to OPERABLE status within if uns,uccessful , explain in the next Semiannual Effluent Report why the inoperability was not corrected in a timely manner.

specified Releases actions are need not be terminated after 30 days provided the continued.

c.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS .

4.3.3.9 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOUR CHECK, ,

frc auencies shown *a Table 4.3-12. CHANNEL CALIBRATION, at the and CHANNEL F t

LLSTONE - UNIT 2 ,

3/4 3-50 Amendment No. JR/ ,151

January 1, 1986 C.

7 s

l TABLE 3.3-12 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUNENTATION u ALARM MINIMUN # SETPOINT INSTRUMENT OPERABLE REQUIRED APPLICABILITY ACTION

1. Gross Radioactivity Monitors Providing Automatic Termination of Release .
a. Clean Liquid Radweste Effluent Line 1 Yes
  • 1.
b. ~ Aerated Liquid Radwaste Effluent Line 1 Yes
  • 1 M c. Steam Generator Blowdown Monitor or Condenser Air Ejector Monitor 1** Yes *** 2 Y

$ d. Condensate Polishing Facility Waste Neut Sump 1 Yes 1

2. Gross Radioactivity Monitors Not Providing Automatic Termination of Release i
s. Reactor Building Closed Cooling Water Monitorf 1 Yes
  • 3
3. Flow hete Measurements
a. Clean U quid Radwaste Effluent Line 1 No
  • 4 2 b. Aerated Ligaid Radwaste Effluent E. Line 1 No
  • 4 2

3 c. Condensate Poliseitng Facility Waste Neut Sump Discharge Line 1 No

  • 4
d. Dilution Water Flow ff No
  • NA
e. Steam Generator Blowdown Line fif No
  • NA

February 23 1988 TABLE 3 3-12 (Continued)

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUENTATION Table Notes

t all times - which means that channels shall be OPERABtE and in service on a continuous, uninterrupted basis, except that outages are permitted, for a maximum or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance or required tests, checks, calibrations, or sampling. ,

Although both monitors are normally operable, only one is necessary as the activity measured by each can be related to the other, and both monitors are capable or automatically isolating the steam generation blowdown.

Modes 1-5 and Mode 6 when pathway is being used except that outages are permitted for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling.

l f -

Since the only source or service water , contamination is the reactor building closed cooling water, monitoring of the closed cooling water and conservative leakage assumptions will provide adequate control or service water errluents.

The dilution water is determined by the use of condenser cooling water and service water pump status.

Only those pumps actually discharging to the quarry at the time of release are included. Pump status is only reviewed for purposes or determining riows.

Determined by the use or valve curves and/or make up riow rates for the purpose of determining riows only.-

NA - Not applicable.

1/4 3-52 Amendment No. jd(1,126

_ _ , , _ _ , , , _ _ , . , _ __,____m__- _ _ _ _ _ - - - - - - - - - - - - - - - - - - - " - - - - - " - - - - - ^ ^ ^ ^ - - - ^ ^ - ^ ^ ' " ^ ^ ^ ' - '

Jcnuary 1,1986 TABLE 3.3-12 9 (Continued)

ACTION STATEMENTS ACTION 1: With the. number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initi'ating a release:

1. At least two independent samples are analyzed in accordance with Specification 4.11.1.1.1; and
2. The original release rate calculations and discharge valving.

are independently verified,by a second individual.

ACTION 2: With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are analyzed for gross radio-activity (beta or gamma) at a lower limit of detection of at least -

3 x 10- uCi/ml; ,

1. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is > 0.01 uCi/gm DOSE EQUIVALENT I-131.

@ 2. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the secondary coolant is < 0.01 uCi/gm DOSE EQUIVALENT I-131.

ACTION 3: With the n' umber of channels OPERABLE less than required by the Minssum Channels OPERABLE requirement, effluent releases via this Pathway may continue provided that best efforts are made to repair the instrument and that once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples of the service water effluent are collected and analyzed for gross radio-activit 2 x 10 y uCi/ml.

(beta or gamma) at a lower limit of detection of at least i I

ACTION 4: With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump performance curves may be used to estimate flow.

, HILLSTONE - UNIT 2 3/4 3-53 Amendment No.104

Janusry 1, 1986 i .

TABLE 4.3-12

?

RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCL REQUIRErENTS ,  ;

CHANNEL .

CHANNEL SOURCE CHANNEL FUNCTIONAL INSTRUMENT CIECK CIECK CALIBRATION TEST '

1. GROSS RADIOACTIVITY MONITORS  !

PROVIDING ALARM AUTOMATIC l TERMINATION OF RELEASE ,  ;

a. Clean Liquid Radwaste P

Effluent Line . D* P R(1) Q(2) i i

b. Aerated Liquid Radwaste Effluent Line D* P R(1) Q(2) i
c. Steam Generator Blowdown Monitor D* M R(1) Q(2) ,
d. Condenser Air Ejector Monitor D* t1 R(3) Q(2)
e. Condensate Polishing Facility -

Waste Neut Sump D* P R(1) Q(2)

2. GROSS RAD.10 ACTIVITY MONITORS l PROVIDING ALARM BUT NOT l

PROVIDING AUTOMATIC TERMINATION OF RELEASE

a. Reactor Building Closed Cooling Water D* M R(1) Q(2)
3. FLOW RATE tEASUREFENT DEVICES
a. Clean Liquid Radwaste Line  !

D* NA R Q

b. Aerated Liquid Radwaste Line D* NA R Q '

l

c. Condensate Polishing Facility -  ! l Waste Neut Sump Line D* .NA R Q
d. Dilution Vater Flow D(4) NA NA NA
e. Steam Generator Blowdown Line D(4) NA NA NA i

MILLSTONE - UNIT 2 3/4 3-54 Amendment No.104

. . , - - . - - - ' - " " _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ ~ ~ ~

January 1,1986 9 i TA!)LE 4.3-12 (Continued)

TABLE NOTATIONS I

  • - During releases via this pathway and when the monitor is requ. red l OPERABLE per Table 3.3-12.

l discharge is in progress. The CHANNEL CHECK should be done when the NA - Not.^ plicable.

(1) - Calibration shall include the use of a known radioactive liquid or solid source which is traceable to an NBS source.

(2) - The alannCHANNEL annunciation FUNCTIONAL occurs if any of TEST shall also the following exist:demonstrate that control roo a.

Instrument indicates measured levels above the alarm / trip setpoint. i

b. I Instrument indicates a downscale or circuit failure.

~

Automatic isolation of the discharge stream shall also be  !

I i

demonstrated for this case for each monitor except t.se  : I reactor building closed cooling water monitor. For the 9 condenser air ejector monitor it is the isolation of the steam generator blowdown that shall be demonstrated.

I (3) - Calibration shall be performed using a known source whose strength is determined by a detector which has been calibrated to an NBS source. 6 The source shall be in a known reproducible geometry. '

i4) - Pump or valve status, as appropriate, shall be checked daily for the purposes of determining flow rates.

i i

l i

I' HILLSTONE - UNIT 2 3/4 3-55 II Amendment No. 104

i' SAMPLE RECORD OF ALLEGATION PANEL DECISIONS SITE: M iLt s ros E 1- PANEL ATTENDEES:

ALLEGATION NO.: 91 -h _o 7-1 # Chairman - Wee,e,ks

! DATE: 912919 I (Panel No.(1)2 3 4 5) Branch Chief -

PRIORITY: High 66 Low Section Chief (AOC) - 6.R uv i SAFETY SIGNIFICANCE: es No nkn Sr. Allegation Coord (SAC) Rdemeerdo l CONCURRENCE OI Reoresentative - J . c., thd u

! TO CLOSEOUT: DD 8 SC (Other) 9.Best CONFIDENTIALITY G  : Yes No y, g, A4 E46-(See Allegation Receipt Report) p, y,g, py

IS THERE A HARASSMENT / DISCRIMINATION I ISSUE: Yes No i IF YES, i 1) has the individual been informed of the DOL process and the need to file a complaint within 30 days Yes No
2) has the individual filed a complaint l with DOL Yes No l 3) has a letter been sent to the complainant seeking Yes No \

any safety concerns / '

IS A CHILLING EFFECT LETTER WARRANTED: Yes No

IF YES, HAS IT BEEN SENT 1 HAS THE LICENSEE RESPONDED TO THE CHILLING Yes No f 8%

EFFECT LETTER: Yes No [ l[@

4 ACTION:

I) Dt t +o w t ~Los telsa n-d GL b Itws cc ,/ EM pgn A GC0 -2 JS

2) D R 9 % sw J rsG le h, A, isse nw . -lu e m h o v s. -

M I}1,4 EG( m m

,j g L/ src0-2.w 4

3) O M k uns oas4 Eks, C Eco - 4 w*.45
4) DRP Amri/d y h1 ar e m.a coau ] e - c ,, o 5)

NOTES:

A4-I l k

)

A

Ilb ALLEGATION MANAGEMENT SYSTEM ALLEGATION NUMBER - RI-91-A-0231 RUN DATE: 09/11/91 DOCKET / FACILITY / UNIT: 05000336 / MILLSTONE 2 /2 DOCKET / FACILITY / UNIT: / /

DOCKET / FACILITY / UNIT: / /

. DOCKET / FACILITY / UNIT: / /

ACTIVITY TYPES - REACTOR MATERIAL LICENSES -

FUNCTIONAL AREAS -

OPERATIONS DESCRIPTION - 1) NO CHECK SOURCES IN S/G BLOWDOWN OR RBCCW RAD MONITORS.

2) PORC REVIEWS ARE SUPERFICIAL, DIDNT IDENTIFY ERRORS
3) NU IS UNRESPONSIVE TO EMPLOYEE CONCERNSECT. ALSO GAVE CONCERNS - 4) RBCCW RAD MONITOR SAMPLE VALVES NOT LABELED AND DRAWING -

6 DOESNT REFLECT AS-BUILT CONDITION

5) OPERATORS FAILED TO ENTER LCO WITH RBCCW RAD MONITOR OOS
6) I&C TECHS INCORRECTLY STARTED SJAE RAD MONITOR SOURCE - LICENSEE EMPLOYEE CONFIDENT - NO RECEIVED - 910822 BY - JT SHEDLOSKY / RI ACTION OFFICE CONTACT - EM KELLY - (FTS)346-5183 SAFETY SIGNIFICANCE - UNKNOWN BOARD NOTIFICATION - NO STATUS - OPEN SCHED COMPLETION - 911231 DATE CLOSED -

ALLEGATION SUBSTANTIATED - ALLEGER NOTIFIED -

1 OI ACTION - OI REPORT NUMBER - i REM.NRKS - RECEIVED AT RESIDENT OFFICE BY MEMO, WITH SUBSEQUENT UPDATE. l PANELED 28AUG91.

)

l SUPPORT OFFICE: RPS-4A

. ACTION PENDING: REFER TO LICENSEE DOCUMENTATION: ]

ALLEGER LAST CONTACTED: 22AUG91 l

REFERENCE:

KEYWORD: RAD MONITOR, RESPONSIVENESS

, ENTERED SYSTEM - 910903 CLOSED SYSTEM - RECORD CHANGED - 910903 i

ilf RECORD OF ALLEGATION PANEL DECISIONS SITE: . 4 4 PANEL ATTENDEES:

ALLEGATION NO. -

-$- 02.M Chairman - (A h W N S DATE: $8 M (Panel No. I 2 3 4 5) Branch Chief -

PRIORITY: High Low Section Chlef fAOC) - 6 y SAFETY SIGNIFICANCE: ,Yes @ Unkn Sr. A11ecation Coord (SAci c m4: c CONCURRENCE TO CLOSEOUT: DD h SC OI Peoresentative -

CONFIDENTIALITY GRANTED:

(See Allegation Receipt Report)

Yes

@ (Othern I w w er-IS THERE A HARASSMENT / DISCRIMINATION IF YES, ISSUE: Yes h

1) has the individual been informed of the DOL process and the need to file a complaint within 30 days Yes No
2) has the individual filed a complaint with DOL Yes No
3) has a letter been sent to the co.nplainant seeking Yes No any safety concerns IS A CHILLING EFFECT LETTER WARRANTED: Yes No IF YES, HAS IT BEEN SENT Yes No HAS THE LICENSEE RESPONDED TO THE CHILLING EFFECT LETTER: Yes No ACTION: RESP ECD
1) b M'dw 1 l%"bdOh ol4 P8E M M IUtntif O nuo c r- $ 4(_ fofff9[

co>iceras '2w/ /w tdbee ccrommeness isswO4n<

> Reenutt A>erruseti DeP tssmi 3) 4)

5)

NOTES:

r 4

1 l

t 10/91( (IV  ;

REACTOR BUILDING CLOSED COOLING WATER ak MONITOR - RM-6038 l DESCRIPTION )i Gamma Scintillator - 2" x 2" Nal detector Offline common sample line taken off the discharge of each pump Detector is surrounded by 5" lead shield Located along the south wall (-25' 6" elev.) of Aux. Bldg. See Figure 1 P&lD # 25203-26022 - Sh.1 PURPOSE To monitor the gross gamma activity in the RBCCW and hence, provide an indication of heat exchangerleakage.

Alarms on High Rad No automatic control functions.

REGULATORY REQUIREMENTS Technial Specification 3/4.3.3.9 - Tables 3.3-12 and 4.3-12 Included in the liquid effluent monitoring table as MP2 has no service water rad monitor to act as a final effluent monitor for service water. Detectable activity in the service water could only result if RBCCW activity was high and a leak into service ,

water existed. An indication of high activity in RBCCW would result in more frequent service water sampling.

REMODCM - Section E.7 of ODCM RANGE 101 to 106 cpm Based on a typical conversion factor of 6 x 10 9 uCi/ml per CPM this corresponds to a range of 6 x 10-8 uCi/mi to 6 x 10-3 uCi/ml l FLOW RATES Sampler flow rate is maintained at approximatelg 2 gpm.

ALARM SETPOINT Required Setpoint Per the ODCM, the setpoint should be less than or equal to the CPM corresponding to:

Background + 5 x 10 5 uCi/ml in this case, background is not the normal process reading,it is the in place reading ,

of the monitor with clean flush water in the sample chamber.

16 1 1

(

,..,ig.

el (

y 3* ,

] Recommended Setooint '

The alarm may be set at values less than above. An alarm of 2 to 3 times the rormal reading is recommended as an indication of change.

Q BASIS FOR ALARM SETPOINT

  • Required Setpoint ,

4 The alarm setpoint is based on ensuring that any potential releases via the service water system are maintained within 10CFR20 limits. The alarm setpoint was ,

calculated as follows: '

t Assumptions used in determining the alarm setpoint for this monitor are:

a. Maximum flow from primary makeup water is 400 gpm and hence, assumed maximum RBCCW to service water leak rate.

e;

b. Minimum circulating water dilution flow is 135,000 gpm (1 circulating water pump).
c. The release rate limit is conservatively set at 50% of the 10CFR Part 20 Imit for 1 131 (0.5 x 3 x 10 7 uCi/mi = 1.5 x 10-7 uCi/ml).

! d. Background can be added afer the above calculations are performed. '

4 4

Therefore, the alarm setpoint (using the latest monitor calibration curve) should r, correspond to a concentration of:

O Alarm (uCi//ml) = 135,000/400 x 1.5 x 10 7 + background *

= 5 x 10-5 uCi/ml** + background i

Note that the purpose of this monitor is to detect high activity that ma, occur between the weekly RBCCW samples. Hence, the maximum undetected dose consequence, assuming an unlikely 400 gpm leak, is:

5 x 10 5 uCi/mi x 400 gal / min x 168 hr/ week x 60 min /hr x 3785 cc/ gal x Ci/106 uCi = 0.8 Ci 0.8 Ci x 0. 2 mrem /Ci = 0.16 mrem maximum organ This dose is below limits and is an event that should rarely, if ever, happen over the ife of the plant.

Monitor background at monitor location.

Note that this value has been specified in the Radiological Environmental Review for REMM Change Request #881.

Recommended Setooint l

As long as 2 to 3 times normal is less than the required setpoint, it is recommended to be a more sensitive indicator of change and hence, a more rapid indicator of potential heat exchanger leakage. i I

l 16 2 I

CONVERSION FACTOR  :

Variable depending on latest calibration data, but based on recent (1988/'189) .

f

- calibration is typically about 6 x 10 9 uCi/ml/ccpm.

i CAllBRATION TECHNIQUE NBS traceable concentrations of Cs-137 in a liquid sample container of equivalent geometry to the process chamber are used. Three different concentration solutions +

are used and the ccpm for each is determined. An average calibration factor is then determined.

i l

.1 t

9 16 3

4 Figuro i I a

l LIQUID

  • RAD WASTE FILTERS l

l l

Rn9tls --9 E~ C RM9049 m, p-E E E 0 0 3 RM f,03I M 3 3 E{ 3 A

5 U

M '

P Aux Bldg. -25'6"

e,

-(

RI-91-A-231 ISSUES & REQUESTS Issue 231-2:

Plant Operation Re' view Committa (PORC) actions are superficial. There are different calibration accuracy requirements between the Steam Generator radiation monitor functional test procedure (SP 2404A1), recently reviewed by the PORC, and'-

a referenced source. Procedural problems also exist in the RBCCW radiation monitor calibration procedure, which was also recently reviewed.

Request:

Please discuss the validity of this assertion. Please provide assurance that the calibration accuracy requirements are correct and consistent and that procedcal problems in the RBCCW are resolved. ,

Issue 231-4:

The RBCCW radiation monitor (RM 6083) sample valves are not labeled.

Additionally, the piping and instrumentation drawing (P&ID) 25203-26022, Sheet No.1, does not reflect the actual installed configuration of the sample lines. (This concern is similar to issue 210-1 referred to you by letter under File Number RI A-0210, dated August 22,1991.) .

Request:

Please discuss the validity of this assertion. Please provide assurances that the RBCCW radiation monitor (RM 6083) sample valves will be labeled in the future and that piping and instrumentation drawings will reflect actual conditions.

Issue 231-6:

I&C technicians incorrectly started the Steam Jet Air Ejector (SUI) radiation monitor (RM 5099) with the sample pump inlet valve shut. Subsequently, the motor failed to re-start. The sample pump was started by I&C Department personnel. It should have been operated by Operations Department personnel.

Of t Ox r -

I

)  ;

i D B N- FOR P RI-91-A-231 ISSUES & REQUESTS (continued) >

Request (231-6):

Please discuss the v'alidity of this assertion and provide assurances that the stated  !

problems with regard to the SJAE radiation monitor system operation are resolved ,

with regard to safety requirements.

GENERAL REQUEST: l Please provide your review of the above assertions. If the above conditions are valid, ,

notify us of the corrective actions you have taken to prevent recurrence. Also provide us with an assessment of the safety significuce of any identified deficiencies, ,

including generic considerations.

9 I

I i

l T OrfdR}UBEIC Di5DEOSURL

_ t,

, f a..g

[ g UMTEo STATES

,8- 3 j NUCLEAR REOut.ATORY COMMISSION ,

4 j REOlON i

/ 475 ALLENDALE ROAD 3 KING OF PRUSSIA. PENNSYLVANIA 19406 00T 2 91991 Docket Number: 50-336 i

File Numbers: RI-91-A-0232 and RI-91-A-0263 Northeast Nuclear Energy Company A'ITN: Mr. John F. Opeka Executive Vice President - Nuclear P.O. Box 270 Hartford, Connecticut 06141-0270

Dear Mr. Opeka:

The U.S. Nuclear Regulatory Commission recently received information concerning activities ,

at Millstone Unit 2. Enclosed are the details 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 numbers RI-91-A-0232 and RI-91-A-0263 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 1. The enclosure to this letter is considered Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, a copy of this letter excluding the enclosure will be placed in the NRC Public Document room.

The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork j Reduction Act of 1980, PL 96-511. .

1 Your cooperation in this matter is appreciatoi. We will gladly discuss any questions you have l concerning this information.  !

Sincerely,

+ y; Charl W. He 1, Director

) '

I

  • Division of Reactor Projects hjjj u ^O2 C h ~ Sff-

Northeast Nuclear Energy Company 2 OGI 1 S SSI '

Enclosure:

10 CFR 2.790(a) Information Issues and Requests cc w/o encl:

Public Document Room (PDR.)

Local Public Document Room (LPDR)

State of Connecticut bec:

Allegation Files, RI-91-A-0232 and RI-91-A-0263 E. Connor T. Shediosky W. Raymond E. Kelly Contractors Office File (REAGAN) se4+-

Concurrence:

RI:DRP DRP R[RP R. Barkley y E.-Nenzinger E/_/21 E/Af/21 go }j h_/21 t

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