ML20115F882

Partially Withheld Ltr Providing Addl Data Detailing Chronic History of Procedural Noncompliance on Part of Unit 2 & Mgt

ML20115F882
Person / Time
Site:	Millstone
Issue date:	12/30/1988
From:	AFFILIATION NOT ASSIGNED
To:	Habinghorst P NRC
Shared Package
ML20115F670	List: ML20115F882 ML20115F978 ML20115G532
References
FOIA-91-162 NUDOCS 9210230254
Download: ML20115F882 (13)

Text

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J,AM 05 ' 89 11:35 HRC MILLSTONF 0 0FFICE P02 i .

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December 30, 1988 ,

Mr. Peter Habinghorst Resident Inspector Nuclear Regulatory Commission i Millstone Unit 2 Waterford, CT 22, 1988, we, ,j As a follow-up to our meetings of December ,

the undersigned, would like to state for the record our concerns, and provide you with additional data detailing a chronic history of procedural non-compliance on the part of Millstone Unit 2 and its management.

As an initial response we would like to comment on Nr.

McCabe's letters to us regarding problems presented to him for resolution. It appears that Mr. McCabe was unable to -

resist the easy and preferred answers provided by the company, and in so doing cast aside or neglected other answers more worthy of consideratior.. Furthermore, the NBC's failure to follow-up on documented charges S, Labor of employee harassment (independent o' the U.

Department) suggests that power _not individual rights count.

This f ailure furthe. gives unwarpnted status to the belief

" lowly" individuals :uch 3s 56'tig should surrender to what is most powerful, and in so do that make the worship of vulgar success look principled even at-the expense of public safety.

Mr. McCabe's condescending attitude, his poor choice of words and indeed his arrogant portrayal of the nim's actions serves to enforce our.long held belief that an i enforcetaent entropy or an. evaporation of tha will to enforce required nuclear and safety procedures with regard to N.U. exists on the part of the N'.R.C. Most of his responses.can-best be described as having.gone neutral if indeed not benign. Most of his narrative is merely publia-relations clap-trap, sprinkled at times with sanctimonious comment.

In fact, based on the information supplied, his explanation and justification must have required a breathtaking leap of /

illogicality. Further, his amateurish attempt at intinidation by stating. he- would make' available to the )y

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JAH '05 'S9 11:35 HRC MILLSTONE OFFICE P03 Page Two December 30, 1988 An example of such ramblings are his comments on the comolaint of procedural non-compliance regarding excessive overtime. He stated that no safety violations occurred.

Rm:3meer the comp 1= int was on excessive overtime--not safety violations. At best such ";ogic" (or lack of it) constitutes a non sequitur but in layman's language it is akin to saying that milk cows in Wasconsin are supplying tainted milk due to excessive pesticides in tne tood supply ,

but that is acceptatle because the aristocra / in Genoa, Italy are all driving their Ferrari's in a safe manner.

In addition to the items we discussed mt cur December 22 meeting we are providing you with addit'ional data suggesting procedural non-compliance. We are also providing a minimal amount of manufacturer's data suggesting that our claims are founded on facts. We are prepared to supply other data which you may require, and we will continue to supply you instances of non-compliance until we are satisfied that the NRC actions will lead to i parmanent and satisf actory solution.

Examples of non-compliance:

Tolerances on rad monitors 2404 AR 2404 A0 2401 J i

2404 BA 2401 E ACP 1. 14 Ground Cart Procedure l Rad Menitor Horns Lack of UCRs on deficiencies CTMT Rad Mon Test Switches Overt!me.Non-Compliance Acoustic Valve Monitor Calib Acoustic Valve Mon. Testing

Acoustic Valve Hon. Amp Repl SPM 2401E/T-88-2 RCP Oil Level Problems RCP Alarm Set Points RCP RTD's RCP Diff. Temp.

RCP Undersped Input to RPS RCP Level Transmitters Incorrect Prints Rad Monitor Key Switches H2 Analyzer Problems Diesel Gen Flow Switch Rad Mon SJAE RPS lifted lead problems Functional Tests on R.M.

Lack of procedur(s-Asbestos Lack of Procedures-PCB's Lack of Documentation on l Key Checkout NRC's failure to address discrimination l

jai 05L*89-11836 i'RCJMILLSTONEl0FFICE PO4'

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-._'. i Page Three December-30,-1988 ,

Overhaul of B&D car fans without procedure Hearing replacement on Rod Drive.MG without procedure NU's internal report on Ground Cart incident stating root cause as failure to follow procedure

overhaul of "A" Car ran planned this outage--still no

L approved procedure .

Lack of separate ground oon "C" Inst. Air Comp.-in violation of_SP-EE-076, page 3, Item 6.1.25 Lack of approved (PORC) procedure for cathodic protection surveillance Lack of asbestos and PCB procedures plant-wide Company doesEnot__ follow time constraints of.theirLown '

orievance. procedure Use of~EMT for CKTS other than lighting in violation- -

of SP-EE-076 Electricians have consistently noted problems ~with- -

spare station battery such.as cracked cell',' severe discoloration of cell interconnecting bars and material oozing:from cell posts--no' action on theipart of the; company we continue to disoose of' emergency-light battery-acid by pouring same into floor drain-ofECPF. This is11n-violation of company procedure and environmental guidelines Many of the 270lJ series surveillance forms are outdated, incorrect or both TCB 7 has not worked properly-in over 5 years.- During _;~

high risk testing requires manual closing Many in-plant electrical panels do-not agree with-existing; prints. This- is;due to many changes and : PDCR-I not being recorded at_ time of change.

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JAll105 '89 112 36 11RC MILLST011E OFFICE P05 b

I Page Four December 30, 1988 ,

In closing we would like to state that we are prepared to .

supply any documentation you require and are willing to discuss any and all matters regarding these complaints at ,

your convanience, e t

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,w i t922.2%_.:Q; 5 1SUFERINTENDENT . . __ J ;2 4 '-

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_EFFEwT1- CATE SCRC MTE..Ms..

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PDCR' EVALUATION FORM 1

ds NUMBER MP2-64-040 TITLE Aux Bldo Soece Htr X-162 Misc Lichtin2.

For Maint Hot Weld /Mechine Shop _

SYSTEM 2331 ORIGINATOR

1. DESCRIPTION OF CHANGEt This change involves the relocation of space heater X-162.and relocation /elimina*. ion of several area lighting fi:ttures ' to f acilitate the addition of a Hot Machine / Weld Shop at El. 08*-6" of them Auxiliary Building near the Seal Rebuild and No::le Dam Repair Room.

Technical detsils addressing installation of tne Hot Machine / Weld Sho; and associated auniliaries (including power requirements. ventilation and HEPA, drainage, fire protection, instrument air, radiological concerns, etc.) will be documented in a Plant Design Change Recore (PDCR).

i PEASON FQP CHANGE:

L The drain line for scace heater X-160 15 presently _ routed thru tne area where the Hot Machine /Wela Shop is going to be buil t - (Jus t east of the Spent Fuel Fool Area). Additonally. . airflow from the' space hes.er will be partially blockad by the shoc. Thus, relocation of the scace heatar is recuired.

Four arer lighting tintures are located less than 12' ecove the *!cce in tre area. Tha shop will be greater than 12' tall in these areas anc as sach tne lighting fintures require ralocation or removal.

2. EVALUATION IF ANY ANSWER TO OUESTIONS 2.1 THROUGH 2.c Is 'vE5". lHEN m FULn is REQUIRED FOR THE CHANGE.

2.1 Does tne change affect the' system /ccmponent cesign function or reduce its design margin?-

Yes :o Y Scses:

This change does not af f ect any system / component design function or recuce its design margin.

Both the supolv and return lines'from the heater will be shortened by.over OS' to accomodate'tne new location of the space highe' heater. The supply line will be routec at an elevation 4" than the present highest point in the line. This-increase ~1n j/j sepolu line elevation is considered insignificant anc.will not affect any original design flow margin 2.

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The design funwtion of the space' heater-w. 1 not.be.aficctec bv this change. The heater will continue to provide heet for this-

+ area.

s The lighting f i::tures -tha t are being removed will no longer be required since they are located'directlyOne above the shop and.the of the-lights to be shop will have independant lighting.

removed prov' des operational emergency lighting (not requiredLby.

Appendin "R'). Moving this light is not required due to the

_The-presence of other emergency lighting in the immediate area.

lighting fintures which are being relocated will provide - lighting The design function of the area along the east side of the shop.

lighting is not affected by this change.

The relocated lights are suoclied from circuits L50-30 and L91-10. Circuits LOO-CO and DO21-8 supply power to the two lights being removed. The change results in the load on panel DO21 being reo-ced by 130 watts and the load on panel L30 being recuced by 300 watts. Thus this change coes not decrease any design margins associated with the power supply circuits.

2.2 Does the change affect pipe lascing, floor loading, hanger loading. ctress calculationa, or seismic calculations which result in structural modifications being required?

'n N o _ __

eesse:

The cmange coes rot-affect pace leading. ficor loading, hanger Ic4cinc, stress calculaticns, er seismic calculations which

?sult :n structural mcoificacicns being requirec.

Scace neater anc picing succort cesigns are shown on Sketch 4 Design of lighting f i:: tu re supports will be a ccmbination of l

r engle iron / rod supports.similar to existing lighting supports.

It is notea that the supcly and return lines from X-iso are "non-OA' anc are not requirec t: function following a seismic event. Also, tnere are no ac]acent- GA Category 1 components whi:n could be affected by failure of the piping or hangers.

2.0 Dees the change require a cnange to any environmental

-lifications (e.g., operability time, aging, temperature, pressure, relative humidity, raclation, spray submergence); or t

does it result in a different normal or accident environment?

Yes Ne X Bases:

The change does not require any changes to environmental cualifications (e.g.. operability time, aging, temperature.

pressure relative humidity, radiation, spray sucmergenceit nor L

coes it result in a different normal or accident environment.

?o rc e hester piping will'not be routed to any different area than it is at present and tnus will not result in e different normal v acciaent ensironment.

SF 039 Rev. 03

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. Liggting cn3ne will - nsve no s f f ec t cn a 'tronments!

l cualifications.

• 2.4 *Does the c hange adver'sely affect any system / component pressure, temperature, fluid chemistry. voltage. current, or material compatibility?

Yes No X Pasis Relocating the space heater will result in a shorter run of supply and drain lines and thus will not adversely affect the auxiliary steam pressure.

As described in Section 2.1 above, the lighting changes do not edversely affect and voltage or current requirements associated with powar supply circuits.

The change does not adversely affect any system / component temperature, fluid chemistry, or material compatibility.

2.5 Does the change adversely affect any element in the fire protectien/ Append 1r "R" program or in the Security Plan?

Yes No Y Bases:

The change cars not adversely affect any element in the fire protection /Accend1: "R" program or in the Security Plan.

Automatic 2moke detectcrs are located in the area. however the scace heater will not be located any clcser to cetectors than it c u r r e n t l', is and thus will not adverselv affect their operation.

One of the lign s to be removec is an ocerational emergency lign (not Append 1: 'R'). The remaining lights being affectec by tnis change are alsc non Appendi: 'R'.

2.6 Does the change create cr increase the potential levels of oftsite radiation or airoorne radioactivity or adversely 3ffect ALAFA goals? ,

Yes No i Bases:

The relocation of the space heater anc relocation / removal of lighting fi::tures coes not increase the potential of offsite radiation or airborne radioactivity or adversely affect ALARA goals.

2.7 Could the change be unsafe or have the potential to create an unreviewed safety question in that it would:

a.

Affect the operability of anv plant system or equipment as defined in Tecn Specs?

yes No X i J59 Rev. 03 Pace 3 of

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'Si' l$pMINISTikTIVE IMPAL T :

Reference.

Required Completed Number S.1 PMMS Update. No S.2 -Procedure Update No S.O DSR/DCR ,

Yes 5.4 AWO Number Yes 5.5 MEPL Update No S.6 FSAR Update No S.7 I9I Program Update No ,

i S.8 Other No ,

i (See Instruction 6.2.6) ~!

Send a copy of this PDCR l S.9 Evaluation Form to the Director l of Nuclear Training. l

6. CLO9ECUT 1

' Unit Engineering Supervisor Date  !

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SF 359 Rev. 03 Page 5 of S

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b. Result in any- plant syntom _ oparation which would deviate

f rom th3 way that th2 Syntom-op2 rat 3D 00 doccribOd in design documents?.

Yes No X If the answer to a or b is yes, then a Safety. Evaluation IAW L

NEO 3.12 (Reference 3.2.2) is required. PORC/SORC_ review is required prior to implementation.

c. If the answe,r to a or b is yes, is an Integrated Safety Evaluation required?

Yes No X CONCLUS IONS :

a. If any question 2.1 through 2.6 is answered YES, then PDCR is required. Indicate "NA" for Sections 0.0, 4.0, and 5.0, then closecut this evaluation.

b. If all questions 0.1 througn 2.5 are answered NO, then no PDCR is recuired. However, if a Safety Evaluation (question 2.7) is reautred, then submit evaluation to FORC/SORC orier to implementation.

3.0 PETEST REOUIREMENTSt.

a) Space Heater Supply / Return Line Modifications :

Inservice Leak Test of Pioe Joints Acceptance Criteria: No Visible Leakage, b) Electrical Lighting Modifications:

Acceptance Criteria: ' Verif y - lights f unction properly.

Evaluation Ccmoleteo B ngineer

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' Date IL (See NEO S.OS; -!

7'//~UT I Desion Verifice tien Date  !-

(See NEO'5.05) dngineer t

' d Frior to PORC/SORC Approval Yes No I mo l emen ta tion A 7 O $1

=;pproved Ev Date Unit Engineering Supervisor

4. PORC/SORC APPROVAlt No .'

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Date SF 359 Rev.-05 Fage 4 of S

e ATTACHMENT TO.

EECH EVAL 4ATION HP2-89-040 DESIGN INPUTS:

1. NUSCO Drawing No. 25203-24087, Sheet 039, Rev. 0; " Auxiliary Steam Condensate to Condensate Recovery Tank T-78".

2. NUSCO Drawing No. 25203-24087, Sheet 040, Rev. 0; " Low Pressure Auxiliary Steam from PCV-8417".

3.

NUSCO Drawing No. 25203-24087, Sheet 041, Rev. 0; " Auxiliary Steam Condensate to Condensate Recovery Tank T-78".

4. NUSCO Drawing No. 25203-35019, " Lighting Grounding and Comm. ,

Auxiliary Building at El. 36*-6"

5. NUSCO Drawing No. 25203-35038, Sheets 18 and 17; " Lighting Panel Schedules for L-29 and L-30"

8. Generation Engineering Specification SP-ME-688, " Millstone Unit 2 Piping Class Sheets.

7. Power Piping Code. ANSI /ASME B31.1, 1971 Ed.

8. NUSCO Memo, W .R. Rotherf orth to T. A. Moore dated 7/11/88.

DETAILED DESIGN:

1. Gener21 El. 38*-6" of A Maintenance Hot Weld /east Machine Shop will be erected atof the Spent Fuel Pool Area a the Auxiliary Building, This change Seal Rebuild and Nozzle Dam Repair Room (See Sketch 1).

involves the relocation of space heater X-162, the relocation of two removal of two lighting fixtures in the lighting fixtures and the area to allow the necessary clearances required for erection of the shop.

Technical details addressing installation of the Hot Weld / Machine Shop and associated auxiliaries (including power requirement =,

ventilation, HEPA, drainage, fire protection, instrument air, radiological concerns, etc.) will be documented in a Plant Design Change Record (PDCR).

2. Space Henter_

Auxiliary Building Area Space Heater X-182 requires

~

relocation Sketches 1 thruto 3 installation of the Hot Machine / Weld Shop.

identify the piping change to lines 1"-HBD-153 (steam supply)These and allow 2 " -H B O - 144 (condensate return) necessary to relocate X-182.

to accomodate the new location of lines will be shortened by over 25'The supply line will be routed at an elevation the space heater.

only 4" higher than the present highest point in the line. This increase in elevation is insignificant and will not adversely affect auxiliary steam suppl! pressure.

f Page 1 of 3

9 Space. heater and pipe support modifications are shown on Sketch 4.

• Attachment of these supports to-the structural steel in the overhead is justified in accordance with Design Input No. 8, (attached).

Power supply cabling and conduit for this space heater will be field routed from its present location.

3. Lichtina ',

Two overhead lights in the area require relocation and two others will be removed to allow construction of the new Shop. The lighting fixtures that are being removed are no longer required since they are located directly above the shop and the shop will have independant lighting. One of the lights to be removed provides operational emergency lighting (not Appendix 'R'). Hoving this light is not required due to the presence of other emergency lighting in the immediate area. The lighting fixtures which are being relocated will provide lighting along the east side of the shop. Sketch 5 identifies the modifications necessary for the lighting change.

The relocated lights are supplied from circuits L30-30 and L81-10.

Circuits L30-30 and D021-8 supply power to the two lights being removed. The change results in the load on panel D021 being reduced by 150 watts and the load on panel L30-30 being reduced by 300 watts.

Technical justification f or modification to the lighting fixtures _is attached (See Memo K. Wallace to R. Bates, dtd. 3/29/89).

4. Imolementstica Two seperate AWO's will be written to perform this change; one each for the-space heater modifications and lighting changes.

All welding of pipe and hangers shall be _ in accordance with the Northeast Utilities Welding Manual. Visual inspection of pipe welds shall be performed in accordance with NNECO Procedure GWS-004 with acceptance criteria in accorcance with ANSI B31.1, parar 2ph 136.4.2.

All support welds shall be visually inspected per GWS-004, with acceptance criteria in accordance Attachment 3.2 of GWS-004.

Any conduit supports requiring attachment to building concrete will be done in accordance with MP 2721X.

All electrical work shall be done in accordance with applicable plant procedures.

Space heater piping shall be re-insulated in accordance with approved materials.

Page 2 of 3

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_7, Docunentatina.

Drawing Change' Requests (DCR's) 9111 be developed as required to-incorporate piping and electrical changes as required of this PDCE, Page 3 of 3

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= == s e san senessoassemassess e ss e m e P1MS ID: M2 O2 FHV MTR DRV FOO 1 WORK. ORDER..... -M2 89 08707 i LOCAL ID: F20M i WO TYPE.....: CM- I L SYS t- 2314F. l PRIORITY.......: 3 1 DG: AB' 1 LEAD DEPT......: MNTC 1.

OM a ' NEAR D/G DAY-TK ROOM i UNT STATUS-REOD: U -i cLEV: 0038 FT 06 IN 'l SCHD STRT DATE: 08 / $4 / 89 i TROUBLE REPORT NO.: 03M2192337 1 DES COMP DATE:.08 / 11 / 89 I EQUIPMENT DESCRIPTION: ==========...............s==....

FUEL HANDLING BUILDING HSV UNIT FAN MOTOR ( 3-EELTS-S/C-TT572054)

PROBLEM DESCRIPTION: MOTOR SMOKED, BREAKER TRIPPED.

PR465218 SUSPECTED MOTOR EEARING SPENT.

CAUSE:

ORIGINATOR  : DATE: 03 / 03 / 39 DEPT: OPS.

SUPV APPROVAL : DATE: 08 / 03 / $9 WO TAG HUNG: Y o************** *******#*******************************u*********************

OC REQD  : N CAT I N CONVEX-CLR N PART SHEET N TAG REQD : YES EEQ  : N GUARD REQD: N TANK ENTRY: N-RWP REQD : N FPOA : N LLRT REQD N TOOL LIST: N ALARA REV: N RWOA : N ISI REQD  : N FIRE WATCH N PROCCDURES CAUTIONS CAUTION NOTES 2710F -

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. VAL CD-245 TASK DEPT ACT ACT REWORK ' N DESCRIPTION -MEN HRS INVOLVES PDCR N REPAIR ELEC ___ ___

PDCR NO. ___ - ___

RESP ENGR ___ ___

APPL CODE: ___ ___.

P.O. NO.: ___ ___.

JOB 1) INVESTIGATE AND REPAIR AS NECESSARY DESCRIPTION AU CCC ACC SU C CMS W.O. ACT RE AC%

ACCOUNTS: -

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WORK DIRECTE EY: __

ASST DEPT NOTIFIED: JOB SbPERVIS 31J FERR -

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DEPARTMENT APPROVAL: .. DATE: __./ __,-/ __

TAG CLEARANCE NO: ________________ COPY OF TAGGING-ATTACHED: ________

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~ APPL TECH SPEC NO: __________ TIME PERMITTED: _ _ _ _ _ _ _ _ . _ _ _ _

AUTHORIZED BY OPS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ , _

TIME: ______

DATE: __,/ __ / _ _ .

.