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f %. UNITED 8TATES
.,' NUCLEAR REGULATORY COMMISSION \
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g 475 ALLENDALE MOAD g KING OF PRUS$1 A, PENNSYLVANIA 19406
..... OCT 011993 ,
Docket No. 54336 Mr. Edward C. Mroczka .
Senior Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company P.O. Box 270 Hartford, CT 06141 0270
Dear Mr. Mroczka:
The U.S. Nuclear Regulatory Commission recently received an allegation concerning activities at Millstone 2 (RI 90-A-144). Details of this allegation are enclosed for your review and followup.
We request that the results of your review and disposition of this matter be submitted to Region I within 30 days 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. -
The enclosure to your letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the allegation has been completed and reviewed ;
by NRC Region I. 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 Reduction Act of 1980, PL 96-511.
9212220036 920608 i'0 PDR FOIA CUILD91-162 PDR
-2 Your cooperation with us is appreciated. We will gladly discuss any questions you may have concerning this information.
Sincerely, Original Signed By Edward C. Wenzinger, Chief Reactor Projects Branch 4 Division of Reactor Projects '
Enclosure:
Allegation Details (10 CFR 2.790(a) INFORMATION) cc w/ encl:
W. Raymond, SRI cc w/o encl:
W.D. Romberg, Vice President, Nuclear Operations S.E. Scace, Nuclear Station Director, Millstone Station J.S. Keenan, Nuclear Unit Director, Millstone Unit 2 -
L Gerald Garfield, Esquire l- Public Document Room (PDR)
Local Public Document Room (LPDR) ;
L State of Connecticut 5 l
l -bec w/ encl: '
M. Perkins, DRMA J. Stewart, DRP i
SAMPLE RECORD OF ALLEMTION PANEL DEC1510NS SITE: lh , M rt L PANEL ATTENDEES:
ALLEMT10N NO. : U~ k4 - d'W Chairman - IJJ ca,'n 5 DATE: T/10 /9o (Htg. h 3 4 5) Branch Chief -
PRIORITY: High Hedium @ 5ection Chief (AOC) - .Nuedao
$AFETY SIGNIFICANCE: Yes h Unknown Others - 969.J46 ,
CONCURRENCE TO CLOSE00T: 00 BC SC Gr% -hk$
CONFIDENTIALITY GRANTED: Yes No /Na /(i n Oll.-
(See Allegation Receipt Report) ;
IS THEIR A 00L FINDING: Yes No l IS CHILLING EFFECT LETTER WARRANTED: Yes No !
HAS CHILLING EFFECT LETTER BEEN SENT: Yes No l HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER: Yes No l
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ACTION:
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FOIA 8/_.-- M # h l
ALLEMTION RECEIPT REPORT h
ce 2 w/ 20 MCCd 5 Allegation No. kt 'O' O ' d/M i (leave blank)
Name: Address:
Phone: City / State / Zip:
Confidentiality:
Was it requested? Yes No )~
Was it initially granted? Yes No 'f Was it finally granted by the allegation panel Yes No Does a confidentiality agreement need to be sent to alleger? Yes No Has a confidentiality agreement been signed? Yes No Memo documenting why it was granted is attached? Yes No 1 ye N h)ECO Position /
Title:
Facility: C/\ dish 1- Docket No.: h ["6B 6, (Allegation Summary (brief description of concern (s): div 43 A issvu o, NN t. kr e-M ' ) ccwem fMb did (6 % e(semo & /Mc bn]w ss Qmh N hi R.a a uwaus w AtN t4 e% ss 'i)bE 7,.!, d,fJ L L 72;L %/L (m(%f:JE2sRT.
Number of Concerns: df N . hco ,md I
. ties n thd h fM g Co ksar> / y.5fw < r Employee Receiving Allegation:
(first two initials and last name)
Type of Regulated Activity (a) g Reactor (d) _ Other: Safeguards i
(b) Vendor (e) _ (Specify)
(c) _ Materials Materials License No. (if applicable):
i a) Operation:; (e) Emergency Preparedness l
Functional Area (s): g((b) Construction (f Onsite Health and Safety l (c) Safeguardt (g Offsite Health and Safety l (d) Transportation (h)Other:
i I
l (NRC Region I Form 2 0rmation in this record vos deleted i Revised 10/89) im of information in a:cctdar.;e witt{tt g _
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RECORD OF TELEPHONE CALL
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FRON" M ] Sep 14,1990 Received BY: Bill Reymond 1:40 PM ..
Addre ;*.f6 Phone City / St.
Employer: NNECO Fec111ty: MILLSTONE 2 Position /
Title:
DOCKET NO.: 50- 36 M]
SUMMARY
. See atteched theet for 3 concerns regarding (1) f ailure of operators to note that the SJAE redletion monitor meg not be working properly;(2) the f ailure of a su ervisor to respond (Liis Questions within 14 days; and (3) the f ailure of to follow a department instruction to updole en equipment history file and IS$ue o trouble report sticker of ter completing meintenance on a signal input to the reector regulating system (Tref vs.Teve comparator).
au ested the employee to contact me if he had any further information NUMBER OF CONCERNS: 3 EMPLOYEE RECEIVING CONCERNS- WILLI AH J RAYMOND Time Pequired to Process Request: 2 Han-Hours -
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I. SJAE OPERABILITY QUESTION
> aid he checked on the SJAE today and noted that the sample line ,
condensete bottle does not appear to be collecting water and that f urther, the monitor response oppears to have decreased, indicating mois ture buildup may be causing a decrease in channel functioning. The monitor had been reading ebout 2000 com end h decreased to 1000 cpm. He further noted thet the PEQ id he had not emptied the collection bottle for the lost ITdays{ eld norTnelly the chillers collect about 4 quarts per dog.
Joid he notified the Operations Shitt Supervisor of his
,servati ns that the SJAE might not be working.Malso notified supervisor in l&C) of his concern 7 stated his concern was that (1) operators are not finding the same problems he is, end (ii) the SJAE may not have been opereble for an extended penod of time with no compensatory octions taken
- 2. RESPONSIVENESS Tn CONCERNS O q
] stated tnet he raised three questions with(q/h!s depertmerirsupervisor on August 23,1990 The questions involved (1) use of Ine " completed by" Dlock Ior prerequisites, Imtlel conditions and precautions when doing surveillantes;(ii) 8 Drocedure statement about actions to be teken dunng testing of the RPS if pre-tnps or inps come in on another channel, end,(til) break times {Mstated that dunng e department meeting on September 5 the answers to questions "I and 83
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were provided, but not f or "2 )tated he was not in attendance at the meeting stated it was significant to him inet his supervisor did not answer all the auestions as requested I told that the NRC connot ein him communicate with his supervisor on routine matters end that nould talk to his supervisor about the resolution to question "2, since there several possibly valid reasons to deley the supervisor's response. ecame belligerent and Wes adement thothid not have to initiate contact on the metter agein since he rolsed the question once and the supervisor felled to get back to him a within 14 days as required by the procedure on handling nuclear concerns.
^
Dstated he felt the NRC should help him get enswers to estions within the 14 days I declined to pursue the issue further en] told that I hed noted the concern, of fered the following about question *2. He stated he hed problems because the question come up while doing a surveillance recently because some pre-tngs come in on Tt1LP while he was doing an RPS surveillance. The procedure stated he should place channels in bypass and return the channel under test to " normal' at the d/scre//aa of the sN//
supervisorMold the shif t supervisor stated it was OK to continue testing.
- 2. fAlLURE OF TECH TO TOLLOW INSTRUCTIONS , ,
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o troubleshoot a problem with the control circuit for the turbine k' (
! bypass valves. The opperently has been a on unexplained shtf t (decrease by s ,. e 10 degrees F)in the Tref input to the Tref to Teve controller. The Tref signal is derived from turbine first stage pressure measured by PT 4300.
010 not elaborate 00 tne selution to the technical problem stated that during his reviews, he discovered that another lad performed work on the system per AW0s 06490 and 07792, and that there was a known problem from that effort which req)1 red work on PT 4300 dunng the upcoming refueling outageMcited the following issues relative to the performence by the other tech feilure to document the previous work in the looD folder was o point of confusion for (although he was able to reconstruct the work history from the AW0s), f elture to document the previous work in the loop folder was contrary to the instructions to the I&C staf f in the department instruction; ond, the tech also did not affix en orange sticker to the essociated instrument, which was also contrary to the department instruction end caused operators to submit e redundent trouble report on the problem toted he was sensitive to this issue of folling to documert work in the loop folder because of his previous problem when he did a test on the RPS and thought the system was inoperable, when in f act, test circuit deficienct! Was known by 16C personnel but not communicated to him etated the problem of needing to update the loop folcer work
histories was previously addressed in department meetings and it is obvious s
that techs still are not doing it right.
...................*********** Ad c 4Gd4 GvobfmMD ADDIT 10NAl. QUESTION (3 WM- [ c Mstoted when he recently worked on the turbine bypass volve (TP8V) control circuit, the control room operators had to switch the reactor regulating s stem to control on channel X while he worked on channel Y for 2
- 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. stoted that there is no quick opemng feature for the TBPVs when controlling on Channel X. Lated the quick open feature was removed by the licensee as part of a PDCR some time ago. Mr.-
"Mesked me if this was e violation of the technical spectitcottons. I told u that I was not owere of any Tech Spec requirement for the TBPYs to be operable, and that operation of the volves was not relled upon for plant safety. I also stated that he should addroes his question to -
qualified licensee personnel (either l&C supervisory personnel or licensed operations monogement) and to not rely on my response ' stated his intentions were to not pursue the questionc e -
e ussessees s e ess e e s se eeee eee ee e eeeeessasemeseeme FUPTHER INF0PHATION BASED ON INSPECTOR REVIEW OF ISSUE
- personnel on September 14 Plant operators had suspected a possible moisture problem with the SJAE detector (R5099) eDout 3 weeks ago when i the ch111er stopped collecting water f rom the sample lines initial evaluation was that the monitor was tracking SJAE octivity. Nonetheless, the operetors only used the chonnel for trending SJAE octivity and did not I
rely on it for meeting the Tech Specs, or for assuring e steem generator blowdown isoletion, or for monitoring of the effluent path in the event of a SG tube leek. The SG blowdown monitor (R4262) was operable during the period in question. In response to uestion, l&C investigated the monitor per AWD 90-09965 on 9/14 I&C found no moisture in the
4.2 Che-istry Centrols (Primary / Seconds _ryj '
. The innector reviewed prir.ary and secondary chemistry results during the inspection period. The review included a comparison of measured j values to technical specifi:ation (TS) 3.4.7 "Reacter Coolant System
, Chemistry," TS 3.4.8 " Reactor Coolant System Specific Activity," TS 3.7G .4 " Specific Activity Secondary Coolant," and Procedure DP 2217, Rev. 4. Secondary Chemistry Control, requirements. No inadequacies i
were noted, Im ) 4.3 Radiatien Moniter Status Alart- Issues 4.3.1 Stea. Jpt Air Efector Radiation Monitor Performance The inspecter reviewed the performance of the steat .iet air ejector (5JAE) radiation monitor, and assessed the safety significance to determine whether licensee actions sufficiently addressed the operation of the radiation monitor.
BaCbground As cocumented in inspection report 50-336/89-13 dated November 9, 1989, an allegation questioned the capability of the SJAE radiation monitor to detect a steam generator tube leak. The previous NRC review substantiated the allegation. The primary focus of this review is to assess further the need for and reliability of the SJAE radiation monitor.
The inspector reviewed the ccndition of the steam generator tubes f rom eddy current testing results during the February, 1989 refueling outage, and the mid-cycle outage conducted in November, 1989. The review fo:Used on the number of tubes identified with circurferentially oriented cracks. In February, 1989, 309 tubes with circumferential cracks were detected, and during the November,1989 eddy current inspection an adcitional 104 cracts were identified. In January, 1987 the unit k
detector well and considers that the thennel was operable and trendmg SJAE octivity As a final note. excerpts form Millstone 2 IR 69-24 ore f orwardea f or ref erence, which contains on coverage of the operability and rellobility of RN 5099 The licensee intends to upgrade the channel to address longstandmg maintenance issue and to enhance system reliability by a PDQ, now scheduled for implementation in the latter part of 1990 I
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203 443 5693
. SEP 19 '90 16:20 NRC MILLSTONE OFFICE P01 I N 3
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)89-135, auxiliary exhaust actuation systerr radiation monitor
(
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) RIT - 8157 out of calibration 93-03, RM-5099 isctopic out of calibration No inadequacies were noted.
4.0 gcioleoical Controls 4.) postiac and Cea.trols of Radiolocical Areas Dur'ng plant tours, posting of contaminated, high airborne radiation, c'c high radiation areas were reviewed with respect to boundary icentification, locking requirements, and appropriate control points.
N: .racecaaties were notec.
4.? _Chey stry Centrcis (primary /$ecordary)
Se de rect:- reviewed prir.ary and secondary chemistry results during ite inspection period. The review included a comparison of measurec va ;es to tecnnical speci: stim (TS) 3.4.7 " Reactor Coolant System Cne n stry," TS 3.4.8 " Reactor Coolant System Specific Activity," TS 3 77).4 "Spe:ific A:tivity Seconcary Coolant," and Procedure GP 2217, Rev. 4, Seconcary Chet,istry Control, requirements. No inadequacies were noted.
,,n.
/ ') 4.3 Mciatier Monitor Status Alarm Issues
' w) 4.3.1 Stean Jet Air Ejector Radiation Monitor performanc_e The inspe: tor reviewed the performance of the steam jet air ejector (SJAE) radiation r onitor, and assessed the safety significance to determine whether licensee actions sufficiently a:: dressed the operation of the radiation m0 nit 0r, Backgrounc As documented in inspection report 50-336/89-13 dated November 9, 1989, an allegation questioned the capability of the SJAE radiation monitor to detect a steam generator tube leak. The previous NRC review substantiated the allegation. The primary focus of this review is to assess further the need for and reliability of the SJAE radiation monitor.
The inspector reviewed the condition of the steam generator tubes from eddy current testing results during the February, 1989 refueling outage, and the mid-cycle outage conducted in Novemcer, 1989. The review focused on the number of In tubes February, identified with circurferentially oriented cracks.
1989, 309 tubes with circumferential cracks were detected, and during the November, 1989 eddy current inspection an additional
(
1 104 cracks were identified. In January, 1987 the unit n /
wavu SEP 19 '90 16821 NRC MILLSTONE OFFICE P02 g i 4
i ex;erienced a tube leak frem a circumf<rential crack at the top
('v) cf the tube-sheet which forced a shut down of the plant. The evert description was previously documented in inspection report 50-336/87-01. As documented in inspection report 50-336/89-13 the SJAE monitor did not indicate an increase in steam generator activity until two days after chemistry sampling, and after the steam generator blowdown monitor indicated a tube leak.
Firai Saf ety Analysis Report section 14.14.1 states that
" detection of the steam generator tube rupture incident is facilitated by radiation monitors in the steam generator blow-down l'rts and in the condenser air ejector discharge lines.
TM ror.itors initiate alarms in the control room and alert the cperator of abnormal activity levels and that corrective actions are required."
jerforrarce During eio-December, the SJAE radiation monitors developed stu-ious spu es in radiation indication resulting in multiple
,,isolations of the steam generator blowdown system. The inspector identified no inaaequate control room operator actions as a result of the isolation and procedural follow-up actions.
Various plant operations review committee (PORC) meetings during the inspection period discussed the performance of the radiation a\ monitor, verification of the activity in the SJAE samples, and (d initiation of corrective maintenance activities.
The inspector reviewed the previous corrective maintenance activities on the SJAE during power operations between 1988 and 1989. Approximately twenty-seven authorized work orders were performed by the licensee. Effectively 14 days out of 329 days the radiation monitor was out of service solely for corrective maintenance, excluding required technical specification surveillances (i.e. source check, channel calibration, and channel function test). The general deficiencies with the monitor performance were flooding, low flow alarms,-no audible horn alarm, monitor spiking after trip monitor floods. Pcst utility corrective actions included heat tracing the inlet lines to the radiation monitor to prevent flooding, and adjusting sample flow.
Recently (late December 1989/early January 1990), the SJAE monitor was out of service for troubleshooting based on numerous-steam generator blowdown isolations. In review of completed authorized work orders, three primary items in SJAE performance were identified by the licensee! a potential dilution from the-instrnent air flow based on the isotopic gas calibration results; sample flow low (i.e. 1.8 standard cubic feet per ninute (SCFM) vs. 3.0 SCFM;- and inappropriate wire configuration l, ,)
for the detector establishing a potential ' floating' ground.
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MS~95.DSev3 3 F,SEP 19 '90 16121 NRC MILLSTONE OFFICE P03 s.
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'v The instrument loop folder indicates the flow rate and detector electrical installation were previously identified respectively in January and December, 3957.
Chemistry Sampling As prescribed in procedure SP-2802 the required sampling frequency for SJAE exhaust is monthly for tritium and gaseous activity. The licensee administratively completes the analyses weekly and in the event of a radiation level exceeding the alarm setpoint for the monitor. Further guidance prescribed by the assistant chemistry supervisor per document MP-S-C-89-215 indicates a daily sampling frequency, consisting of: leakrate determination, trending of data, and establishment of a baseline. The specific guidance requires a sample frequency of Mce per oay if the primary-to-secondary leakrate calculation increases to 5 gallons per day. In the event the leakrate calculation exceeds 72 gallons per day, the sampling frequency is three times per day. The technical specification 3.4.6.2.c limit is 1 gallon per minute (gpm) total primary to secondary
'and 0.10 g;m through any one steam generator. The leatrate ceterr.inations for the SJAE are based on the isotopes Xenon-133, Xenon-135, Xenon-135M for gaseous and iodine-131, iodine-135, and icdine-135 for particulate.
Safety Sionifican_ce
()
The safety significance of SJAE radiation monitor cperation was assessed based on the-emergency operating procedures, technical specification requirements and basis, Final Safety Analysis Report (FSAR), and integrated plant detection capabilities of a potential steam generator tube leak / rupture.
The emergency operating procedures (EOPs) use the SJXE radiation i
monitor alarm in the break identification chart to assess a primary coolant or main steam line rupture, and the monitor alarm is an entry condition for E0P 2534 " Steam Generator Tube Rupture." The SJAE radiation alarm, however, is not relied upon solely, as a decision point for control room operators actions.
Technical Specification 3.3.3.9 table 3.3-12 item Ic describes l the requirements for operability-of the SJAE radiation monitor 1 f
or the steam generator blowdown radiation monitor.
Specifically, if both radiation monitors are inoperable, best kg/ g'h.
l efforts to repair the monitors are required, and in the interim l
chemistry grab samples of steam generator activity for gross racioactivity are acquired. The frequency of grab samples is based on reactor coolant system gross equivalent iodine._ No licensee action is required if one of the two monitors is inoperable.
fTY
203-44315893 m SEP 19 '90 -14.822 -NRC MILLSTONE OFFICE PO4 The FSAR description on the steam generator tube rupture event (Section 14.14) indicates that detection and integrated plant behavior varies depending upon the size of the tube rupture.
For leakage rates up to the capacity of the chemical and volume control system charging pumps, reactor coolant inventory can be maintained and an automatic reactor trip would not occur. The gaseous fission products would be released to the atmosphe_re from the main steam system via the condenser air ejector discharge to the unit I stack. Those fission products not discharged in this way would be retained by the main steam, feedwater and condensate systems. For leaks that exceed the capacity of the chargir.g pumps, pressurizer water level and pressure decrease and an automatic reactor trip results.
The licensee's other methods of steam generator tube leak detection consist of, but are not limited to, the following parareters: steam generator blowdown radiation monitor alarm; main steae line radiatien monitor, unbalance in the control of letdown / charging flowrates, pressurizer level and pressure cecrease, start u; cf stand-by charging pumps, and chemistry samples for gross radioactivity.
Conclusion Licensee ef forts to address problems with the SJAE radiation monitor were-extensive; however, the significant amount of V / corrective maintenance was not successful in assuring reliability of the monitor. The inspector noted that detection of a steam generator tube leak is not : solely related to the
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performance of the SJAE monitor; however, poor performance of this monitor removes a valuable source of information to the control room operators.
4.3.2 Operability Evaluation for High Range Noble Gas Effluent Monitor On January 2, 1990 at approximately 10:00 a.m.. the licensee was-initiating a required calibration of the high range noble gas -
ef fluent monitor (RM-8168). ~ The calibration is' required by technical specification surveillance table 4'.4-3 item Id.
RM-8168 f ailed its calibration acceptance criteria; specifically, the channel 3 particulate iodine Geiger 4ueller detector f ailed its 100 millirem / hour'(*10%) acceptance criteria. On January 12, the plant operations review committee approved an operability evaluation for RM-8168 based on the unsuccessful calibration.
Desertption RM-8168 (Kaman channel) is' the in-line accident range stack gas-effluent radiation monitor. It samples the Unit 2 stack by one q
l(vj cf.three isokinetic nozzles. The monitor has five channels for
--._-m-.
- , PECOPD of it LEPHONE CALL i
FR0li -
Tue, See '6,1990 '-
Received DY Bill Reymond 4 20 PH I received a telephone cell trom who stated he wanted to talk to Pete. I informe that Pete was out sick today,but was expected back tomorrow Iacke if I could help him.[6 sold he had a concern but declined to dlMuss it with me. When I asked why,M.old because when he explains his issues to me, i ergue witt, him, and with Pete, -
$11 he hos to do is tell him his issues I sold it was not my Intention to orgue with him.{h)teted that I orgued with him the other dog (see telecon note for Sept 14), when I told him he should go back log Mto Issue ask 7 Whenwhy he had not toenswered the question about the D[r
~
) I reef firmed my intention listen to his concern
- i. toted he was
- pissed-of f
- of ter our last conversotton and he would rather
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not Slk with me I stated it wes not my intention to make him upset. f1r himt
'A]tated his concern did not impact plant safety, was not on
,eteiSSueord'w he WOuld rathAr wolt to talk to Pete.
I repeated mu willingneti to heer his concerns The conversation Ance:
withN)te'% he would contact Pete tomorrow s equestec the employee to coniott me if he hed any f urther inf ormation us< ew m ,
Ni i
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