ML20217P352

Provides Preliminary Results of Emergency Preparedness Team Insp of Millstone Unit 3 PASS Performed During 980223-26. Insp Revealed Inability to Rept Results of Containment Air Sample within 3 H & Deletion of UFSAR Annual Commitment

ML20217P352
Person / Time
Site:	Millstone
Issue date:	04/03/1998
From:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9804100075
Download: ML20217P352 (5)

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April 3, 1998 Mr. Martin L. Bowling Recovery Officer - Millstone Unit 2

- c/o Mr. Harry Miller, Director - Regulatory Affairs -

NORTHEAST NUCLEAR ENERGY COMPANY P.O. Box 128 Waterford, CT 06385-0128

Dear Mr. Bowling:

1 JThis' letter provides the preliminary results of the Emergency Preparedness Team inspection of the Millstone Unit 3 Post Accident Sampling System (PASS). This inspection was performed during February 23 - 26,~ 1998. The inspection revealed problems in the PASS including the demonstrated inability to report the results of a containment air sample within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and the deletion of an Updated Final Safety Analysis Report (UFSAR) annual-l

~ commitment to sample a sump liquid.' PASS requirements are contained in Chapter 6 of the Technical. Specification (TS) " Administrative Controls" and the PASS capabilities are l~

> described in the UFSAR and in commitments made in response to NUREG 0737 and.

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' Regulatory Guide 1.97 requirements. These TS requirements and UFSAR and other commitments are not being met, therefore, creating an unacceptable state of system

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readiness. -

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' Background-Millstone Unit 3 TS Paragraph 6.4.8(d) stipulates the minimum requirements needed to

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. ensure the capability to obtain and analyze post accident samples under. accident i

conditions. The program shall include: "(1) training of personnel; (2) procedures for '

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~ sampling and analysis; (3) provisions for maintenance of sampling and analysis i

equipment." Millstone Unit 3 UFSAR, Section 9.3.2.6 describes the minimum functional requirements for the system. The system shall be capable of taking a. primary reactor L

coolant sample, above 240 PSIG, for the purposes of determining,T1) boron concentration; l

(2) radionuclide gamma spectrum and gross radioactivity; and (3) chloride concentration.

..The system shall be capable of acquiring a containment air sample for the purposes of

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determining gas composition and isotope analysis. The system shall be capable of taking a

. containment. sump liquid sample; although the UFSAR does not stipulate the constituents

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' being analyzed. The UFSAR stipulates the time necessary to acquire and analyze all three

. samples'shall not exceed a combine time'of three hours from the moment a decision is j

made to acquire the results of the samples. The UFSAR also requires a semiannual test of

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the primary coolant and containment air sampling system, and an annual test'of the sump i

sampling system; although it suggests a semiannual test of the sump system would be appropriate.

9004100075 990403

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PDR ADOCK 05000423 G-PDR 4

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Mri Martin L. Bowling 2

Status Before 1995 The records of surveillance testing of the system are incomplete. It is not possible,

' therefore, to determine if Millstone Unit 3 met all the frequency requirements for the t

system during the period preceding 1995. The records do reflect numerous problems with the system. For example: instrument tubing and fitting leaks, vaive position indication

. failures, solenoid valve failures, and inadequate test procedures. These and other problems continued to plague the licensee during that time period. Similar records show that the Millstone Unit 3 chemistry procedure was revised in 1988 effectively eliminating the requirement to take an annual sump liquid sample. The reason for removing this requirement from the procedure ~ remains indeterminate because no supporting documentation or, analysis could be produced justifying its elimination. Prior to 1995 l.

electrical engineers were typically given responsibility for the maintenance of the PASS.

L Interviews indicate the historice! problems associated with the PASS were caused by high l;

engineering staff turnover, lack of expertise and training, and inattentive management.

< 1995 to Present L

in 1995 Northeast Utilities assigned a system engineer to the PASS. Over the past two i'

years 31 condition reports were generated describing various problems with the system.

The PASS continued to receive inadequate support despite the high number of condition y

reports until late 1997 when an internal audit stated " Millstone Unit 3 had failed to maintain an adequate PASS program". On January 8,1998, a Millstone Unit 3 LER,97-060, was submitted, documenting problems with the ability to collect and analyze PASS' samples. It was noted that this condition has existed since initial plant startup.

. During the inspection, Millstone Unit 3 chemistry personnel attempted to demonstrate the PASS, utilizing the semiannual surveillance procedure, by acquiring and analyzing a p

containment air sample.1 The procedure was inadequate bect.uw it lacked detail, had to be -

D revised prior to being implemented, had operational steps out-of-order, and did not contain.

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_ the required, sump liquid sampling capability. In addition, it was noted that valves' at the -

sample panel were inadequately marked and system identification tags could not be l -

distinguished from some of the valve identification tags. Although a sample was l:

. eventually acquired, results of the analysis would not have been reported within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> j

j, from the moment a decision was made to acquire the sample. Note that the UFSAR l

requirement is that all the PASS results be reported in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; not just containment air.

.The demonstration did not include any expected impediments created by an actual s

emergency condition such as additional radiological protection measures, i

The Emergency Plan, Section 6, " Emergency Measures," requires an annual PASS drill.

1 Because of inadequate record keeping, Millstone Unit 3 is unable to show this requirement has been met. In addition, chemistry personnel could not recall using the PASS procedure contained in the Emergency Plan describing sample acquisition, radiological protection, analysis, and timeliness under emergency conditions. The chemistry personnel could only recall using the surveillance procedure for the PASS. The Millstone Emergency Planning staff, when asked about this discrepancy, stated the PASS implementation was simulated during the annual emergency preparedness drill. Simulation does not adequately demonstrate capability.

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Mr. Martin.L' Bowling ~..

Conclusion-'

The inspection revealed problems in the PASS including the demonstrated inability to report the results of a containment air sample within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and the deletion of a UFSAR

required sump liquid sampling. Consequently, the PASS capability has not been adequately

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demonstrated as required. The system is in a degraded condition and does not comply i

. with the requirements of the Unit 3 Technical Specification and Updated Final Safety.

Analysis report. Corrective actions as documented in LER 97-060 as Mode 3 -

commitments for completion prior to startup, do not fully address the weaknesses the NRC and your staff identified with the PASS. Particularly, in did not include emergency

- preparedness's corrective actions and restart plan addressing training and operation of the PASS under emergency conditions, revising the " emergency" PASS procedures and their objectives for adequately conducting PASS drills demonstrating system capability and j

sample analyses. Prior to going to mode 2, the PASS must be fully operational, with--

1 documented procedures, and trained personnel to support a response to a significant -

. emergency.

- The NRC staff willinclude the above findings, in inspection report 50-423/98-01. Based on our currerd view, the problems with the PASS constitute an apparent violation of TS.

NRC's decircon on enforcement actions relative to PASS will also be discussed in that report. If you have any questions related to the matters discussed in this letter please call-

-me at (6106 337-5359.

Sincerely, ORIGINAL SIGNED BY:

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- James T. Wiggins, Director Division of Rerator Safety

. Docket No. 50-423

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y Mr. Martin L. Bowling 4

cc w/ encl:

B. Kenyon, President and Chief Executive Officer M. H. Brothers, Vice President - Operations J. McElwain, Unit 1 Recovery Officer J. Streeter, Recovery Officer - Nuclear Oversight G. D. Hicks, Unit Director - Millstone Unit 3 J.- A. Price, Unit Director - Millstone Unit 2 D. Amerine, Vice President for Engineering and Support Services P. D. Hinnenkamp, Director, Unit 1 Operations F. C. Rothen, Vice President, Work Services

. J. Cantrell, Director - Nuclear Training S. J. Sherman, Audits and Evaluation L. M. Cuoco, Esquire J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control-S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN J. M. Block, Attorney, CAN S. P. Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon E. Woollacott, Co-Chairman, NEAC I

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Mr. Martin L. Bowling 5

Distribution w/ encl:

. Region I Docket Room (with 9.99y of concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC FILE CENTER, NRR (with Oriainal concurrences)

SPO Secretarial File, Region i FEMA, Region l NRC Resident inspector B. Jones, PIMB/ DISP '

W. Lanning, Deputy Director of Inspections, SPO, RI D. Screnci, PAO W. Travers, Director, SPO, NRR Distribution w/enci (VIA E-MAIL):

J. Andersen, PM, SPO, NRR-M. Callahan, OCA

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R. Correia, NRR '

B. McCabe, OEDO S. Dembek, PM, SPO, NRR G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR D. Mcdonald,'PM, SPO, NRR 1

P. McKee, Deputy Director of Licensing, SPO, NRR

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1 S. Reynolds, Chief, ICAVP Oversight, SPO, NRR Inspection Program Branch (IPAS)

DOCUMENT NAME: G:\\EP&SB\\ SILK \\ Quicklook.Mll Ta receive a copy of this document, indicate in the box: 'C' = %opy without attachment / enclosure "E" = Copy with attachment / enclosure

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