View source for A09076, Submits Results of Review of Allegation RI-90-A-144 Re Steam Jet Air Ejector Radiation Monitor RM 5099

{{Adams
| number = ML20073C320
| issue date = 12/07/1990
| title = Submits Results of Review of Allegation RI-90-A-144 Re Steam Jet Air Ejector Radiation Monitor RM 5099
| author name = Morczka E, Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Wenzinger E
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000336
| license number = 
| contact person = 
| document report number = A09076, A9076, NUDOCS 9104250181
| package number = ML20073C307
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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==Dear Mr. Venzinger:==

Millstone Nuclear Power Station, Unit No. 2 RI-90-A-144 Ve have completed our reviev of an allegation concetning activities at Millstone Unit 2 (RI-90-A-144). As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information. The r.aterial contained in this response may be released to the public and placed in the NRC Public Document Room at your discretion. The NRC letter and our response have received controlled and limited distribution on a "need to know" basis during the preparation of this response. Based upon our request on October 25, 1990, Region I personnel extended the due date for this response to December 7, 1990. The basis for our extension request was the competing demands for time on personnel involved in these matters and the then ongoing refueling outage.
Item 1 Steam Jet Air Ejector (SJAE) radiation monitor, PH 5099, does not appear to be collecting vater.                                    The monitor response may have decreased.                                                                                The Plant Equipment Operator (PEO) has not emptied the collection bottle for ten days (as of September 14, 1990), although normally, four quarts of water are emptied per day. The monitor has been reading 2,000 cpm and has decreased to 1,000 cpm.
9104250181 910417 PDR             ADOCK 05000336 P                                                   PDR oS1422 REV 4 48

     -.   ,4 Mr. E. C. V:nzing r, Chief
        -     U. S. Nucicar R:gulctory Conaission
[
A09076/Page 2 December 7, 1990
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Background Information The SJAE RM monitors the gaseous activity in the SJAE exhaust. The system includes a maisture removal system that dries the gas going to the detector pig. The output of the moisture removal system is manually removed from collection bottles as part of the Plant Equipment Operator rounds. The moisture content of the gas exiting the SJAE is largely dependent upon the performance of the SJAE drain system. When this SJAE drain system is operating effectively, there is essentially no moisture to be removed. When the SJAE is not being effectively drained, the moisture content in the SJAE exhaust increases substantially. As a result, the amount of moisture removed by the RM moisture collection system increases as well. If the moisture is not effectively ren.oved from the gas, it collects in the detector pig and causes the detector to fail.
Exc3ssive moisture in the SJAE exhaust has been a long-standing problem with the operation of this system. A replacement radiation monitoring system that is external to the process piping is currently being designed (Project Assignment 89-053). This vill allow reliable radiation monitoring vithout compromise by the moisture level of the SJAE exhaust.
This allegation questions the response of the RM during the time period of September 4 through 14 of 1990. During this period, the unit operated at 100%
pover. During the previous veek, the unit had undergone a startup that included a review of the valve alignment of the SJAE drain system. Changes in the valve alignment at that time significantly improved the moisture removal effectiveness of the SJAE. The result of this improved drain performance was the lov output of moisture from the RM moisture removal system. This lov output of moisture is a normal response for the RH system when these conditions exist.
The activity level of the gas at the SJAE is dependent upon the amount of the gaseous activity of the RCS, the amount of primary to secondary leakage, and the amount of air inleakage into the condenser. During this time period, the RM readings varied between 1,000 and 2,400 cpm. Chemistry samples indicate that SJAE activity was 2 E-5 uci/ml to 6 E-5 uci/ml respectively. This shows a close correlation between actual sample values and RM response.
: a. Should Operations have determined there to be a problem?

===Response===
The RM performance during this time period does iot represent a problem.
The response of the RM vas correct for the plant conditions present. The secondary side conditions, including the SJAE activity levels, are appropriately monitored by Operations. This includes review by Plant Management and Chemistry staffs on a daily basis.

Mr. E. C. Vznzingar, Chief
    ,.~      U. S. Nuclear R:gulatory Comaission A090'ia/Page 3 December 7, 1990
         *b. Have appropriate compensatory measures been taken by Operations?

===Response===
No additional actions were necessary,
: c. Have evaluations been done to ensure the monitor is operating properly or is reliable?

===Response===
Yes. The RH's performance is revieved on a daily basis by the Operations, Management, and Chemistry staffs. Vhen the monitor was removed from service at the next outage, it was verified to be dry and in proper vorking order. The long-term reliability issue is being addressed by the replacement of the RH vith a non-intrusive system, which is not subject to moisture damage. Short-term reliability of this RM has been enhanced by the upgrading of the moisture removal system capacity and additional Operations' awareness of the need for optimum performance of the SJAE drain system.
: d. If problems have been noted, what actions have been taken to evaluate, compensate, track, and resolve the problems? Have all appropriate trouble reports or other documents been completed or filed?

===Response===
Ve currently plan to replace the RH vith an improved design in 1991.
L                The RH vas calibrated during the outage as part of its normal maintenance.
Bypass jumpers remain in place that have increased the moisture removal capability of the system. All work has been conducted in accordance with station procedures.
: e. Have Operations and I6C personnel performed the appropriate duties with regard to the radiation monitor? (The Shift Supervisor and an I6C L                supervisor have been made aware that there may be a problem.)

===Response===
l l                Yes,-appropriate duties vere performed.
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: f. Vhat actions are planned to ensure continued reliability and performance?
i j                Response Short term - Additional attention has been placed by Operations on the
!                proper operation of the SJAE drain system. Performance review activities will be continued by Operations, Management, and Chemistry staff-personnel. A temporary SJAE radiation monitor is being used to provide diverse indication.

I Mr. E. C. Venzingar, Chiof                                                                                                                               )
U. S. Nucleat R gulatory Cornission                                                                                                                       !
                                .A09076/Page 4                                                                                                                                              i a                                 December 7, 1990
* Long term - The RN is planned to be replaced in 1991 vith the mnre                                                                                  1 reliable system being designed and procured at this time.
                                  , Item 2 The alleger has complained that an 1&C Supervisor failed to tespond to one of his concerns within a 14-day administrative requirement. The concern was raised by the alleger on August 23, 1990 and involved three issues:
: 1. use of the " completed by" block for prerequisites,
: 2. a ptocedure statement about required actions if RPS pretrips come in on another channel, during testing, and
: 3. break times.
ltems (1) and (3) vere discussed at a September 5, 1990 16C Department meeting.      Item (2) vas not discussed.
Background Information A Unit 2 I&C Department meeting vas held on August 23, 1990. A variety of material was covered. Numerous questions vere fielded f rom the at tendees.
i
: a. Vhat is your policy in this regard?
Rerponse pertinent questions asked during Department meetings for which an answer must be researched are addressed. No time requirements exist for this process. The Department meeting forum is used as a means of sharing information and discussing issues in an open environment which are of interest to the entire Department.
: b. Does the complaint have validity, and if so, why vasn't the employee's concern addressed?

===Response===
The issue does not have validity. The question (i.e., Item 2 of this allegation) was asked by a member of the 16C Department and addressed by the Department Manager at that time. The Department Manager did not note the need for specific follov-up to this question. The verbal response provided by the Department Manager to Iteu 2 of this allegation discussed the Unit 2 I6C procedure guidance regarding surveillance testing.
i

Mr. E. C. V:nxinger, Chief
     .'       U. S..Nucloor R:guistory Consission
             'A09076/Page 5 December 7, 1990 Item 3 A vorker was assigne0 to troubleshoot a problem with the control circuit for the turbine bypass valves under AVO 90-09684 on September 11, 1990. Vork had previously been performed on this system under AVO 90-06498 and AVO 90-07792.
This vorK identified deficiencies with PT 4300 which vere to be corrected during the outage.
: a. The initial AV0s may not have been documented in the appropriate loop folder. Is there a requirement to do so? Vhy vasn't this requirement met?

===Response===
There is no station requirement to maintain a loop folder. Vork activities that are performed are required to be documented on the AVO document. Unit 2 I&C has a Department Instruction 1.10 that defines the contents of the department loop folders. It includes the I&C specialists' and technicians' responsibility to maintain a brief handwritten vork history in the loop folder.      It is expected that all Unit 2 I&C personnel vill keep the loop folder information up to date. This allows a more ef ficient work history reviev than car, be obtained f rom the PMMS system or the Nuclear Plant Records facility.
AVO M2-90-06498 vas vritten to troubleshoot a problem associated with a reactor regulating system alarm. Since this vas written against the system ID, there is no loop folder to record information in. The AVO that governed the specific calibration activity on PT 4300 was updated with the    {
necessary information.      All Unit 2 I&C Department expectations were met with respect jo loop f oldeTenGies.
: b. An orange sticker was not affixed to the instrument PT 4300 contrary to Dyertment instruction causing a redundant ttouble report to be issued.
Is there a requirement to affix an oranEc sticker when a deficiency is identified with an instrument? Why vasn't that requirement met?

===Response===
ACP-0A-2.02C, "Votk Orders", contains step 6.1.2 that states, "Vhere possible, place problem report tags / stickers on the component or other conspicuous location, which indicate the problem has been reported." The requirement van met for each trouble report. Note that the AVO problem description reflected the problem as it was seen by the Operations staff.
Vork order tags vere appropriately hung, as indicated on the associated AV0s. The location of the tag is typically at the location that is conspicuous to the Operations Department staff. In this case, it was properly located in the control room by the alarm vindow that is associated with the reactor regulating system.
l l

Hr. E. C. benringer, Chief l   .
U. S. Nuclear Regulatory Commission
  -       A09076/Page 6 l         December 7, 1990 Note the second AVO, H2-90-09684, is not a "redandant" trouble report.
The first AVO, M2-90-06498, identified the alarm condition as being caused                                                                I. b by the pressure transmitter and recommended its calibration. The second AVO describes an additional problem, that of the recent decream in the Tref value as well ss the previously existing alarm condition. The
                                                                                                                                                            /
information that PT 4300 had alteady been identified as needing calibration was included in the job description section of AVO H2-90-09684. The work activities of this AVO resolved problems associated                                                               j vith both the recorder and the pressure transmitter viring.                                                                   AVO     /
M2-90-07792 pertormed the calibration activity.
Atter our review and evaluation, ve find that none of these issues taken either singularly or collectively present any indication of a compromise of nuclear safety.                                   Ve appreciate the opportunity to respond and explair. the basis for our actions. Please contact my staff if there are further questions on any of these matters.
Very truly yours, NORTilEAST NUCLEAR ENERGY COMPANY c'397M
                                                                                                                        ~
C. J.t)tioczka (/
Senici Vice President cct   V. J. Raymond, Senior Resident Inspectot. Millstone Unit Nos. 1, 2 and 3
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