View source for A09755, Informs That Review of Issues Re Employee Concerns for Allegations RI-91-A-0172 & RI-91-A-0173 Complete.Comments Encl

{{Adams
| number = ML20091P988
| issue date = 09/13/1991
| title = Informs That Review of Issues Re Employee Concerns for Allegations RI-91-A-0172 & RI-91-A-0173 Complete.Comments Encl
| author name = Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Hehl C
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000336
| license number = 
| contact person = 
| document report number = A09755, A9755, NUDOCS 9202040118
| package number = ML20091P903
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

=Text=
{{#Wiki_filter:.                                     _ _ _ _ _ _ _ _ _                  _
-   NORTHEAST                 UTILITIES                                                                  o.n.,,i on,c.. . som.n si, t s.,i,n. conn.ci,cu
                     ,_ .e...                   .-
9             =ri-w ,,i s m= coe."'                                                                                  P O. DOX 270 HARTFORD. CONNECTICUT o6141 o270 Z$'.,7),*(([*L k  '    J     . . ,a . i.m. w                                                                                        (203) 665-5000 September 13, 1991 Docket No. 50-336 A09733 RE:  Employee Concerns, Hr. Charles V. Behl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406

==Dear Hr. Behl:==

Hillstone Nuclear Power Station, Unit No. 2 RI-91-A-0172 & RI-91-A-0173 Ve have completed our reviev of identified issues concerning activities at Hillstone Station.                               As requested in your                        transmittal letter, our sesponse does         not contain                any personal privacy,                                      proprietary, or 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 Staff's transmittal letter and our response have received controlled and limited distribution on a "need to know" basis during the preparation
: c. f   this response. Additional time to respond to these issues was granted by the Region I Staf f in a telephone conversation on August 30, 1991.
ISSUE S        172:
After        tagging out the Air Ejector Exhaust Fan "B" for preventative maintenance on June 24, 1991, auxiliary contacts in the fan motor's circuit breaker cubicle remained energized.
Request:
T) case discuss the validity of the above assertion. If deficiencies are found in the equipment tagging procedures, please notify us of the corrective actions you have taken to prevent recurrence.                                                                  Please provide us with         an assessment of the                                                  safety significance of any                    identified deficiencies.
9202040118 911106 PDR     ADOCK 05000336       PDR p
l
                                          - - = - - . _. _- -_-_-_- -_ - _                   _         _         __-_ - _ _

Mr. Charles V. Behl, Director U. S. Nucloor Regulatory Commission A09755/Page 2 September 13, \991

===Response===
The assertion, as stated, is valid. Air Ejector exhaust fans F55A and F55B fan by opening the power are interlocked such that de-energizing the "B" supply circuit does not de-energize all of the contacts associated with this interlock.
A review of the Automated Vork Order (AV0) and the associated tag log sheet for the preventive maintenance for fan F55B shovs that because of plant operating needs it vould not have been practical to de-energize both Air Ejector Exhaust f ans, therefore, no additional tagging vas provided for the work.
items A-2 and A-3, The job leader made a note in the AVO indicating that which are the inspection of the main and auxiliary contacts, could       not be However, this performed because of the cross feed f rom the other fan unit.
note was lined-out by the Electrical Maintenance Supervisor, initialed and dated. When interviewed, the Electrical Maintenance Supervisor indicated that    the individual performing the work did not feel comfortable in performing items A-2 and A-3 of the preventive maintenance      Thewith voltage Electrical potential across some of the auxiliary contacts.
Maintenance Supervisor then completed the preventive maintenance items and signed off the AVO. As explained in the Background Section belov, no individual is pressured to work with energized circuits.
ISSLIE 173:
On June 24, 1991 inadequate electrical"B"     boundaries vere established to Stator Cooling Vater Pump in support preventative maintenance en the                                     "B" that the "A" pump vas not tagged out to pr eclude cr oss-f eeding to the pump. This was said to occur because Generator Test Engineering was concerned that the system would drain and air bind.
Requests Please discuss the validity c' the above assertion. If deficiencies are found in the equipment tagging procedures, please notify     Please us of the provide us corrective actions you have taken to prevent recurrence.            identified with Li assessment of the          safety significance  of  any deficiencies.

===Response===
j The assertion is not valid. Review of the electrical schematic draving for the Stator Cooling Vater Pump, Pf5B. indicates that there is an interlock between the pairs of Stator Cooling Pumps. However the relays and contacts receive 125 volt DC power from the Plant Annunciator System so that tagging the 'A" Stator Cooling Pump vould not de-energire the auxiliary contacts in i
l the P65B cubicle.

                       -_    .-     -  . _-      -- .. -. . - - - .             -      ~. -
_ ,.7 Mr. Charles V. H:ble Director
: 11. S. Nucicar Regulstery Commission
    -         A09755/Page 3 September 13, 1991 The Automated Vork Order (AVO) and associated tag log sheet for the preventive saintenance for pump P0$B shov that no additional tagging was provided and no notes to indicate the existence of any problem with tagging were antered into the AVO. The AVO vas signed off as complete and satisfactory.
Background for Issues 172 and 173:
Performing preventive maintenance on breakers and motor starters with energized auxiliary contacts is an issue that has been previously addressed and resolved within the Haintenance Department. Guidance for vorking with Electrical electrical equipment was previously provided from the Maintenance Supervisor to plant maintenance electricians as follows.
there are
: a. Test the equipment to ensure that it is de-energized.
If portions of-the circuit that remain energized, the work packageIfshould   after be returned to Operations and additional tagging requested.
additional tagging      is  not reviev by~ the Operations Department, practical _or cannot be provided, one of the following alternatives should be performed:
: b. Request permission from the Control Room to remove the starter from the cubicle. .Upon concurrence from Operations, remove the starter and complete the PM activity,
: c. Perform the vork vith the starter-in the cubicle- using proper safety equipment    and devices. As a minimum when vorking on or near energized equipment of 750 volts or less,_ electricians are instructed to vear lov voltage gloves and safety glasses,
: d. If an electrician does not find any of the above acceptable, the job is to be stopped and the Electrical Maintenance Supervisor informed.
Department : policy has been that any.individuel not feeling that preventive maintenance can be performed safely on equipment with some auxiliary contacts remaining energized is not to work on jobs that he does not
* believe are safe. No one has been or vill be pressured to work with                  ,
energized circuits.
Since the -procedures. and guidance are in place to support the above discussion,    there are no ' deficiencies in the tagging procedures and no corrective _ action is required. Since the work can-be performed safely by following the electrical maintenance guidance, and no_ one is pressured to work on energized circuits, there is no ' adverse impact on either nuclear or industrual safety.
I It    is important to understand that tagging is the mutual responsibility 'of the 'Shif t Supervisor and . the Job Supervisor at Millstone. Included in the j
responsibilities of the Shift Supervisor are the placing of proper tags for personnel safety and evaluating how the intended tag-out vill' af fect the plant. The Job Supervisor is responsible for verifying that the equipeent isolation and tagging represents safe-vorking conditions at the work site.
t

4 Mr. Charles V. Bahl, Director U. S. Nuclear Regulatory Commission
  -       A09755/Page 4 September 13, 1991 For maintenance.setivities, such as troubleshooting, in which the scope of work can not be clearly defined or the circumstances change as the job is being performed, the sagging process may be iterative. In either case, Operations vill add or change tagging-vhen requested by a Job Supervisor.
If plant conditions do not allow additional tagging, alternate methods such as removing the circuit or vorking on energized circuits are available.
After our review and evaluation of these issues, ve find that they did not present any indication of a compromise of personnel or nuclear safety.-
Ve vere avare of        the concern expressed regarding issue 0172, and since existing practices exempting employees from performing vork vi~th which they feel uncomfortable vere followed, no action was required. Ve vere not avare of any concern relating to issue 0173 prior to the receipt of the NRC letter.      Ve 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 F,
                                                                          $/
J.~H/4czk'a Senior Vice President cci   V. J. P,aytond, Senior Resident      Inspector, Millstone Unit Nos.       1, 2, and 3 E. .C. Venzinger, Chief, Projects Branch No. 4, Division       of Reactor
                -Projects E. H. F.elly, Chief, Reactor Projects Section 4A J. T. Shedlosky, NRC, Hillstone Nuclear Power Station l
l l
                                                                                                       .}}