A10023, Discusses Review of RI-91-A-276 Re Various Activities at Millstone Unit 2.W/related Matl

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Discusses Review of RI-91-A-276 Re Various Activities at Millstone Unit 2.W/related Matl
ML20080K832
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/23/1991
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20079Q807 List:
References
FOIA-92-162 A10023, NUDOCS 9503010338
Download: ML20080K832 (6)
v • d • e


Text

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, Re: Employee Concerns (  ;

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Mr. Charles W. Hehl, Director V Division of Reactor Projects g yt :

l U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

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Dear Mr. Hehl:

Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0276 We have completed our review of an identified issue concerning activities at Millstone Unit No. 2. As requested in your transmittal letter of November 19, or 1991, our response does not contain any personal privacy, proprietary, safeguards information. The material contained in this response may be released to the public and placed in the NRC Public Document Room at your letter and our response have received discretion. The NRC transmittal controlled and limited distribution on a "need-to-know" basis during the preparation of this response.

ISSUE:

"Although the Millstone 2 process radiation monitor multi-point recorder RQR-9129 may pass the Northeast Utilities calibration requirements which are based on the recorder logarithmic scale, it fails to meet the manufacturer's specified accuracy, +/- 0.3% of the recorder linear electrical span."

REQUEST:

Include in your "Please provide your evaluation of the above assertion.

response the reason why calibration stickers are placed on equipment which may not meet manufacturer's accuracy specifications, and why no procedures exist Please compare to perform calibrations of non-safety related instrumentation. If the above the performance of this recorder with other similar recorders.

condition is valid, notify us of the corrective actions you have taken to prevent recurrence. Also please provide us with us with an assessment of the deficiencies, including generic safety significance of any identified considerations."

9503010338 940009 9

PDR FOIA PDR HUBBARD92-162

1 Mr. Charles W. Hehl A10023/Page 2 ,

December 23, 1991 j

RESPONSE

I We were initially made 4 ware of an employee's concerns regarding this asser-tion via a memo on October 11, 1991 to the Millstone Unit No. 2 I&C Manager, at which time we Sgan en investigation. j This assertion is not valid. The required accuracy of a piece of instrumenta-tion is determined by the user in order to meet the needs of the application for which it is used.

The m. curacy of a piece of instrumentation as stated by the vendor is that which the instrument is capable of achieving and not what is necessary for its application. In this case, the recorder manufacturer states an accuracy capability of +.3 percent of the recorder electrical span. This equates to +

0.3 millivolts over a 100-millivolt electrical span. The recorder's overall accuracy from input signal to output pen is not established by the manufac-turer. The recorder at issue is used to trend liquid effluent radiation monitors. The NUSCO Radiological Assessment Branch (RAB) has established that all effluent radiation monitor recorders are primary indicators and will be within +/- 20 percent overall accuracy. As long as the recorder meets the overall accuracy required for its use, it is our policy that it will display a calibration sticker signifying that it is within its calibration limits.

There are no Administrative Control Procedure requirements to have specific calibration procedures in place for nonsafety-related instruments. It is the Millstone Unit No. 2 Instrumentation and Controls (I&C) Department practice to attach a calibration sticker to equipment that has been calibrated. This is included as a procedure activity in Procedure IC 2427A, " Recorders Annual PM."

Basic calibration checks, adjustments, and repairs as described in the vendor technical manual are skills expected to be within the abilities of an instru-ment specialist at Millstone t' nit No. 2. Should adjustment of the recorder be required and the specialist was unsure as to the technique required, the guidance provided in the vendor technicai manual would be reviewed and used.

Also, Instrument Specialists are encouraged to stop work and discuss questions with their supervisors if they are unsure of how to proceed.

The complexity of an instrument and the role the instrument serves determines whether a procedure is required for its calibration. The instrument at issue is addressed by Procedure IC 2427A, which provides an annual preventive maintenance activity for the recorder and includes its calibration. Since this is a multipoint recorder, the calibration of each point is also checked in the calibration procedure of each radiation monitor which inputs to it.

This process ensures that the individual channel's performance meets its acceptance criteria.

Mr. Charles W. Hehl A10023/Page 3 December 23, 1991 The performance of RJR-9129 has been satisfactory for the purpose it serves and compares favorably with other recorders of the same manufacturer. A review of maintenance history does not indicate any significant defects.

After our review and evaluation of this issue, we find that this issue did not present any indication of a compromise of nuclear safety.

, We appreciate the opportunity to respond and explain the basis of our actions. l Please contact my staff if there are further questions on any of these  !

l matters. I Very truly yours, 4 NORTHEAST NUCLEAR ENERGY COMPANY l

J. F. Opeka k E dJL O

Executive Vice President cc: W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 E. C. Wenzinger, Chief Projects Branch No. 4, Division of Reactor Projects i E. M. Kelly, Chief, Reactor Projects Section 4A I J. T. Shedlosky, U.S. Nuclear Regulatory Commission, Millstone l

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-blMITED~DISTRIBUTIDMOT10f PdBI'IC' DISCLOSURE ENCLOSURE Issue RI-91-A-276:

Although the Millstone 2 process radiation monitor multi-point recorder RJR-9129 may pass the Northeast Utilities' calibration requirements which are based on the recorder logrithmic scale, it fails to meet the manufacturer's specified accuracy, i 0.3% of the recorder linear electrical span.

l Request:

Please provide your evaluation of the above assertion. Include in your response the reason why calibration stickers are placed on equipment which may not meet 1 manufacturer's accuracy specifications, and why no procedures exist to perform calibrations of non-safety related instrumentation. Please compare the performance of I

this recorder with other similar recorders. If the above condition is valid, notify us of the corrective actions you have taken to prevent recurrence. Also please provide us with an assessment of the safety significance of any identified deficiencies, including generic considerations.

At _ - J - - . -- r A6 s NT  :

AIMATIGi RECEIPT RE!WT  !

Date/ Time / i Received: October 16, 1991 0730 Allegation No. [ 1 T I - ON '

Name: Address:

Phone: City /St./ Zip: -

Confidentiality:  ;

Was it requested? No Alleger's Employer: NNECO Position /

Title:

Instrumentation and Control 1 Department Technician  !

Facility: tiillstone Unit 2 Dockat No.: 50-336 Allegation Summary: Pm Radiation tionitor thalit-point ~ Recorder, RJR-9129, fails to meet the mamfacturers specified accuracy of *0.3K of its electrical span. The instnament apparently met the li ~s program accuracy mquire-monts.

Number of Concerns: 1 .

Employee receiving allegation: J. T. Shedlosky l

Type of regulated activity: Reactor l Functional Area (s): Operations Detailed Description of Allegation: The allesse informed us of an issue has been '

brought to the 14a-ama='s attention. '

h si i h alleser noted that the pma=== radiation monitor multi-point recorder, RJR-9129, failed to meet the marnifacturer's specified accuracy of *0.3K of its 1 electrical span. '

This specification was +9 from the 4==tnament hia=1

= =1 h recorder has a logarithmic acale which may allos it to pass the pud = al calibration requirements easier than the linear performance specified  !

by the naimifactaarer.

Atwhts:

tismoran&m dated October 11, 1991 Leeds & Northrgy 't:'- =- H & W thalti-point Recorder Mm==1 pages: ouver, intro & action, contenta and specification.

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i RECORD OF ALLEGATION PANEL DECISIONS l SITE: _ s 3% PANEL ATTENDEES:

ALLEGATION NO.: b9I bd Chairman - V4CL AS DATE: 2iOC7 *Id- (Panel No 3 4 5) Branch Chief -

PRIORITY: High Low section chief fAOC) -

SAFETY SIGNIFICANCE: Y,e s Unkn Sr. Allecation Coord iSAC) VMfd CONCURRENCE TO CLOSEOUT: DD h SC OI Representative -

CONFIDENTIALITY GRANTED: Yes @ (Other) kN . MNd (See Allegation Receipt Report)

IS THERE A HARASSHENT/DISCRIHINATION IF YES, ISSUE: Yes h

1) has the individual been informed of the DOL process and the need to file a complaint within 30 days Yes No
2) has the individual filed a complaint with DOL Yes No
3) has a letter been sent to the complainant seeking Yes No any safety concerns IS A CHILLING EFFECT LETTER WARRANTED: Yes IF YES, HAS IT BEEN SENT Yes o HAS THE LICENSEE RESPONDED TO THE CHILLING EFFECT LETTER: Yes No ACTION: RESP ECD
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  • f REcloN I 475 ALLENDALE ROAD KING oF PRUS$1A, PENNSYLVANIA 19406 1415 ayy Docket Number: 50-336 File Number: RI-91-A-0278 Northeast Nuclear Energy Company ATTN: Mr. John F. Opeka Executive Vice President - Nuclear P.O. Box 270 Hartford, Connecticut 06141-0270

Dear Mr. Opeka:

The U.S. Nuclear Regulatory Commission recently received information concerning activities at Millstone Unit 2. Enclosed are the details for your review and followup.

We request that the results of your review and disposition of these matters be submitted to Region I within 30 days of the c' ate of receipt of this letter. We request that your response contain no pasonal 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. Please refer to file number RI-91-A-0278 when providing your response.

The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the concern has been completed and reviewed by NRC Region I. The enclosure to this letter is considered Exempt from Public Disclosure in

&ccordance 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.

Your cooperation in this matter is appreciated. We will gladly discuss any questions you have l concerning this information.

Sincerely, p '

Charly W. Hehl, D ector Division of Reactor Projects G f o w iiI

3 Northeast Nuclear Energy Company 2

Enclosure:

10 CFR 2.790(a) Information Issues and Requests cc w/o encl: .

Public Document Room (PDR)

Local Public Document Room (LPDR)

State of Connecticut -

bec /w encl:

Allegation file: RJ-91-A-0278 E. Conner W. Raymond/T. Shedlosky Contractor's Office (Hunt)

I concurrences:

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