.g , . ,1

--,

, . LgM -- ggggggg gyggygg o.nors ou,e... sea.n sir..t. e rnn Conn eucut .

. m1 - wesNaYsIeNiettIYNc*'co*mpa'n7 P.030X270-

' * '

$57a:NENv e7c'Eny . HARTFORD. CONNECTICUT 06414-0270-g . '. , Nortrieast Nuciw Energy Company - (203)665-5000 ;i

4 a'.

-- !,

Re: 10CFR50.73(a)(2)(i)'

october is 1990MP-90-1066

9 U.S. Nuclear Regulatory Commission .Document Control Desk..

M Washington, D.C. 20555, ,

T' Reference: Facility Operating License No. NPF-49Docket No. 50-423 ,' Licensee Event Report 89-018-01

t'

Gentlemen: $,.

- .

: This letter forwards Licensee Event Report 89-018-01,-which is being submitted torevise the anticipated completion date for the action to prevent recurrence, as discussedin the response to Notice of Violation 50-423/90-10. Licensee Event Report 89-018-00.was submitted pursuant to 10CFR50.73(a)(2)(i), any operation or condition prohibitedby the plant's Technical Specification.

;

FOR: Stephen E.' ScaceDirector, Millstone Station

-;

.

BY: Carl Yd$Ine'

;'

Millstone Unit 3 Director!

SESNRJ:mo.

Attachment: .LER 89-018-01'

-cc: T. T. Martin, Region I Administrator,W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2 and 3D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 i

;

-

*p.

O - .,

NAOtorm 344 U 6, NUCLEAR REGULATORY COMMISSION APPROVED OM6 NO 3150-0104,a6-69) E XP RE S 4 /30'92*'.

Estimated buroen par response to comply with tNsenformaton conection teovest 60.0 nrs. Forward

LICENSEE EVENT REPORT (LER) EE" ts Ea'nNn'",*a'l$"$*sTO$"*u"S Eu*c.ar'**

BRegulatory Commission. WasNngton DC 20555. and to*the Pep.rworm Reduction Pro-ect (3160-0104). Othee ofManagement and Booget. WasNngton. DC 20503

F ACILITY NAME ( ; DopiT NUMbsk 121 ,'''9Millstone Nuclear Power Station Unit 3 015| ol ol of 4 |2 |3 1|OF| 0| 4

TilLE 14)Inoperable Waste Neutralization Sump Effluent Radiation Monitor Due to Personnel Error

EVfNT DATE ($ r (F A NUMR84161 AEPOAT DATE (7 n OTHE A F A0t| TIES INVOL VED #8MONTF DAY YEAR YEAR MONTw DAY YEAR F ACIUTY NAMES i

ofsIofolol i I~

O 8 0|2 8 9 6 |9 0|1|8 0| j 1|0 0| 1 9| 0 o; 5g og o| o; ; ;OPERATING THtS REPORT IS BEING SJBM4TTED PUASUANT TO THE REOJREMENTS OF 10 CFR i: (Check one or more of tne followincH1t)

DE W I20 402tb) 20 402tc) 60. 73(a H2) t n) 73.71tb).

OWER 20 406ta)(1|(1) 60.36 t c)(1) 50.73(a)(2)(v) 73 71gejLE VE, L 1 | () | 0

-

20 405Iait tlDij 60.36 tc)(2) 60.73 taH2)(vil) OTHER Soecify in- ' - -

110

v $mS[A),

_20 405(a)(1)thi) $0. 731aH2HO 60. ?3(a)(2 H viii)( A t t*

20 405(a)(1Hiv) 60. 73 t a H2) till 60.73 tall 2)(viii)(B)4 *,

20 406 t a t t i l ov) | 50 731aH2Hb4 50 73(aH2Hx)

LICENSEE CONTAOT FOA TH:S LEA (12i

NAME TELEPHONE NUMBE A

AREA CODE\'ere R. Joseph, Associate Engineer, Ext. 5571

2|0|3 4| 4| 7|-| 1| 7| 9| 1CovptETE ONE UNE FOA E ACH COMPONENT FAfLURE DESCRIBED IN TH:S REPORT 113)

'

OAuSE SYSTEN COMPONENT Nhk~'

CAUSE SY$TEU COMPONENT hgC- .*,

I II I I I I ^ l !I I I I I'

'

I II I I I I I Ii I I I I ' 'SUPPLEMENTAL REPORT EXPECTED 414 6 MONTH DAY YEAR

SUBMISS:ON

~l YES of v.s comom. EXPECTED SUBMtSS!ON DATE) NO | | |DATE 05)

ABSTRACT (Limn to 1400 soac.s. ... . aoorommmeon.en s,.-soac. ivoewnu., nn.s> oe)

On August 2,1989 at 1430, in Mode 1 at 100rc power, shift personnel declared t le Condensate DemineralizerWaste Neutralization Sump effluent radiation monitor, 3CND-07 inoperable due to inadequate testing of thei

I high activity automatic termination feature, since plant startup.

The compensatory actions required by the Technical Specifications had alread; been incorporated into existingprocedures and were being performed. However, Technical Specifications a'30 requires an explanation besubmitted in the next Semiannual Radioactive Effluent Release Report indicating why the "inoperability" was notcorrected in a timely manner (30 days). This action was never performed.

The root cause of the event was personnel error. Plant personnel failed to incorporate all of the automaticrelease termination capability of 3CND-07 into the applicable surveillance procedure. With the radiation monitorinoperable an explanation was never provided in the Semiannual Effluent Release Report.

No immediate correctise action was required. The surveillance procedure was changed to incorporate theinterlocks for all release paths and were satisfactorily tested. An explanation will be provided in the nextSemiannual Release Report. No other deficiencies were identified in other radiation monitoring surveillances.Lessons learned will be included in the training for applicable plant personnel.

NRO Form 366(6-89)

- _ _ _ - _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

_

_ _ . _ . . . . _ . . . . .

'

U.$. NUOLE AR REGULATORY COMM:SSioN APPRo bi 60-0104gorm acoA .*

Estim ied ouroen per response to compiy witn tNo

LICENSEE EVENT REPORT (LER) 'ajo"g,g'et;,on '*g"L6,{,0f','g ,ff'n**'|,,,TEXT CONTINUATION ano Repons uanaa.meni eranen to-s3ci. u s. Nuc ar

f3no ae Ro on Pro 1 o nManaoement and Budget. WanNngton. DC 20503:

F ACL,lTY NAME (1) DOCKET NUMBER (2) if n Nuusq m asi PAGE (3)

YEAR

Millstone Nuclear Power StationUnit 3 o| sj o| o| o|4 |2 |3 8|9 0| 1| 8 0|1 0| 2 OF 0|4

TEXT (19 more space is required. use modttional NRC Form 366A's) (17)

1. Deerintion of Event

On August 2,1989 at 1430, with the plant in Alode 1 at 100G power, 587 degrees Fahrenheit and 2250psia, shift personnel declared the (Condensate Deminerahzer) Waste Neutralization Sump effluentradiation monitor, 3CND-07, inoperable due to inadequate testing of the automatic release terminationfeature on high effluent radiation. The testing deficiency was discovered by RadiologicalAssessment / engineering personnel reviewing the radiation monitoring surveillance program to verifyadequate testing procedures were in place. Compliance with existing plant procedures and theRadiological Effluent Monitoring and Off-site Dose Calculation Manual (REMODCM) fulfilled thecompensatory actions required by plant Technical Specification 3.3.3.9. However, TechnicalSpecification 3.3.3.9 also requires that an explanation in the next Semiannual Radioactive EffluentRelease Report, of why efforts to restore the inoperable radiation monitor had not been completed withina timely manner (i.e., 30 days). This requirement was never performed.

3CND-07 is required to be operable at all times in Modes 1 (Power Operations) - 5 (Cold Shutdown)and, in Mode 6 (Refueling) when discharges are being performed from the Waste Neutralization, Sumps.The analog functional check surveillance procedure only tested the automatic discharge termmauoncapability of one (out of three) release paths since plant startup. Of the two remaining WasteNeutralization Sump Effluent release paths, only one had not been in service since plant startup. Theother release path was m service as a temporary system under the station's Bypass / Jumper program, untilJanuary of 1989. At that time, a plant modification incorporated the temporary system as permanentplant equipment. As part of the modification, new interlocks were added to allow automatic isolationcapabihty of all release paths for the Condensate Demineralizer Waste Neutralization Sump effluent on ahigh. radiation signal. These interlocks were satisfactorily tested upon completion of the modification, butthe surveillance for the radiation monitor was never updated to reflect the new interlocks. This

. requirement was not identified during the review of the modification since credit was taken for theadministrative controls already in place.

11. Cauce of Event

The root cause of the event, was personnel error. The surveillance procedure associated with the WasteNeutralization Sump Radiation Monitor had not been updated due to engineering and administrativeoversight during the review of the Condensate Demineralizer Liquid Waste system requirements. As a-result, all of the actions required by the Technical Specifications for 3CND-07, were not performed. Thisrequirements was missed throughout the modification review cycle, since credit was being taken forexisting administrative controls.

111. Analvsic of Event

This event is reportable under 10CFR50.73(a)(2)(i), as a condition prohibited by the plant's TechnicalSpecifications.

Technical Specifications 3.3.3.9 requires that radiation monitor 3CND-07 be operable at all times duringModes 1 (Power Operation) through 5 (Cold Shutdown) and, Mode 6 (Refueling) during actual orpotential releases of radioactive effluent from the Waste Neutralization Sumps, to provide automatictermination of a release on high activity. Interlocks existed to provide automatic release termination onhigh acuvity. However, only one of the flow paths was being surveilled. Since, the automatic releasetermination capability of the other two release paths were not surveilled since initial functional testing, theradiation monitor was inoperable.

I

gagorm 3ee

1

* N5 Furm 366A U.S. NVcLE.t.R REGULATORY CoMMiSStoN APPROVED OMB No 3160-0104(6-89) EXPtAES 4/a0'92

Estimated twroen per response to comply with this

LICENSEE EVENT REPORT (LER) '"j',m*J, ",g'*"y'g's,510f,'og'f,,, *TEXT CONTINUATION ano Rooons uanagement Branen ip sao). U.S. Nuclear

' O. . Regulatory Commission, Washington. De 20655, and tothe Paperwork Aecuction Pro,ect (3150-0104 L office ofManaoement ano Buopet. washington. De 20503

F ACILITY NAME (t) DOCKET NUMBER (2) (FA NtomFn e PAGE(36

YEAR

hiilistone Nuclear Power Station tUnit 3

0| 6| 0] o| o|4 |2 |3 8|9 0|1|8 0|1 0| 3 OF 0[4TcxT of more space is reawr.o. us. soaii:onai Nac Form a66A ) itr) ,

111. Annhwis of Event (Cont'd)

The safety significance of this event was minimized due to performance of the required TechnicalSpecification and RENIODCM actions via existing plant procedures. Steam generator gross activity wasverified below minimum detectable activity (h!DA), independent (dual) valve kne-up verification wasbeing performed and effluent flow was being calculated as required. Had steam generator activity beenabove hlDA, existmp procedural controls were in place to maintain radioactive releases within the limitsof 10CFR20. In addition, the automatic release termination capability of 3CND-07 on high activity (forall release paths) was subsequently satisfactorily tested, which indicates that they were fully capable ofperforming their miended function.

IV. Corrective Action

No immediate corrective action was necessary, since the required Technical Specification compensatoryactions were being performed via existing plant procedures. i

As corrective action, the surveillance procedure for testing the automatic release termination feature of3CND-07 has been changed to include all release paths from the Waste Neutralization Sumps and thesurveillance procedure was satisfactorily tested. An explanation was provided in the July-December,1989Semiannual Radioactive Effluent Release Report as to why 3CND-07 had been inoperable for a periodgreater than thirty days. The review of all other radiation monitonng surveillances to verify compliancewith the requirements of the Technical Specifications did not identify other reportable deficiencies. Thelessons learned from this event will be incorporated into the Technical Support Staff /Alanagers, and PlantOperations Review Committee members training, which will be completed by December 31, 1990.

V. Additinnnt information

Licensee Event Reports submitted within the past 2 years, which discuss surveillances not' performed in.

accordance with the Technical Specifications due to administrative errors are: i

LER Number Subject87-042 Alissed Intermediate Range / Power Range Surveillance87-045 Failure to Sample Diesel Fuel Oil for Kinematic Viscosity

| 86-020 improper Bypass Breaker Surveillance Due to Administrative Errori 89-006 Alissed Fire Detector Surveillance on Six Fire Detectors Due

to Administrative Error

The surveillance procedure review documented in LER 87-042-01, would not have discovered thedeficiency in the surveillance procedure for 3CND-07, because of the plant configuration around thetime of the surveillance review. This review did address the concerns of LER 87-045, and resulted in thesubmittal of LER 85-020. At the time of the review, the surveillance and piping diagrams accuratelyreflected the permanent rekase path in service. This release path was being surveilled. For the other two

- release paths to which interluks were added, one was not in service, and the other was installed as atemporary system under the st tion's Bypass / Jumper program. The temporary system would not havebeen reflected on the associated pping diar:.m. The temporary system was released for operation aspermanent plant equipment in January of 1989, after the surveillance review. The corrective action forLER 89-006 would not have identified this problem since it was directed at correcting deficiencies in theFire Detection and Control system.

In order to reduce the likelihood of a temporary system adsersely impacting the requirements of theTechnical Specification, a review of all Bypass Jumpers currently installed were performed to verify thatnone of the temporary installation would produce such an exposure. No deficiencies were identified.

|g6 orm abo

|1

- - - _ - - - _ _ _ - _ _ -

.e . ;y -,

e

' '' ~ Nr40' Form 366A U.S. NUCLEAR REGJLATORY COMM.SBION . APPROVED OMS NO. 3150-0104(6-89) EXPtRES: &30/92

Estimated buroen per response to comply with thisV'

LICENSEE EVENT REPORT (LER) e"mirn.m'en co'''"on ''re.n estimate 'to ine Rec'd"* m* t a**" 60 0 a '- " o'**

1s regarding ou oro, TEXT CONTINUATION .no R.corts management er nen to-Sach U S. Nuc6 ear jAngulatory Commission WasNngton. DC 20655. and to -tM Paperwcek Raouction Pro 3ect (3150-01046. Office ofManagemen* and Budget. WasNngton DC 20503.

F ACLITY NAME (1.) DOCKET NUMBER (2) t F A N1 AABF A #6i PAGE GI

YEAR

Millstone Nuclear Power StationUnit 3 ~ ~o| 6[ 0| oj o|4 |2 |3 8|9 0|1|8 0|1 0| 4 OF 0|4

1 TEXT 01 more space is recurred. use additional NRC Form 366 A's) (17)

EIIS Codes

System Comnonents

Radiation Monitoring System -IL Radiation Monhor - MON

,

f

|

'!

!

.j

'

t

i

i

-

1

]

|1 -

|l' NHC Form 366 |j. (6-89)l',

- _._ _ . _ _ _ _ _ _ _ m . _ _ _ _ _ _ _ . _ - . _ _ _ _ _ . - _ - - - ._