A10069, Discusses Review of RI-91-A-0289 Re Various Activities at Millstone Unit 2
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L J $,$$',"5.N $. 7 (203) 665-5000 January 13, 1992 Docket No. 50-336 A10069 Re: Employee Concerns Mr. Charles W. Hehl, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406
Dear Mr. Hehl:
Millstone Nuclear Power Station, Unit No. 2 RI-91-A-0289 We have completed our review of an identified issue concerning activities at Millstone Unit No. 2.
As requested in your transmittal letter of December 9, 1991, our response does not contain any personal privacy, proprietary, or safeguards information.
The material contained in this response may be released to the public and placed in the NRC Public Document Room at your discretion.
The NRC transmittal letter and our response have received con-trolled and limited distribution on a "need-to-know" basis during the prepara-tion of this response.
ISSUE:
" Data for flow transmitter 2-CND-FIT-246, associated with monitoring the effluent from the Condensate Polishing Facility neutralizing waste tank, is missing from the applicable instrument
' loop folder'.
In addition, the instrument is not entered in the PMMS
[ Production Maintenance Management System) computer data base."
REQUEST:
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" GENERAL.:
Please provide your review of the above issue.
If the above information is valid, notify us of the corrective actions you have taken to prevent reoccurrence.
Also, provide us with an assessment of the safety significance of any identified deficiencies, including generic considerations.
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A10069/Page 2 January 13, 1991 i
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" SPECIFIC:
How is the updating of instrument ' loop folders' formally i
controlled, since they appear to be relied upon frequently by technicians during the perfor.mance of both safety-related and non-safety related work?"
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RESPONSE
This assertion is not valid.
The flow transmitter at issue (2-CND-FIT-246) does not exist.
If we assume the assertion refers to Transmitter 2CNDFT246, the assertion is nevertheless invalid as this instrument was identified in the PMMS database on June 29, 1983.
Its ID remains valid at this time and its loop folder is current with the latest update:
November 6, 1991.
The loop folder system was developed in the 1970s to provide a place to collect historical maintenance and calibration information based on equipment
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ID.
Copies of calibration and maintenance information were placed in these loop folders to allow personnel seeking information about the maintenance history on a piece of equipment to readily obtain that information. When the PPWS computer database was conceived and implemented in the 1980s, the com-puter database became the controlled information source, but the loop folder system was maintained as a supplemental historical collection system. The system (consisting of approximately 2000 folders) is administered under Instrumentation and Controls Department Instruction 1.10.
The system provides an uncontrolled source of instrument information that is available to anyone, i
without the necessity of computer system access.
The concept of the loop folder was developed as an effective job aid to exist within the framework of the formal, controlled information systems. There is no safety related information uniquely contained in loop folders.
Such information is contained on controlled drawings and in procedures.
Information contained in loop folders supplements, but does not replace, the necessary reliance on controlled documents and the PMMS database. The PMMS ID sheet in the front of the loop folder contains primarily equipment location, nameplate, and reference informatb for the user. This sheet is printed from data contained in the PMMS ID database and is updated as any new or changed i
information becomes available. Reference to controlled documents (drawings, vendor manuals, procedures, Material &-Equipment Parts List evaluations, etc.)
may be found on these sheets. The user of these referenced documents must use an actual controlled copy or check revision indices for proper revision levels prior to use.
The quality of loop folder information was enhanced in 1990. The folders were purged of unnecessary information and upgraded to four-part folders so that l
each folder, in addition to the PMMS ID Summary Sheet, could contain sections i
on drawings, calibration data, equipment maintenance history and miscellaneous i
documents. Updated loop drawings are replaced as new revisions are issued. A l
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2 Mr. Charles W. Hehl A10069/Page 3 January 13, 1991 i
second phase of this upgrade is planned to develop and include additional vendor manual cross-reference information in the database and loop folder data sheets.
After our review and evaluation of this issue, we find that this issue did not
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present any indication of a compromise to nuclear safety. We were not aware of this concern prior to receipt of your letter. We appreciate the opportuni-ty to respond and explain the basis of our actions.
Please contact my staff i
if there are further questions on a y of these matters.
l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY t
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Executive Vice President cc:
W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 l
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- Chief, Projects Branch No.
4, Division of Reactor Projects E. M. Kelly, Chief, Reactor Project: Section 4A j
J. T. Shedlosky, U.S. Nu; lear Regulatory Commission, Millstone t
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< LNG OF PRUSSIA. PENNSYLVANIA 19406-141s November 13, 1991 Docket Nos: 50-245 50-336 50-423 50-213 Northeast Nuclear Energy Company ATTN: Mr. J. Opeka Executive Vice President Nuclear P.O. Box 270 Hartford. Connecticut 06141-0270
Dear Mr. Opeka:
r On November 8.1991. Northeast Nuclear Energy Company terminated the employment of i
two individuals who worked at the Millstone. Unit 2. facility. As you are aware, these two individuals have filed several complaints with the NRC and the U.S. Department of Labor j
alleging harassment, intimidation and discrimination for engaging in protected activities. In view of the above, the NRC needs to uns*erstand the basis for your termination of employment of these two individuals, and also needs to understand the actions you have taken or planned to ensure that your actions with respect to these two individuals does not have a chilling effect on other employees.
Therefore, you are requested to provide this office, within 30 days of the date of this letter, a response which:
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Provides the basis for the termination of employment of the two former employees and includes a copy of any investigation reports you have regarding the circumstances of these actions; and 2.
Describes the actions taken or planned to assure that the termination of employment of these individuals does not have a chilling effect which discourages other licensee or contractor employees from raising perceived safety concerns.
After reviewing your response the NRC will determine whether action is necessary at this time to ensure compliance with regulatory requirements, e
Please itGeate in your response whether any of the information that you provide should be withheld froin public disclosure based on the provisions of 10 CFR 2.790(ab Please cite the specific prosision of this regulation that is applicable or other basis for nondisclosure.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.
The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
I Sincerely,
, n_.M~_
Thomas T. Martin Regional Administrator I
cc:
W. D. Romberg, Vice President, Nuclear Operations S. E. Scace, Nuclear Station Director J. S. Keenan, Nuclear Unit Director R. M. Kacich, Manager, Nuclear Licensing D. O. Nordquist, Director of Quality Services Gerald Gar 6 eld, Esquire Nicholas Reynolds. Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut l
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