B15238, Provides Info Committed to in to NRC Re Readiness Assessment Team Insp,Including Major Activities Yet to Be Completed,Startup Criteria & Startup Assessment Team Final Rept

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Provides Info Committed to in to NRC Re Readiness Assessment Team Insp,Including Major Activities Yet to Be Completed,Startup Criteria & Startup Assessment Team Final Rept
ML20084C228
Person / Time
Site: Millstone Dominion icon.png
Issue date: 05/25/1995
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20084C232 List:
References
B15238, NUDOCS 9505310459
Download: ML20084C228 (13)
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Text

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May 25, 1995 j Docket No. 50-336 B15238 I l

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U.S. Nuclear Regulatory Commission  !

Attention: Document Control Desk '

Washington, DC 20555

+ l Millstone Nuclear Power Station, Unit No. 2 -

Ranuant for Readiness Ammaamment Team Inanection i In our letter to the NRC dated April 4, 1995, m Northeast Nuclear fj Energy Company (NNECO) committed to provide the NRC with the m following:

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. Date by which NNECO will be ready for the Millstone Unit ,

No. 2 Readiness Assessment Team Inspection (RATI), {

  • Detailed information regarding the startup criteria used by NNECO management to assure that corrective actions j have resulted in sufficient improvement to justify restart of Millstone Unit No. 2, and .

. Our disposition of recommendations resulting from the ,

Startup Assessment Team (SAT) , which I commissioned on i January 12, 1995.# ,

The purpose of this letter is to provide this information.

NNECO requests that the NRC's RATI begin on Tuesday, May 30, 1995.

To assist the RATI in reviewing the-status of work remaining to be i f

(1) J. F. Opeka letter to U.S. Nuclear Regulatory Commission, i

" Millstone Unit No. 2 Startup Plan," dated April 4, 1995. I (2) J. F. Opeka letter to U.S. Nuclear Regulatory Commission,

" Formation of Startup Assessment Team," dated January 12, 1995. 3 AD 36 k P PDR 9 Ii

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U.S. Nuclear Regulatory Commission B15238/Page 2 May 25, 1995 accomplished, Attachment 1 provides a list of the major activities j that have yet to be completed.

Attachment 2 lists the startup criteria established by NNECO to determine the readiness of Millstone Unit No. 2 for restart. Those criteria provide evidence of (1) the improved material condition of the plant's systems, structures, and components; (2) the ,

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improvement in procedural adherence; and (3) the management controls in place to proactively identify and correct existing and future deficiencies. In support of Millstone Unit No. 2 startup, we have developed and are tracking specific key performance indicators related to issue significance, discovery method, and equipment deficiencies. These indicators support the evaluation of various startup criteria and will help us monitor performance in the future. Trend graphs of these indicators are included in Attachment 2. When evaluated in the aggregate, the criteria listed in Attachment 2 affirm our readiness to restart Millstone Unit No. 2. Although not tied to startup, two additional performance ,

indicators have been established to help us assess the  !

effectiveness of our corrective actions (repeat findings) and our efforts at improving housekeeping and materiel condition.

Attachment 3 provides the SAT's final report. The SAT has identified a number of issues that it believes should be corrected ,

prior to startup. With these exceptions, the SAT has identified no  !

issue which would I.revent the plant from proceeding with startup (Mode 4). The SAT's final report was presented to the Nuclear Safety Assessment Board (NSAB) during a meeting on May 19, 1995.

The NSAB concurred with the SAT's conclusion and considers that Millstone Unit No. 2 can be safely restarted and operated. The  :

NSAB conclusion is dependent upon completing the activities in the Millstone Unit No. 2 Startup Plan, satisfying the prerequisites in the SAT's final report, and resolving additional items discussed during the NSAB meeting.

I I have authorized entry into Modes 4 and 3 contingent upon the completion of the SAT recommendations, NSAB recommendations, and certain other items identified by the Senior Vice President -

Millstone Station including such items as: Operations being "in charge," acceptable resolution of SPDS issues, identifying the reason for an increase in tagging errors, and resolution of issues dealing with configuration control, corrective action effectiveness, and preventive maintenance as surveillances. This authorization was based on my review of the SAT final report, my attendance at portions of both the NSAB special meeting and a System Readiness Review Meeting, and my assessment of the progress made in improving Millstone Unit No. 2 performance.

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U.S. Nuclear Regulatory Commission B15238/Page 3 May 25, 1995 We look forward to the opportunity to demonstrate to the RATI our l

readiness to proceed with the safe startup of Millstone Unit No. 2.

Should you have any questions regarding the information provided, please call Mr. Michael J. Wilson of my staff at (203) 440-2081, or me.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY 01tb~

J. F. Ope}ch 4/

Executive Vice President cc: T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 R. W. Cooper, II, Director, Division of Reactor Projects, Region I J. P. Durr, Chief, Projects Branch 4, Region I l J. B. Jacobson, Team Leader, Special Inspection Branch, NRR 1

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Docket No. 50-336 B15238 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Major Activities That Have Yet to be Completed May 1995

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U.S. Nuclear Regulatory Commission B15238/ Attachment 1/Page 1 May 25, 1995 MAJOR ACTIVITIES THAT RAVE YET TO BE COMPLETED Rmarcancy Onaratina Procedura (EOP) Revisions EOP revisions to resolve safety significant deviations from  !

CEN-152 Revision 3 and the current writers guide (Mode 4)  ;

i EOP Training l Training on the revised EOPs (Mode 4)

Verification of Operator Performance Laval (

l The Operations Manager and Unit Director. determination of the  ;

adequacy of operator performance (Mode 4) ,

Onerator Burden Reduction Work to reduce the present number of operator burdens. As an i indication of our progress in this area, we expect to start up  :

with 10 or fewer control panel deficiency and bypass jumper i operator burdens.  ;

Technical specification surveillance Tracking Work to resolve deficiencies resulting from the review of i surveillance procedures and tracking methods (Mode 4) l Plant Danign chanaa Request (PDCR) Clomeout and Turnover to Operations l Closeout, turnover, and release for operations of the '

l remaining PDCRs.

t Completion of Startun Punchlist Details l Plant Operations Review Committee review of punchlist items prior to mode changes System Readiness Review Followup l system Readiness Reviews review and approval (Mode 4)

Material Equipment Parts List Evaluation of items reclassified during the MEPL project (Mode 4)

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U.S. Nuclear Regulatory Commission B15238/ Attachment 1/Page 2 May 25, 1995 l

Enaineered Safety Actuation System (ESAS) Design and Performance Review Implementation of ESAS modifications (Mode 4)

Station Batterv Replacement Replacement of the Station Battery (Mode 4) l

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i Docket No. 50-336 B15238 9

Attachment 2 Millstone Nuclear Power Station, Unit No. 2 Startup criteria l

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1 May 1995

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,'.}. ' $ l U.S. Nuclear Regulatory Commission B15238/ Attachment 2/Page 1 May 25,.1995 Attachment 2 Millstone Unit No. 2 4 startup criteria

.i I. Adverse Condition Report'(ACR)' Significance The ACR significance reported in the Accomplishments and Issues . report shows most adverse conditions are of low significance. (The enclosed trend shows a recent increase in the number of significance level C issues. This is due in part to the identification of past problems and is not representative of recent performance.)

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II. ACR Discovery Method l The discovery method distribution shows that most errors are self-identified and do not result in events. (The relatively large percentage of third party identification the week of  :

, May 20 is due, in part to the lower number of total ACRs, and the review of Unit 2 susceptability to Millstone Unit No. 3 issues.)

III. Material condition .

Corrective maintenance, Trouble Report, and Automated Work  !

Order (AWO) backlogs are acceptable. The overall impact on operations will be evaluated by assessing the quantity and significance of the backlog.

IV. Major Items Aging The top ten list is in place and posted.

V. Operator Burdens -

The quantity of operator burdens has been significantly reduced. The significance of the remaining burdens is acceptable. The management review process is in place. (Our expectations are to start up with 10 or fewer of the  ;

currently identified control panel' deficiency and bypass jumper operator burdens.)

VI. Personnel Error Rate The number and significance of personnel errors is low.

Significant events do not routinely occur.

tr : .g U.S. Nuclear Regulatory Commission B15238/ Attachment 2/Page 2 May_25, 1995 i i

VII. Surveillance Program Process review of surveillance databases complete and any related changes completed.

VIII. Startup Assessment Team All Mode 4 issues are dispositioned.

IX. Operator Performance  ;

The Operations Manager and the Unit Director chserve day-to-  ;

day in-plant performance and simulator performance of l operators and determine it to be adequate. -

X. Emergency. Operating Procedures (EOPs)

EOPs are' revised and necessary Verification and Validation i activities are complete. Operator performance on the ,

simulator is satisfactory. l XI. Work Order Quality  ;

Quality and Assessment Services and Work Observation input indicate that AWO quality is adequate.  ;

XII. Equipment Performance Readiness reviews for designated systems are complete and accepted by the Plant Operations Review Committee. Major deficiencies are resolved.  ;

XIII. Improving Station Performance (ISP)

The designated " Improving Station Performance" ISP activities for Millstone Unit No. 2 startup have been verified complete. L i

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Millstone Point Unit 2 - Key Performance Indicators ACR Significance ACR Significance Distributl0n . A, B, & C Lvels 32.0 %

D C 00 0%co 00% A E# O sp g g 0%

Distribution

$ 200%

b 16 0 %

e 26.6%

g 00%

04%

00% 00% e3%

g 12 0 %

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12 0 %

40% 00% 00%

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I00% 00%

Week Ending Todse 22,Apr 29 Apr 6-M ay 13-M ay 20-M ay 27 M ay 3 An Every ACR is assigned a significance level, ranging from A (the highest significance level) to D (the issue is not significant). High significance level events should rarely occur.

Level A - High Consequences, Iligh Complexity.

Level B - liigh Consequences, Low Complexity.

Level C - Low Consequences, Iligh Complexity.

Level D - Low Consequences, Low Complexity.

This KPI shows the weekly and cumulative distribution of significance levels for ACRs assigned to Unit 2. The graph does unlinclude ACRs documenting . cite-wide issues. The ,

graph shows the percentage of ACRs that were significance level A, B and C. l l

T0date T0date 4/22 4/22 4/29 4/29 5/6 5/S 8

- .s13 5/13 5/20 5/20

  1. OfACRs Percent #OfACRs Percent #OfACRs Percent #OfACRs Percent #OfACRs Percent #OfACRs Percent Sgn. A 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0 Sign. B 1 04 0 0.0 0 0.0 0 00 0 0.0 0 0.0 Sgn, C 31 12.1 3 12,0 1 34 0 0.0 9 26.5 5 26.3 Sign. D 225 87.6 22 88.0 28 96.6 23 100.0 25 73.5 14 731 Cum Total 256 100 25 100 29 100 34 100 34 100 19 100 i

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Millstone Point Unit 2 - Key Performance Indicators I ACR Discovery Method Distribution l

ACR Discovery Method Distributl0n  !

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s 38% 42% 59% s4 ,. i<

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g3 15 8 %

90 0 % ..

92% 20 h 11 8 % $i

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80 0% " 0" '

SN 2o 63 %

TN N 70 0 % 63% .* Sit e M O% D 3%

6% Distribution "I 60 0% " - - - - ' - ^ ~ - '~~

03%

50 0 %

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op 40 0%

692% M 8% 676 %

30 0 % 600% 26%

46 m i 20 0%

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Discovery methods are categorized as follows:

  1. 1 Self Identified - workers and performers themselves find it through the self-checking, attention to detail, and good work practices.
  1. 2 Line Identified - The reviews, observations, and other activities performed by the management team finds it.
  1. 3 Independent Entities identified - Third party organizations, including QAS, NRC, INPO, combined utility audits, insurance inspectors and OSHA etc find it.
  1. 4 Condition / Event Identified - The conditions that are self-revealing, with or without consequences (for example, equipment problems found because of alarms, failed retests, mispositioned valves) find it.

This KPI shows the weekly and cumulative distribution of ACR discovery methods for ACRs assigned to Unit 2. The graph does not include ACRs documenting site-wide issues.

Todate Todate 4/22 4/22 4/29 4/29 506 5/06 5/13 5/13 5/20 5/20

  1. ofACRs Percent #OfACRs Percent #OfACRs Percent #ofACRs Permnt #ofACRs Percent #ofACRs Percent
  1. 1 Sen ident 150 60 0 18 69.2 14 46 7 17 70 8 23 67.6 10 52.6
  1. 2 Line ident 35 14 0 2 7.7 4 13.3 4 16.7 5 14.7 1 5.3
  1. 3 lndep. ident 37 14 8 5 19 2 4 13.3 2 8.3 4 11 8 5 26.3
  1. 4 Condiident 28 11.2 1 3.8 8 26.7 1 42 2 59 3 15.8 Total 250 100.0 26 100 0 30 100 0 24 100 0 34 100.0 19 100 0

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Millstone Point Unit 2 - Key Performance Indicators Major Issues Aging  !

I MP 2 Top Ten losues. Aging Trends 10

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The major items aging indicator shows how quickly unit personnd correct significant equipment deficiencies. The item's age is counted from the date the issue is added to the Major Items List. The Major Items list is published in the Daily Status Report. ,

The graph illustrates: 1) the number ofissues on the major items list 2) the average age, i in weeks 3) age of the oldest issue, in weeks 4) age of the newest issue, in weeks. ,

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1 Docket No. 50-336 B15238 1 4

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i Attachment 3 Millstone Nuclear Power Station, Unit No. 2 a

Startup Assessment Team Final Report a

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1 May 1995 l

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