B17424, Responds to NRC Re Violations Noted in Insp Rept 50-423/98-208.Corrective Actions:Lessons Learned Were Addressed by Operations Manager in Staff Briefing Memo & Reevaluated Approach to Unit Restart

Responds to NRC Re Violations Noted in Insp Rept 50-423/98-208.Corrective Actions:Lessons Learned Were Addressed by Operations Manager in Staff Briefing Memo & Reevaluated Approach to Unit Restart

ML20153B221
Person / Time
Site:	Millstone
Issue date:	09/14/1998
From:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-423-98-208, B17424, NUDOCS 9809230018
Download: ML20153B221 (7)

Text

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

4' Northeast R Pe nny RddRoute 156h W(tuford, CT 062 Nuclear Energy muone Nuclear Power Station Northeast Nuclear Energy Company P.O. Box 128 Waterford, Cr 06385-0128 (860) 447-1791 Fax (860) 444-4277 The Northeast Utilities System SEP I 4 1998 Docket No. 50-423 B17424 l

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station Unit No. 3 Response to Notice of Violation Nuclear Reoulatory Commission Inspection Report 50-423/98-208 By letter dated August 12,1998, ,the Nuclear Regulatory Commission (NRC) transmitted the results of the above referenced inspection. The letter included a Notice of Violation (NOV) citing one instance where Northeast Nuclear Energy Company

- (NNECo) activities were not in compliance with NRC regulations.

NNECo's response to the citation is provided as Attachment 1 of this submittal. ,

Attachment 2 provides a summary of NNECo's commitments made in response to the citation. Should you have any questions regarding the information contained herein, please contact Mr. David A. Smith at (860) 437-5840.

i Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY L

seas Martin L. Bowling, Jr. d

. 9tng< Recovery Officer - Technical Services 9809230018 990914 .

PDR ADOCK 05000423 P g- PDR L

. - U.S. Nuciser Regulatory Commission i B17424\Page 2 1 4

DWD:dd l

l cc: H. J. Miller, Region l Administrator J. W. Andersen, NRC Project Manager, Millstone Unit No. 3

{

A. C. Cerne, Senior Resident inspec+or, Millstorie Unit No. 3 E. V. Imbro, Director, Millstone ICAVP inspections l J. P. Durr, Chief, Office of the Regional Administrator W. D. Lanning, Director, Millstone Inspections i

i J

R, 4

i f

a V

4 4

W

-- a

t 1

1 Docket No. 50-423 B17424 l

i l

6 l

Attachment 1 Millstone Nuclear Power Station, Unit No. 3 Response to Notice of Violation Nuclear Reaulatory Commission inspection Report 50-423/98-208 i

l y :;

1 2 September 1998

. U.S. Nucl::ar R::gulatory Commission B17424\ Attachment 1\Page 2 Response to Notice of Violation Nuclear Regulatory Commission inspection Report 50-423/98-208 Nuclear Reaulatory Commission Citation (50-423/98-208-04)

Restatement of the Violation Technical Specification 6.8.1.a. requires, in part, that written procedures shall be implemented covering the activities referenced in Appendix A of Regulatory Guide 1.33, February 1978, item 2.a., General Plant Operating Procedures, " Cold Shutdown to Hot Standby." Step 4.2.34.g.2 of OP 3201, " Plant Heatup," states, IF any RCS hot or cold leg WR temperature increases to greater than 195*F, DIRECT test personnel to close and lock the applicable RHR outboard drain valve (3RHS*V26).

Contrary to the above, on June 2,1998, the licensee failed to direct test personnel to close and lock RHR outboard drain valve,3RHS*V26, when RCS WR temperature increased to greater than 195"F. Valve 3RHS*V26 was subsequenSy closed when reactor coolant system wide range temperature approached 197'F duririg periormance of SP 3601F.4,"RCS Pressure Isolation Valve Test."

NNECo's Response NNECo agrees with the violation.

Reason for the Violation The cause of the condition is attributed to human error resulting in required actions not being carried out as directed by the cited Operating Procedure (OP). While the decision to delay the closure of the affected valve was made on the basis that the intent of the procedural requirement would continue to'be satisfied, the operating crew failed to process the required temporary change to the procedure to support their decision.

Corrective Actions Taken and Results Achieved The lessons learned from this event were addressed by the Operations Manager in a staff briefing memorandum dated June 13,1998. (AR 98010857-01)

At the time this violation occurred, NNECo had in place ongoing activities directed at improving human performance in the control room. These actions were undertaken as a result of performance deficiencies identified during the initial plant heat-up conducted in preparation for unit restart from the extended outage. The cause of these deficiencies was attributed to skill deficits which had developed during the extended

, 'U.S. Nuclear Rsgulatory Commission l l

B17424\ Attachment 1\Page 3 j 1

l outage. As a consequence, NNECo reevaluated the approach to unit restart and instituted additional measures to ensure an event free startup.

These- measures included; 1) augmentation of the regular shift compliment with additional operations department management personnel to reinforce performance

, standards by facilitating the planning and execution of startup evolutions,2) providing.

( additional startup training to the Operations staff in advance of scheduled startup evolutions and remedial training to address lessons learned from the specific events noted during initial plant heatup, and 3) the assignment of additional management oversight to the control room on an around-the-clock basis throughout the unit restart and power ascension process. The result of these actions was a safe and event free l unit startup and power ascension program. NNECo's Nuclear Oversight organization subsequently concluded in lts report related to the Millstone Unit 3 startup and power ascension, that line performance had improved significantly since the Mode 4 transition and that reduction in round-the-clock oversight coverage of control room activities was justified.

l Corrective Actions to Prevent Future Violations l The Millstone Unit 3 Operations Department currently monitors human performance and procedure compliance related deficiencies through the Performance Annunciator Panel- Reporting System. Within this system, key activities are monitored and appropriate performance criteria are established to define corrective action thresholds.

The annunciator panels are reviewed by management to ensure that adverse  ;

performance trends are appropriately addressed through the corrective action program.  !

Date When Full Compliance Will Be Achieved j

Full compliance has been achieved with respect to the condition described in this citation.

L  ;

i l

l

1 I

Docket No. 50-423 B17424

~

Attachment 2 Millstone Nuclear Power Station, Unit No. 3 Summary of Commitments

. Nuclear Reaulatory Commission Inspection Report 50-423/98-208 September 1998 l

o

- - -. . . _ . - - . . - .=- .- -

.4 ~U S Nuclser Regulatory Commission B17424%ttachment 2\Page 2 List of Regulatory Commitments The following table identifies those actions committed to by NNECo in this document Please notify the Manager Regulatory Compliance at the Millstone Nuclear Power Station of any questions regarding this document or any associated regulatory commitments.

Commitment Commitment Committed Date or No. Outage None l

l~

l

!