IR 05000213/1985099
| ML20134D508 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, 05000000 |
| Issue date: | 08/13/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20134D494 | List: |
| References | |
| 50-213-85-19, NUDOCS 8508190256 | |
| Download: ML20134D508 (46) | |
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EllCLOSURE 2
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I INSPECTION REPORT 50-213/85-99 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT (582 MWe, WESTINGHOUSE DESIGN PRESSURIZED WATER REACTOR)
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ASSESSMENT PERIOD: SEPTEMBER 1, 1983 - FEBRUARY 28, 1985 BOARD MEETING DATE: APRIL 23, 1985 i l I l l eggeqgggggggggga G PDR -
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SUMMARY (9/1/83 - 2/28/85) HADOAM NECK PLANT
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HOURS % OF TIME Plant Operations ........................... 739 25 Radiological Controls ...................... 373 13 Maintenance ................................ 237 8 1 Surveillance ............................... 327 11 Fi re Protection / Housekeeping . . . . . . . . . . . . . . . 123 4 Emergency Preparedness ..................... 338 12 Security and Safeguards .................... 156 5 Refueling & Outage Management .............. 215 7 Design Change Control /Quali.ty Assurance .... 310 11 Licensing Activities ....................... 109* 4 Total 2927 100
*0perating Reactors Licensing Activities performed by Region I personne NRR personnel time is not include Note: Allocations of Inspection Hours vs. Functional Areas are approximations
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TABLE 2 VIOLATION SUMMARY (9/1/83 - 2/28/85) HADDAM NECK NUCLEAR POWER PLANT Number and Severity Level of Violations and Deviations Severity Level SeverityNevelI 0 Severity Level II 1 Severity Level III 2 Severity Level IV 7 Severity Level V 4 Deviations 1 ' TOTAL 15 II. Violations and Deviations vs. Functional Area Severity Levels FUNCTIONAL AREAS I II III IV V DEV Plant Operations
' Radiological Controls 1 2 1 1 Maintenance Surveillance 1 Fire Protection & Housekeeping 2 Emergency Preparedness 1 Security Safeguards Refueling & Outage Management Design Change Control / Quality Assurance 1 1 2 2 Licensing Activities .
Subtotals 0 1 2 7 4 1 ! Total -------15--------
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III. Summary '
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Inspection Inspection Severity Functional Report N Date Level Area Violation
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83-22 9/26-30/83 IV E Failure to perform Tech Spec surveillance 83-24 L 10/3-7/83 V I Inadequate audit of Plant In-
formation Report system 83-25 10/24-28/83 III I Post-accident sample system inoperable 83-26 11/14-18/83 V B Failure to follow a transuranic analysis procedure 83-28 12/5-8/83 IV F Failure to provide required training 84-03 2/1-3/30/84 V D Failure to control gauge calibration 84-11 6/26-29/84 IV B Failure to follow receipt in-spection procedures IV B Failure to conduct a quality control program DEV B Rad Waste handler requalification program not properly implemented 84-14 8/29-10/31/84 IV E Failure to seal a fire penetra-tion barrier V I Inadequate field change review procedures 84-22 8/25-28/84 IV I Design basis for Emergency Diesel
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Generatorss not correctly trans-lated into procedures 84-23 8/21-9/4/84 II* I Failure of safety committees to identify an unreviewed safety question II* I Inadequate design of the refuel-
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*0ne aggregate Severity Level II violation was assigned for these twat violation .
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Inspection Inspection Severity Functional Report N Date Level Area Violation - 84-24 10/22-23/84 III** B Inadequate health physics tech-nician qualification III** B Failure to provide training in radiation protection procedures III** B Failure to provide positive con-trol over high radiation area work.
84-26 11/13-16/84 IV I Failure to maintain quality con-trol of a safety-related com-ponent 85-03 2/12-15/85 *** D Inoperable Reactor Protective System (RPS) loss of flow channels
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0 Inadequate RPS surveillance procedure
- 0ne aggregate Severity Level III violation was assigned for these three violations.
- Enforcement action not yet issued
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TABLE 3 INSPECTION REPORT ACTIVITIES (9/1/83 - 2/18/85) HADDAM NECK NUCLEAR POWER PLANT Inspection Inspection Areas Report N Hours Inspected 83-20 54 Routine resident 83-21 71 Routine resident 83-22 48 Fire Protection 83-23 42 Radiological Controls 83-24 24 Quality Assurance 83-25 144 TMI Action Plan Implementation 83-26 64 Radiological Controls 83-2 Routine resident 83-28 60 Emergency Preparedness 84-01 29 Security and Safeguards 84-02 96 Routine resident 84-03 167 Routine resident .
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84-04 28 Non-radiological Chemistry Program 84-05 102 Followup on IE Bulletins 84-06 50 Emergency Preparedness 84-07 135 Routine resident 84-08 22 Design Change Control 84-09 70 Quality Assurance / Training 84-10 , 228 Emergen~cy Preparedness . 84-11 37 Radwaste Transportation 84-12 86 Routine resident
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Inspection Inspection Areas Report N Hours Inspected 84-13 29 Containment Leak Rate Testing ' ' 84-14 352 Routine resident
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84-15 (cancelled) 84-16 24 Radiological Controls 84-17 20 Operator Licensing Examinations
- 84-18 24 Loss of AC Event
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84-26 106 Followup on NRC Generic Letter 83-28 t
- 84-27 (cancelled)
i ' 84-28 101 Routine resident 84-29 32 Security and Safeguards
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84-30 24 Radiological Controls 84-31 28 Requalification Training 84-32 60 Routine resident
- 85-01 100 Routine resident
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- 85-02 30 Startup Testing
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85-03 9 Inoperable Loss Of Flow Trip
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TABLE 4 TABULAR LISTING OF LERs BY FUNCTIONAL AREA HADDAM NECK PLANT AREA NUMBER /CAUSE CODE TOTAL A. , Plant Operations 1/A, 2/B, 1/D, S/E, 2/X 11 Radiological Centrols 1/A 1 Maintenance 2/A, 1/D 3 Surveillance 3/A, 6/E, 5/X 14 Fire Protection / Housekeeping 6/A, 1/B, 1/D, 1/X 9 Emergency Preparedness NONE Security and Safeguards NONE Refueling and Outage Management 1/B 1 Design Change Control / Quality 1/B 1 Assurance - - Licensing Activities 2/X 2 TOTAL 42 , Cause Codes
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A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D - Defective Procedures E - Component Failure X - Other
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TABLE 5 LER SYNOPSIS (9/1/83 - 2/28/85) HADDAM NECK NUCLEAR POWER PLANT LER 'N Type Summary Description 83-15-3L 30 day Pressurizer level instrument failure
83-16-3L 30 day Failed charging pump bearing thermocouple 83-17-1P Prompt Post accident sample system inoperable 83-18-3L 30 day Charging pump out of service due to seal leakage 83-19-3L 30 day Low pressure safety injection pump start timer slow 83-20-3L 30 day Loss of. containment control air 83-21-3L 30 day Loss of containment control air 83-22-3L 30 day Failed volume control tank outlet valve control circuit 83-23-3L 30 day Diesel generator 28 assumed load greater than the governor setting 83-24-3L 30 day Inadequate service water to the Containment Air Recircu-lation (CAR) fans 83-25-3L 30 day Failure of the control rod motion slave cycler 84-001-00 30 day Fire doors inoperable 84-002-00 30 day Screenwell fire detection system inoperable 84-003-00 30 day Inoperable fire door 84-004-00 30 day Inoperable fire barrier 1 84-005-00 30 day Potential non-conservative 3-loop operating condition { i 84-006-00 30 day Inoperable fire door
84-007-00 30 day Degraded cable penetration fire barriers 84-008-00 30 day Inoperable fire door 84-009-00 30 day Total loss of offsite power / reactor trip
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i LER N Tyge Summary Description 84-010-00 30 day Reactor coolant system overpressure protection system inoperable 84-011-00 30 day Containment integrated leak rate test failu/re
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84-012-00 30 day . Containment local leak rate test failure 84-013-00 30 day Reactor cavity seal failure 84-014-00 30 day Loss of offsite power; diesel generator failed to pickup '
' load 84-015-00 30 day Steam generator tube degradation 84-016-00 30 day Slow containment isolation valve 84-017-00 30 day Degraded reactor protection system wiring 84-018-00 30 day Inoperable fire door 84-019-00 30 day Containment isolation valves improperly opened 84-020-00 30 day Potential personnel overexposure during maintenance 84-021-00 30 day Spurious high startup rate trip during physics testing 84-022-00 30 day Inoperable fire barrier penetration seal 84-023-00 30 day Failures of Westinghouse circuit breaker relays 84-024-00 30 day False steam flow indication in reactor protection syste day Reactor trip due to inadvertent trip of Reactor Coolant Pump #3 84-026-00 30 day Manual reactor trip due to voltage regulator malfunction
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84-027-00 30 day Reactor protection system overpower setpoint drift
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84-028-00 30 day Out of specification main steam safety valve settings ;
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84-029-00 30 day Spurious load runback due to nuclear instrument setpoint drift l , 85-001-00 30 day Containment isolation valve failed to open (MS-TV-1212) 85-002-00 30 day Reduced Containment Air Recirculation fan flow ,
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TABLE 6 UNPLANNED AUTOMATIC SCRAMS Date Power level Cause 8/1/84 0% Loss of offsite AC power during plant shutdown due to operator / procedure erro /3/84 0% High startup rate trip due to technician erro /20/84 100% Loss of flow due to inadvertent shutdown of number three reactor coolant pum FORPED OUTAGES / POWER REDUCTIONS Date Power Level Cause 3/13/84 100% to 5% Suspected control rod malfunctio /09/84 25% to 0% Main turbine generator problem /15/84 25% to 0% Manual trip due to main generator vo'1tage regulator cycling.
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EllCLOSURE 3 U.S. NUCLEAR REGULATORY COMMISSION REGION I' SYSTEMATIC ASSESSMENT OF LICC. EE PERFORMANCE INSPECTION REPORT 50-245/85-99 NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR STATION UNIT 1 (660 MWe BOILING WATER REACTOR - GENERAL ELECTRIC DESIGN
, ASSESSMENT PERIOD: SEPTEMBER 1, 1983 - FEBRUARY 28, 1985 BOARD MEETING DATE, MAY 6, 1985 -
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TABLE OF CONTENTS
. Page INTRODUCTION ......................................................... 1 - Purpose and Overview ......................... 1 SALP Board Members ........................... .................. 1 Background .................................... ................. ................. 1 ,
I CRITERIA AND RATINGS.................................................. 3 III. SUMMARY OF RESULTS ................................................... 4
- Ove ra l l Fac i l i ty Eva l ua t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Overall Evaluation of Training................................. 4 Fa c i l i ty P e rfo rma n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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I P ER FO RMANC E ANA LYS I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6. . . . . . . . . . , Plant Operations .................................. 6
- Radiological Controls ............................. ............. 10 Maintenance ........................................ ........... 13 4 - Surveillance ........................................ ..........
Fire Protection / Housekeeping ....................
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, Emergency Preparedness ......................................... ...... 21 Security and Safeguards ....................................... ........ 23 H .- Refueling and Outage Management ................................ 25 Licensing Activities ........................................... 27 V.
., t SUPPORTING DATA AND SUMMARIES ....................................... 30 l- Investiga tions and Allegation s , Review . . . ... . . . . . . . . . . . . . . . . . . . . . 30 B.
l Escalated Enforcement Management Conferences Actions ...................... . ...........
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........... 30 i Licensee Event Reports ......................................... 30 *
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TABLES , , TABLE 1 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA . . . . . . . . . . . . . . . 33 ...... TABLE 2 - INSPECTION HOURS SUMMARY ....................................... 34 !
- TABLE 3 - VIOLATION SUMMARY .............................................. 35 TABLE 4 - AUTOMATIC SCRAMS AND FORCED OUTAGES . . . . . . . . . . . . . . . . . . . 37 .........
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- TABLE 5 - INSPECTION REPORT SUMMARY ...................................... 38 l
TAB LE 6 - LER SYNO P S I S . . . . . . . . . . . . . . . . . . . .,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
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- ' . , . . . INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect information pe,rfodically and evaluate licen-see performanc SALP supplements the normal regulatory processes used to ensure compliance to NRC regulations. It is intended to be suffi-ciently diagnostic to support allocation of NRC resources and to be meaningful to licensee efforts to improve plant safet An NRC SALP Board met on May 6, 1985 to assess licensee performance in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Lic-ensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report assesses licensee performance at Millstone Unit 1, a General Electric designed Boiling Water Reactor, for the 18-month period from September 1, 1983 through February 28, 198 SALP Board Members R. Starostecki, Director, Division Reactor Projects (DRP), SALP Board Chairman W. Kane, Deputy Director, DRP 'R. Bellamy, Chief,* Emerge'ncy Preparedness and Radiological Protection Branch, Division of Radiation Safety and Safeguards (DRSS)
J. Durr, Chief, Engineering Programs Branch, Director, Division of Reactor Safety (DRS) E. Wenzinger, Chief, Project Branch 3, DRP E. McCabe, Chief, Projects Section 3B, DRP L. Rubenstein, Assistant Director, Core and Plant Systems, Division of Systems Integration, Office of Nuclear Reactor Regulation (NRR) J. Shea, Licensing Project Manager, ORB 5, NRR J. Shedlosky, Senior Resident Inspector
'Other Attendees D. Lipinski, Resident Inspector D. Osborne, Licensing Project Manager, NRR R. Summers, Project Engineer, Projects Section 38 Background Licensee Activities i
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This General Electric designed Boiling Water Reactor operated at full power from the beginning of the assessment period through the end of cycle 9 with one exception. That was a two-day forced outage
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for replacement of a failed recirculation pump seal assembly. A scheduled 28, 1984. refueling outage was conducted from April 14 through June , The major effort during that outage was the non-destruc- ! tive evaluation of Class 1 and 2 stainless steel piping systems to 1 detect and repair intergranular stress corrosion cracking (IGSCC). ; From the return to power through the end of the assessment period, the unit operated at full power except for a two-day forced outage to correct valve packing leakage in the containmen ,
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There have been no automatic or manual reactor trips during the as-
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sessment period. The last unanticipated reactor trip occurred dur-ing August 198 The reactor availability and capacity factors for 1983 were 95.6 percent and 93.5 percent, respectively, and 78.8 and 75.2 percent in 1984. However, excluding the April 14 through June 28 refueling outage, these factors were 99.4 and 96.7 percent, re-spectively, for the eighteen-month assessment period. (These fac-tors were computed by the resident inspectors using data from the licensee's monthly operation reports.) Inspection Activities One NRC resident inspector was assigned to Millstone Units 1 and 2 for the entire appraisal period. A second resident inspector was on site for eight months of the eighteen-month perio Total NRC inspe~ction hours (both resident and region-based) expended for Unit L were*2110. This correlates to 1407 inspection hours per , yea .,
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NRC Emergency Preparedness Inspection Teams observed full scale emergency exercises on October 5,1983 and October 12, 198 , There were no inve'stigations during the assessment perio Tabulations of' Violations and Inspection Activities are provided at the end of,the SALP repor '
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i CRITERIA AND RATINGS i I ! ' Licensee performance is assessed in prescribed functional areas significant i to nuclear safety and the environment. One or more of the following criteria
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are used to assess each functional area.
j Management involvement in assuring quality Approach to resolution of technical issues from a safety standpoint
- Responsiveness to NRC initiatives {
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, Enforcement history
- Reporting and analysis of reportable events Staffing (including management)
! Training effectiveness and qualification :
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These criteria are not limiting; others are used where appropriate.
' The SALP Board classifies each functional area as being in one of three per-formance categories. These categories are: . . ! Category Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; - licensee resources are ample and effectively used so that a high level of performance with respect to safety is being achieve Category NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuc- ' lear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to safety is being achieve Category Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to . safety is being achieve . l The SALP Board also categorized the performance trend by comparing the overall performance during the last fourth of the SALP period to the overall perfor-
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mance during the entire SALP period. This trend was evaluated as " Improving," or as " Consistent" (essentially unchanged), or as " Declining." '
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p III. SUMMARY OF RESULTS ' Overall Facility Evaluation
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Overall, licensee performance was good during this SALP period. Perfor-mance of the plant operators was notably professional in regard to taking prompt action to prevent plant conditions from developing into unplanned
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shutdowns. Operations and operations support have performed well and have interacted effectively, and the unit is currently in its longest operating run (275 days as of May 6,(1985). There were no automatic reactor trips during the SALP period, and analysis of licensee event
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reports showed a low rate of personnel errors. The onsite safety review
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committtee was evaluated as thorough and effective overall. QA auditing
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received by facility management. Instances of deficient licensee self-appraisal were, however, eviden i The radiation protection and housekeeping programs were effectively' ap-plied to reduce contamination and improve area access. Millstone 1 is an exceptionally clean Boiling Water Reactor. Also, radiation protection measures were carefully planned and implemented for significant 'in-ser-
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vice-inspection work in the primary containment drywell. But there were
* multiple lapses in worker adherence to routine radiation protection * procedures and repetitive problems with low level radwaste shipments to *
South Carolina. These lapses indicate a need to upgrade first level
* supervision of such activities as well as to improve worker compliance with routine radiation protection control '
Design control was noted to be deficient, with improper installation of the Post-Accident Sampling System (PASS) the noteworthy exampl Cor-rective measuresion this item are in progress as a result of identifica-tion of design control problems at the licensue's Haddam Neck plan ,
* * In some cases, the licensee has not provided timely responses to the NR *
One such case involved shelf-life control for, perishablec and environ-
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mental controls for welding electodes. Another involved untimely re-
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sponses in the Licensing area. Untimeliness was not noted, however,
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in the more significant issue *
* In summary, licensee performa'nc'e' has been strong in plant operations and control of major activitie There has, however, been a significant * lapse in design control and lap;es in radiation protection. Responses *
to the NRC need to be more timel There is a need for more effective licensee self-appraisa Overall Evaluation of Training
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* As shown by the operational performance of the plant, the training pro-
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gram has been effective overall. Licenses training initiatives have been noteworthy, including an upgrading through training staff expansion in size and authority. A training department screening process has been
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. *- . implemented to correct a problem with operator performance on initial NRC licensing examinations. An onsite plant specific simulator project *- .is in process. Requalification training has been satisfactory and is *- * expected to improve when the simulator is placed in operation. Training * of non-operators was good, with Instrument and Controls department training noted to be particularly effectiv Facility Performance Category Category Recent Functional Area -
Last Period This Period Trend (9/1/82- (9/1/83-8/31/83) 2/28/85)
' Plant Operations 2 1 Consistent Radiological Controls 1 2 Consistent Maintenance 1 1 Consistent Surveillance 2 1 Consistent Fire Protection / Housekeeping 1 1 Improving Emergency Preparedness 2 1 Consistent Security & Safeguards 1
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1 Consistent l Refueling & Outage Mar.sgement 1 2 No Basis Licensing Activities 1 1 Consistent
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. . [ IV. ' PERFORMANCE ANALYSIS Plant Operations (714 hrs., 34%) Analysis ' This area encompasses engineering support, design control, training, and staffing as well as the overall conduct of facility operation During the preceding assessment period, a category 2 rating was as- < signed. Overall performance was judged to have been good, however, several lapses indicated that increased attention to detail was required. The licensee has vigorously addressed the areas indicated .
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in the last SAL . No unplanned scrams during reactor operation have occurred since August 198 There have been notable occurrences when prompt operator action has minimized an operating transient and kept the plant on line. One example was operator action in response to a
' stuck-open moisture separator drain tank normal level valve on
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February 6, 1985. Because the valve is remotely operated with air, recognizing the problem of the valve shaft sticking and then freeing the valve was not a straight-forward evolution. Free-flowing steam through the moisture separator drain tank had resulted in a turbine ! trip in the past. In this recent case, the situation was recognized and proper action taken to remotely free the valve. Such attention
' to detail contributed to the plant being on line uninterrupted for 275 days as of the May 6 SALP Board meeting. This is one indication of high quality performance by the operating staff. (Training ef-factiveness is discussed later 1n this section.)
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Overall, the control room function was assessed as effective.
i * Other than routine security measures, access to the control room was not specifically limite Documents sent to the control room
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* were not specifically pre-screened to avert unnecessary burdening i of the operators.' But, business with the control room was required t * '* to be conducted through one of the two senior licensed operators *
on duty, and specific permission was required to enter the marked .
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areas near the control panels. Pre-briefings for evolutions were assessed as thorough, appropriate, and well presented. The opera-tors' desk was repositioned to provide a better view of the panel Procedures and drawings were found to be readily available and ap-propriately used. Despite a lack of formal status boards, shift
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turnover controls and degraded equipment lists appeared adequate, in that operators were found to be aware of plant conditions.
- Although a high state of training and knowledge is indicated by the
; excellent plant operating record, the results of operator licensing i
' examinations suggest a decline in training program effectivenes Approximately one-half of the candidates for initial operator and { senior operator licenses were unsuccessful in NRC administered ex-
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amination Personnel reassignments and a perceptible decline in the morale of the training department may have contributed to this l
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decline in training effectiveness. However, an effective requali-
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fication training program is administered in a six week classroom
, * series and one week of contracted simulator training. The examina- * tions administered are generally thorough and challenging. Opera- * tors who fail an exam section are evaluated by the training depart- * ment, which reports directly to the corporate management, and may *
be removed from licensed duties. A plant specific simulator is to
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operator training. Training department staffing includes licensed
' * operators and is expanding to meet simulator training needs. These * factors are indicators of a sound and improving operator training progra .
A strong sense of forehandedness was evident during several planned power reductions for corrective maintenance. These ranged from i
' rout 1~ne replacement of Recirculation Motor-Generator brushes to more challenging work such as repairing a pipe break in extraction steam
< piping and rebuilding a Feedwater Regulating Valv Two brief ' shutdowns were conducted to correct; significant failures. During October 1983, one of two redundant seals of the "A" Reactor Recir-culation Pump failed. The licensee began contingency planning in case of a failure of the second seal. Very late on November 25, , 1985, early symptoms of seal failure were observed and a shutdown was commenced. The pump seals were replaced without incident and a startup was commenced early on November 28, 1985. Early on August 2,1984, a rise in measured drywell sump leakage was observed.
- Power was reduced to less than 1% and a variety of problems with small valves were repaired. The unit was returned to power and drywell sump leakage returned to a typically low value. Overall, the success of plant operators and technicians in the diagnosis t and repair of problems is rioteworth ,
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t During the preceding SALP, the percept' ion of a lack of licensee
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sensitivity to issues affecting the reliability of onsite emergency power sources was highlighted. During the current period, modiff- ! cations were made to control the environment of critical Emergency Gas Turbine Generator (EGTG) components. Improvement in the perfor- . mance of the EGTG during surveillance start-ups and full load runs , has been observed. The licensee has also placed increased emphasis on matters involving the Emergency Diesel Generator (EDG). An ex- ' perienced senior engineer holding a current maritime license for , Diesel plants has been assigned responsibility for coordinating EDG matters. A region-based Diesel specialist reviewed EDG performance, i vendor inspection programs and res,ults, and commented favorably on I- EDG reliability. These efforts in the area of emergency power are
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. * * Region-based inspectors reviewed QA audit schedules and plans, * documentation of 11 QA audits, 3 semi-annual QA review reports to * management, the QA monitor schedule, and 6 QA monitor reports. The *
resident inspector observed one monitoring evolution and reviewed
*
the documentation of another. QA audits are done by the corporate ,
*
staff and generally have a broad scope. The audit staff is small '
'* and aggressive, with good communication with senior management and the PORC. QA audit schedules and results are reviewed by the POR * *
The monitor program is conducted by the onsite QA staff. It pro-
* vides site managers with a separate view of the performance of per- *
sonnel and evolutions. Corrective actions on audit and monitor
*
findings generally are implemented promptly. The licensee is re-
* viewing the monitor program to identify ways to enhance its utilit * Overall, the audit and monitor programs are considered to be post-tive contributors to quality and safet * *
Several meetings of the PORC were attended by inspectors at inter-vals during the perio The PORC reviews were critical, thorough, and involved considerable discussion. One violation, the failure of PORC to approve a change in the method of monitoring effluent radioactivity, is ascribed more to error on the part of operating personnel than to a shortcoming of PORC oversight of plant opera-tions. Subsequently, a detailed review of document control revealed that the violation was an isolated event and resulted in the closing
* of previously unresolved or open issues in procedures and drawing control. - '
'
Analysis of Lens indicates a high level of performance. The ratio of personnel related events to facility-related events remains very low at 0.06. This compares favorably with a ratio of 0.12 attained during the previous SALP cycle and 0.18 for a " typical" BWR of NUREG/CR-2378. The ratio of management-related events to facility-related events increased from 0.09 to 0.12 during the cycle. (The
" typical" BWR achieved a management-related to facility-related event ratio of 0.18.) This increase was due to the failure to cor-rect recurring problems with the security system equipment, with Isolation Condenser Containment Isolation Valve 1-IC-3, and the de-sign deficiencies relating to the containment isolation function - *
of the Post-Accident Sample System. LERs, both those submitted under
*
the requirements in effect prior to January 1,1984 and under the
*
new requirements in force since then, were timely and complet * When additional information later developed concerning reported events, updated LERs have been submitte . Conclusion Ratino: Category Recent Trend: Consisten " Asterisked ifnes are common to Units 1 and , *
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9 l Board Pecommendation Licensee: Provide a more vigorous self-appraisal function in order to achieve better internal identification of problem areas such as the high failure rate on initial operator qualificatio NRC: Non ,
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, Radiological Controls (318 hrs., 15%) Analysis
*
* The licenste's performance for this period is degraded from the
*
performance noted in the previous assessment. While no violations
* were noted in the last assessment, five violations were identified *
in the current period. This is particularly noteworthy since the
* radiation protection program was initially subjected to reduced in-spection effort due to previously observed good performanc * * The licensee's radiation protection program continues to be defined *
by generally good polic.ies and procedures. Resident and specialist
* inspector reviews of this area generally indicated consistent good * performance in the area of contamination control, personnel moni-toring, radiological surveillance and job control, instrumentation * *
reliability and effluent control. However, during this period both
* resident and specialist inspectors observed increased deficiencies *
involving procedure establishment, implementation and maintenanc * For example, on two separate occasions, the licensee performed tasks
* that were beyond the work that was authorized and allowed by job *
specific radiation work permits. Though these occurrences were
* identified to the licensee, corrective measures were not effective enough to prevent recurrence a short time late * * Other procedural deficiencies noted this period included the imple- * mentation of a change to the liquid waste discharge procedure without *
administrative and technical review, and failure to adhere to the
*
containment requirements of a special procedure used for fuel re-
*
constitution. Additionally, on one occasion, the licensee failed
*
to implement procedures to prevent recurrence of conditions that
* resulted in materials byan inadvertent sustained intake of airborne radioactive a worke *
For this event, corrective action was not
* initiated until the item was identified by an inspector 30 days 1ate Several other procedural problems noted this period rein- *
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forced the perception that violations are repetitive and indicative ( of a minor programmatic breakdown, particularly in view of the lic- - - * I * ensee's previously observed ability to adequately establish, imple-ment and maintain procedure * i * While reviews by both resident and specialist inspectors generally ! * indicate acceptable performance relative to the transportation of
*
radioactive materials, the State of South Carolina identified ten l
* discrepant shipments received at the burial facility in Barnwell,
*
South Carolina. The latest of these, identified March 11, 1985
- * (outside this current assessment period) caused the State to suspend
! * the Itcensee's State radioactive waste transport permit for one year
*
and assess a $5,000 civil penalty. Previously, the State had as- ! sessed a $3,000 civil penalty for a discrepant shipment received j * in December 1984, and formally notified the Itcensee of a discrepant ' ! .
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sh,ipment received in October 1984. Several other deficiencies be- +
* * tween September 1983 and August 1984 were orally conveyed to the licensee by the State. This indicates that the Itcensee has not .
j * i
* been effectively implementing this portion of the program or ef- !
' facting adequate corrective act.fon. Since multiple and repetitive
* !
violations were identified, programmatic breakdown is eviden ' i *
*
.
Radioactive waste management was not reviewed this period. Effluent
, *
control and radiochemistry review indicated that the licensee was
* effectively implementing that program in accordance with regulatory ; ,
requirement i '
* *
To reduce solid radioactive waste generation, the licensee estab-
- * lished a corporate performance goal for 1984 of ten percent less
*
than the three year 1981 through 1983 average. A sixteen percent
*
reduction was attained. A 1985 goal was set for a ten percent re-
- duction from the 1982 through 1984 averag ,
*
* The licensee has implemented a formal ALARA program designed to
* analyze specific tasks and effect dose reduction methods, as well as monitor task performance relative to performance goals. Records
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, of the effort are generally complete, well maintained and availabl !
1 * Reviews of this area indicate that the program is generally effec-i * tive but does not always achieve established goals. The effective-
* ness of the program has recently been enhanced by a corporate policy ; *
which makes specific ALARA goals. the responsibility of individual t
! manager *
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, * Overall, the licensee's performance during majnr projects involving
- * high levels of radioactivity demonstrated thorough planning and preparation, good procedure development, and the establishment of
acceptable radiological controls. This was evident for the Unit-1 i IHSINeld Overlay, Extraction Steam Line Replacement, and TIP Over-I * haul. Adequate management review and oversight.is usually evident : i j * as demonstrated by sufficient awareness of daily activities, the !
*
establishment of generally effective inter-departmental communica-
- * tions and cooperation, and the effective use of planning meetings j and schedules to reduce personnel exposur ;
*
,
*
An adequate staff is available to carry-out the program, and the l personnel involved are qualified and capable of performing satis- '
*
*
factorily in their assigned areas of responsibility. A formalized
*
training program for the radiation protection staff continued to' 1 l j
*
be implemented and provided sufficient technical and practical in- ; ,
*
structions to assure competenc The Itcensee also implements a :
- *
generally effective radiation worker training program to assure that ' t * radiation workers are aware of radiological safety procedures and l able to implement them competentl .
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: * * Additionally, the licensee has successfully completed corrective * actions on several previously identified findings, and has success-fully resolved open items in a timely manne . Conclusion *
Ratina: Category 2
. *
Recent Trend: Consisten . , Board Recommendations
*
Licensee: Evaluate specific training for first-level supervisors
* * as a measure for improving adherence to requirements. Upgrade- * adherence to routine radiation protection requi,rements by individual worker *
NRC: Non i !
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i Maintenance (347 hrs.,16%)
: Analysis * * Maintenance received the close attention of both resident and re- ; *
gion-based inspectors during the assessment period. During the !
( * previous two SALP periods, ratings of Category I were assigne No areas of general weakness were noted during those periods.
i .* i * In mid-1984, the overall maintenance program received 'a comprehen-
** sive NRC review using a standard NRC' Region I audit plan. Job ! ' * Orders, Maintenance Requests, Machinery History Cards, Plant Inci- * dont Reports, Licensee Event Reports, Monthly Operating Reports, , *
and the Daily Activities Log-were audited. No reportable equipment
. * degradation or failures were disclosed which had not been documented i * as Licensee Event Reports or which were missing from the Monthly .
Operating Reports. Records showed no repetitive maintenance beyond
- *
* routine lubrication, cleaning, and valve packing adjustment for nine
- kcy systems. Machinery History Cards were being maintained manually
*
a for each system to the component level. Machinery History Cards
*
were found to be accurate and timely. The accuracy and. completeness
. ! * of maintenance documentation and the close and consistent involve- * ment of supervisors in day-to-day maintenance were noted as signi-i ficant strength , *
i . Another aspect of the NRC programmatic assessment involved mainten-
*
ance personnel. Interviews with maintenance technicians, supervi- [ '
*
sors, and Quality Assurance inspectors showed that all had a working
* * knowledge of skills necessary to conduct and document maintenance *
evolutions. The involvement of foremen and supervisors in field
* work was found to be consistent and extensive. The maintenance * staff is a mix of experienced personnel present since construction, * other experienced personnel from aircraft and shipbutiding indus- * tries, and newer personnel. A degreed staff engineer is also as- *
signed directly to the maintenance department. The staff and
* supervision of the maintenance department were found to be notable .
strength *
* A second programmatic inspection was conducted during November 1984 *
by region-based inspectors. The inspection was directed toward
* post-maintenance and post-modification testing. The inspectors re- * viewed 35 safety-related work packages from the Maintenance Depart- * ment and 15 packages from the Instrumentation and Controls Department to verify correct classification and appropriate post-maintenance * *
testing. The program was found to include written procedures, cri-
* teria, and responsibilities for post-maintenance testing. The in-
* spection concluded that an acceptable program is in place and is being implemente .
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. * -The licensee implemented a corporate-wide maintenance management system during the present SALP period. Maintenance is still per-l -* formed to departmental procedures. However, the authorization and i *
j
. * control documents have been replaced by a central computerized sys-
- * tem, the Production Maintenance Management System (PMMS). The sys-
*
tem is used to schedule preventive and corrective maintenance. It
* will retain the machinery history type of information which had *
previously been recorded in departmental record Since each
4 * equipment is being identified within the centralized and auto-
* mated system, machinery history will be available throughout the i
i corporation. Preventive maintenance actions may be reviewed based
* * on equipment history and revised or re-scheduled based on perfor-mance data. The system's data base records material and man power i * * usage and is used for resource management. Maintenance, and sur-j veillance may.then be prioritized and schedule ! *
- *
The resident inspectors observed portions of 39 maintenance evolu-
* tions for procedural compliance, safety, work practices, and docu-l mentation. No breakdowns in program implementation were observe *
l * Procedurement practices and storage were examined by a team of re-
- - gion-based inspectors. Two areas of weakness were noted
- shelf-life
*
!
* criteria for perishable items and control of the storage environment i * for low hydrogen stainless steel and nickel welding electrodes.
i
*
Insufftetent management involvement was apparent in both cases.
j Concerns regarding shelf-life co'ntrols previously arose during an ,
*
inspection in mid-1982. A followup inspection late in 1983 found j * only informal controls. Although the Ifcensee fulfilled his com- ! *
*
mitment to establish a more formal program for shelf-life detamin-
*
ation and control, an audit conducted late in 1984 found little ! evidence of program implementation. Specifically, shelf-If fe data ! *
*
had not been requested from vendors and shelf-life had not been {
*
evaluated during QA acceptance inspection. Additionally, the audit !
*
sample included solenoid valves with shelf-life Ilmitations due to l
* certain internal construction materials. Although the valves had
! been the subject of both a vendor service letter and an NRC Sulletin,
**
! * the valve shelf-life had not been included in the licensee's progra * Concerns related to the storage of low-hydrogen welding electrodes
*
arose during an inspection in mid-1983. These electrodes are stored
* in ovens at elevated emperature to limit moisture absorption. Re- *
sponsibility for cal.ibration of the oven temperature monitors had ! a not been established. The inclusion of these monitors in a regular calibration remained outstanding through the end of the inspection
* period. Together, these items reflect a lack of attention to the *
{ details of program implementation.
, The equipment classification program was reviewed during the assess-ment period. The broad scope of the audit involved evaluating
*
samples of safety-related systems, purchace orders, and Plant Design Change Requests (PDCRs) to determine proper component classification
.
- * Asterisked Ifnes are common to Units 1 and 2.
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commensurate with system applicatio The current manual program was judged to be effective. An automated system is planned for in-corporation in the Production Maintenance Management Syste Vendor interfaces were also examined during the assessment perio < . ' The program was found to contain the essential attributes of Regu- ' latory Guides 1.33 and 1.38 and the NUTAC report " Vendor Equipment Technical Information Program."' Interviews with key personnel and document review indicated acceptable program implementation.
, i ' QA involvement in post-maintenance testing was closely audited, It was concluded that the post-maintenance test program at Millstone 1 is aggressively implemented and well supported by plant managemen o The involvement of Quality Assurance in modifications was generally l thorough. An example was their involvement in the Induction Heating Stress Improvement (IHSI) and weld overlay work on the Recirculation System. Review of the calibration of welding equipment, welding l operator training, receipt inspection of thermocouple wire, work l
practices, and documentation packages of a total of 53 QA surveil-lance reports provided the basis for this judgemen . Conclusion
*
Ratina: Categor * Recent Trend: Consistent l 3. Board Recommendation !
*
l l.icensee: Improve shelf-life program and storage program for
*
welding electrode , NRC: Non . l l '
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cAsterisked lines are common to Units 1 and .
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. Surveillance (333 hrs.,165) Analysis Surveillance received the attention of the resident inspectors and region-based specialists. An increase in inspection effort was made in response to, the decline in performance to Category 2 observed
'during the preceding assessment period. The resident inspectors observed a total of 52 surveillance tests. NRC reviews addressed containment leak rate testing, hydrostatic testing, in-service in-
' spection (ISI), core power distribution surveillance, chemistry analyses, and a detailed technical review of radiation monitor calibration procedure *
* A master Surveillance Control Lf st correlates surveillances to lic-*
*
ense requirements and receives PORC oversight. Individual depart-
* mental controls are effectively used to schedule and track comple- *
tion of surveillances. NRC audit of 12 Unit I and 20 Unit 2 tech-
*
nical specifications confirmed timely completion. The plant design
*
change request system requires a positive statement of the need for
. * associated changes to operating procedures, surveillance procedures, *
and technical specifications. The Engineering Department must make that assessment, and PORC must review 1t. NRC audit.of 4 Unit 1
* *
and 7 Unit 2 technical specification amendments verified that sur-
*
veillance procedures were updated when technical specifications were
.
change (A Unit 2 exception to this was found involving failure
* . *
to update ex-core power range nuclear instruments after a 1975 de-sign change.) Site QA monitors surveillance testing. NRC witnessed
* * one QA " monitor" of surveillance on Unit 1 and reviewed 4 surveil- *
1ance " monitor" reports by QA. The reports were found to be critical
*
and to reference INIC guidelines. Such reports are forwarded to the unit superintendent for action and to the corporate QA manager
*
for trendin A detailed review of the Hydrostatic Test Program used at Millstone 1 assessed the conformance of the program and fts implementation - to the requirements of both Technical Specifications and ASME Boiler and Pressure Vessel Code Section XI. Additionally, selected tests were observed and test records were independently analyzed. A11 aspects reviewed either conformed exp1tcitly to code requirements or were reconciled as acceptabl , The containment leak rate test was performed in accordance with the prescribed regulations and guidelines. Test personnel were cogni-zant of the physical meaning of the test result The knowledge of those who performed the test was generally good. However, test control and planning seemed to be insufficent at times. Management involvement and control to assure quality was insufficient to pre-vent confusion over test activities. Excessive external factors interfered with the testing. There was lack of continuity of test personnel, inaccurate preplanning for the test, and inadequate QA CAsterisked lines are common to, Units 1 and . s
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* .
! involvemen The ifcensee considered repair of leaky valves during the test. That would have resulted in a " failed" test. This shows inadequate technical understanding of these activitie *
* Detailed technical review of procedures, practices and, where ap- *
propriate, independent calculation of results of s of Surveillance disclosed no signtficant problems.pectfic aspects The aspects reviewed include Core Power Distribution Monitoring, Chemistry, Radiation Monitor Calibration, and In-Service Inspection. The ap-p11 cation of a computer-afded Ultrasonic Data Recording and Pro-
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cessing System (UDRPS) was a technical inovation which was favorably commented upon by both a metallurgist and a Non-Destructive Evalu-i ation specialist from the regional office. UDRPS was used for ad- ! l ditional evaluation of stainless steel reactor recirculation system piping. This was not required by the NRC or the ASME Boiler and Pressure Vessel Code, but has been used in addition to conventional ultrasonic testing to gather significantly more data during non-destructive examinations. The use of this equipment did result in recording substantially more pipe weld data than was previously j available.
! l i In another effort to learn about potential defects, the Ifcensee l had a weld radiograph taken during plant construction electronically image-enhanced. This was done after a through-wall axial defect opened in the base metal during induction heating stress improvement (INSI) of a recirculation system Jet pump riser weld. The original radiograph did not show any defects, but the image-enhanced version clearly showed a defect in the base meta The Instrument and Control Department has developed several programs which have improved the reliability of plant equipment. Specif1-cally, these aave improved the reliability of safety-related in-
, struments associated with the Reactor Protection System and the Emergency Core Cooling Systems, and have also improved the relt-ability of the Emergency Gas Turbine Generator. By trending the contact resistance of micro-switches within instruments, the Itcen- - see has been able to limit instrument setpoint drift by replacing components at the first sign of degradation. Likewtse, various parameters of the Emergency Gas Turbine Generator are included in trending pro Those programs, along with new system alignment procedures, gram have improved the reliability and operatin of the gas turbine during the SALP assessment period. g performance * Conclusion *
Ratina: Category 1 Recent Trends Consisten .
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18 Board Recommendation
*
Licensee: Upgrade QA of critical surveillance testing such as
*
containment integrated leak rate testin ' NRC: Non . e
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l Fire protection /Housekeepino (42 hrs., 2%) Analysis
* * The licensee has submitted an' Appendix R exemption request and no
*
Appendix R inspection has been conducted yet. Fire protection and l l * housekeeping. received both resident and region-based inspection * These efforts included a detailed programmatic inspection by a fire l * protection specialist. Because of incorporation of fire protection a and housekeeping checks in daily resident inspector tours, the
* actual inspection effort expended on fire protection and housekeep-ing is significantly more than the tabulated tota The facility is generally kept clean and graffitti-free. A high state of cleanliness is readily observed in the reactor butiding, where extensive areas have been made accessible without the use of protective clothing. Three of the four reactor building below grade - corner rooms, the reactor water cleanup system pump room and the
shutdown cooling system pump and heat exchanger rooms have all been cleaned. Access controls remain in several of these areas because ! of high radiation field But all may be entend without protective l clothing. The licensee continues to make steady improvements in ! plant housekeepin Management inspections are conducted both dur- ! ' ing the operating cycle and then more frequently during outage Supervisors for work-in progress are required to accompany the superintendent inspecting an area. There is a very strong emphasis on housekeeping during these inspection * a In contrast with the station interior, large yard a nas are heavily
* cluttend with spare, excess or staged equipment including a large l *
quantity of material and trailers labelled as radioactive. This i t condition has degraded over the appraisal period,
* * Indoctrination in matters pertaining to housekeeping and fire pro-
, '
* tection is provided to new employees, and to all employees on an *
annual basis. Formal lesson plans and multi-media instruction methods are employe Fi n Brigade training consists of actual
- * * fire-fighting at an off-site training center, formal training lec-tures and demonstrations, and fire drills (including back-shift * *
drills). Both specialist and resident inspectors commented favor-ably'on the effectiveness of fire protection trainin The programmatic inspection included dotatted nyiew of licensee e m'asures to control ignition sources, solid and Itquid combustibles, transient combustibles, and general housekeeping. These were deemed to be adequate. The organization for fire protection was found to be adequately staffnd.
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cAsterisked lines are common to Units 1 and 2.
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Ratino: Category 1 Recent Trend: Improvin . Board Recommendation
* I * .fconnee: Address the cluttered yard condition. Resolve Appendix !
ll imp'ementatio * NR,q: R Non .
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. Emeroency Preparedness (169 hrs., 85) Analysis * * * The previous 5 ALP evaluation rated licensee performance in this area *
to be Category 2 based principally upon the corrective actions not . being completed for two significant findings noted during the Emer-
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* gency Preparedness Appraisal conducted on January 4-14, 1982. These
* were(1)installationoftheHighRangeMonitoringandSampling
* Systems for the Unit 1 Stack and the Unit 2 Vent, and (2) estab-
* lishment of an integrated emergency plan training / retraining pro
,
* to ensure that lesson plans are developed and training is accom gram
* plished for each functional area of emergency activity, including
* radiation protection during emergencies, emergency repair / corrective
.
actions, search and rescue, and radwaste operation *
* During this assessment period an inspection was conducted on Febru-ary 21-24, 1984. At that time, it was noted that corrective actions * *
werecompleteonItem(1). The " Emergency Preparedness Training
*
Program * for Item (2) was only prepared in draft form but contained
* a revised training lesson plan format and testing requirement * The training of the emergency response personnel with the new pro- *
gram was scheduled to be completed by June 30, 198 Re-inspection
*
of this area has not yet been completed. However it does not ap-
* pear that the final documentation of. the Emergency, Preparedness *
Training Program received adequate management attention since'the time to correct the ites exceeded two year *
* The licensee conducted a full scale emergency exercise on October * 5, 1983,'and another full scale exercise on October 12, 1984. The licensee s execution and participation in both of the exercises were * *
satisfactory. No major discrepancies were noted and the improvement
*
Items observed in 1983 did not recur during the 1984 exercise. It
* was also noted that the corrective actions described by CAL 94-10 * dated June 5, 1984, that was issued after the May 12, 1984 Haddam * Neck exercise, had been completed prior to the October 12, 1984 .
Millstone exercis *
*
Ouring 1984, a temporary TSC was established within the Millstone
* E0F as a result of a lack of space in the reactor buildings. A new * TSC for the Millstone site is being constructed as a part of Unit 3 and is scheduled to be available for the 1985 emergency exercis * *
The licensee has been responsive to NRC initiatives. Acceptable
* responses were proposed with the exception of the training item noted abov . * . ' #Aste' risked lines are common to Units 1 and ,
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. * * The licensee's onsite emergency preparedness staff consists of one *
full time coordinator. At least two contractor personnel have pro-
*
vided assistance during the past year. Corporate personnel are available as required to support emergency preparedness activitie . ' Conclusion
. * Rating: Category *
Recent Trend: Consistent Board Recommendation
*
Licensee: Evaluate measures for assuring timely completion of
*
action item *
!!R$: Non .
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. Security and Safeauards (63 hrs., 3%)
. Analysis .
*
* During the assessment period, there were.two routine physical pro- !
*
tection inspections by region-based inspectors. Routine resident
*
inspections continued throughout the assessment period. Two Level ; a IV violations were identified by a region-based inspector. One i
*
Level IV violation was identified by a resident inspector. The !
* violations were administrative in nature. Corrective actions were , accomplished immediately. '$fallar violations did not recu I ** ! *
Management attention to the security program has been evident and ;
* has focused on insuring security effectiveness at the operating l * units while maintaining separation between the operating units and * the unit still under construction. The licensee plans to bring all * three units under one multiple unit site security program in Decem-ber 198 Both site and corporate management personnel are directly * t * involved in this project and in planning for the increased security ! *
staffing necessary to support the expanded program. Other activi- !
* ties involved include system and equipment turnovers, integration *
of existing and new systems, and monitoring the installation and ; i
*
completion of barrier construction and related modifications. The !
* smoothness with which these activities are being accomplished is . * indicative of mana ement involvement in the planning, scheduling and coordination o the projec * * The licensee was in the process of modifying and submitting an in-
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tegrated Site Security Plan and a Unit 3 Low Enriched Fuel Protec- l tion Plan to the NAC. These plans were scheduled to be resubmitted L
*
in April 1945. The two plans were reviewed on site by a region-
* * based inspector for overall content and compliance with NRC regula- ! * tions and were found to be generally consistent with the spirit and !
Intent of the regulations. However, a detailed, review of the plans
*
by NRC/NMSS remains to be conducte ! l
! *
* *
A comprehensive corporate security audit program continues to be !
*
a strength of this licensee and demonstrates the licensee's commit- i
*
ment to a quality security program. Audits are conducted on the !
* Security Plan, Safeguards Contingency Plan and Training and Quali- l * fication Plans throughout the year such that the overall audit pro- !
i ! * gram is completed by year's end. The in-depth scope of the audit
*
program, which uses both USNRC Inspection Procedures and licensee i
* requirements has contributed to reducing incidents of non-compli- *
anceespeciallyduringthelaterportionofthisassessmentperiod.
, i' * This performance improvement is Iarticularly significant in light of the fact that two major * outages occurred during this perio l l
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. * * The licensee hired a new security force contractor during this * period. 'The transition went smoothly and satisfactory performance was sustained through the changeover and subsequent perio * * The event' reporting system is consistent with NRC requirements. The * licensee reported thirteen security events during this period. Ten * of these resulted from computer and/or multiplexer system failure * A potentially unmonitored access path into a security area was dis-covered and reporte One event was caused by a failed door alarm * * switch and one involved a security officer who was inattentive to a
his duties. The reports were timely and generally complete. In-
* provement in the quality of some reports to include greater detail is, however, needed. For example, event report 85-001, pertaining * * to both Units 1 and 2, stated that alarm capability had been lost *
on a locked security door. The report failed to describe the type
* of door (it was not a standard personnel door), the area involved, * results of the search to identify possible tampering, or other *
material facts needed to determine the significance of the even * More recent reports have, however, shown improvement in the scope of details discusse *
*
Security organization staffing is currently adequate to meet the a existing security program requirements. Staffing plans and funding
* to meet expanded site needs for inclusion of Unit 3 are already in * place and demonstrate management's sensitivity to prior plannin * Additions to the security force are already being made. Both cor- * porate and site security management representatives are directly * involved in assuring the application of quality training and quali-fication standards for existing and new employee * * A potential training weakness in SAS operations involving its pri- *
mary function was identified by an NRC inspector early in this period. The licensee immediately initiated remedial training to
*
correct the potential deficienc , Conclusion . * Ratinet Category '
*
Recent Trend: Consisten . Board Recommendation
*
Non .
"
cAsterisked lines are common to Units 1 and , ,
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25 : i Refueline and Outane Manacement (124 hrs., 6%)
, , Analysis Performance in refueling and allied areas recetyed ratings of Cate- ' ' gory 1 for the past two assessment periods. During this SALP !
period, the plant underwent a refueling and large scale In-Service-t Inspection (ISI) outage from April 14, 1984 through June 28. 198 '
.
,
!
" Refueling preparations received close scrutiny. Procedures, in- ! ; ' cluding vendor procedures, were prepared and submitted to the Plant l Operations Review Committee well in advance of the outage. Those ;
i procedures were independently reviewed by NRC inspectors and found !
!
i to contain sufficient detail for the evolutions described. Analyses i
of recurring evolutions to specify work practices so as to maintain : exposures "As Low As Reasonably Achievable (ALARA)" were conducted
! well in advance. The depth and accuracy of planning reflects well !
l l
:
on the forehandedness of individuals in key positions and strong i management support for plannin I The fuel receipt inspection activities, for example, reflected a ! high degree of pride and professionalism. Personnel involved in-
- ' !
cluded 3 engineers, 3 technicians, and 10 quality assurance inspec-
' tors. All personnel wre certified jointly by the fuel vendor and !
i the licensee as " Level I Fuel Inspectors" as a minimum. Inspections t ,
.
for this type of fuel involve numerous measurements with special i ! gauges as well as visual examination. Both inspection conduct and j j results documentation were well execute . t
, !
l A major outage objective was the vitrasonic testing of all acces- ! sible service-sensitive welds in the Reactor Recirculation, Isola- !
' tion Condenser, Core Spray, Reactor Water Clean-Up, and Shutdown } , Cooling Systems. The licensee displayed strong technical initiative t i
j in introducing an automated " Ultrasonic Data Recording and Proces- !
{ sing System" (UORPS) to afd in flaw evaluation. Large scale app 11- ;
j cation of Induction Heating Stress Improvement (!HSI) to 88 Reactor :
!
i - Recirculation System welds, 6 weld overlays, and weld / piping re-placement work efforts were conducted based upon the ultrasonic . t
testing program results. Both region-based and resident inspectors l i commented upon the highly effective management involvement in con- ! ! ' tractor control and quality assurance as w il as in the high degree of technical competence displayed by the Northeast Utilities Non-j Destructive Examination engineer , I
' * *
The licensee has committed personnel and financial resources to i computer-based outage plannin * The dotatI provided by these sys-
; * tems has proven to be a key ingredient in successful outage plannin * Schedules for activittes are interfaced and analyzed by the computer ; * which provides schedules along a critical path, identification of i * near-critical activities, and schedules for activities within cor-j tain areas of the plant and by organizations supporting the outag .
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CAsterisked Ifnes are common to Units 1 and t e i
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* *
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However, during 1983, errors were made in the installation of the Post-Accident Sampling System (PASS) design change, rendering the PASS sampling capability from the Shutdown Cooling System inoperabl Because of the reluctance to contaminate the newly installed system, a full test of the PASS was not conducted until specifically re-quested by NRC Region I. The operability test showed that a key valve had been installed so as to render the PASS unable to draw a reactor coolant sample from the Shutdown Cooling System. This inoperability was not revealed during acceptance testing planned and conducted as part of the modification. The tests had been ap-proved by senior engineering staff as well as the Plant Operations Review Committe In response to this collective error of the plant staff, a Task Force led by the Vice President of Nuclear Operations conducted a review of modification acceptance testing. As a result of this failure, a Level III Violation and a Civil Penalty (miti-gated to zero) were issued. A later Region I post-maintenance, post-modification test program inspection revealed no further error Inspection findings documented a lack of licensee follow-through to verify complete implementation of commitments made to the NR The licensee had failed to place locks on all containment isolation valves addressed in the Systematic Evaluation Progra In sddition, three isolation valves were not isolated to meet an additional commitmen However, the unlocked valves were properly positioned, and blank flanges had been installed in lieu of the addttional
- -
isolation valves. The failure to comply with the commitments therefore was significant from the administrative control viewpoint but had no safety impac . Conclusion
*
Ratino: Category 2.
, Recent Trend: No Basi . l Board Recoamendation l
- *
- Licennoe: Improve self-assessment to identify items such as failure
*
l , to fo 'ow through on commitments and design modification * e ggt None.
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l eA,terisked lines are common to Units 1 and * I
* * # , . , ,
. Licensina Analysis This functional area had been rated Category 1 during the previous , SALp assessment perio Stable performance has been observe In general, the licensee's performance in Itcensing matters shows high-level management involvment, clear understanding of technical issues and responsiveness to NRC initiatives. The basis of this appraisal was the licensee's performance in support of licensing period. that actions were either completed or active during the rating These actions consisted of 9 license amendments, one im-plementation schedule extension (concerning Environmental Qualiff-cation of valve operators), 12 completed multi plant licensing ac-tions (chiefly NUREG-0737 items), 28 completed plant-specific lic-ensing actions (chiefly SEP items), and several on The ongoing actions include " Emergency Capability"(NUREG-0737 going action Sup-plement 1.) Fire Protection (10 CFR 50 Appendix R), containment purge and vent issues, post-accident hydrogen control, and piping , integrit (Specific licensing actions are tabulated at the end of this functional area.) Although additional efforts are needed to resolve the remaining active issues, the Ifeensee has thus far been responsive to staff concerns and prioritie The licensee has exhibited an understanding of the issues in the .
resolution of technical questions with a conservative approach rou-tinely employed when a potential for safety significance exist One example of this related to primary containment inerting. Com-bustible gas control during reactor operation and post-accident period depends on limiting the oxygen concentration to less than 55. Millstone 1 has a technical specification oxygen limit of 45 but normally operates with levels of about 1%. This extra measure of conservatism typifies the importance which the licensee attaches to safet ' A number of commitments for analysis and implementation schedules have been missed through the assessment period, however. Some of these omissions have resulted from confusion involving Integrated System Analysis Pro
"living schedules." grams One(!$AP)
exampleandofthe implementation a lack of so-called of timely response is the 10 CFR 50 Appendix J exemption request which has been an open item since 1977. In light of the generally good performance in the more safety significant aspects of licensing, the scheduling and commitment difficulties experienced have been given relatively lit-t1e weight in this appraisal. However additional Ifcensee effort . is needed to assure proper observance o,f schedules and commitment *
* In summary, licensee performance was good overall, but with recur-rent response timeliness problem ,
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i Conclusion .
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Ratino: Category t
*
Recent Trend: Consistent.
, Board Recommendation *
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- Licensee
- Improve management of Itcensing activities to avoid late
* responses. Improve coordination of activities with NRR in regard ! * j to schedule, prioritization, and project status, -
i
- TABULATION OF LICENSING ACTIONS
Multi-Plant Actions (Comoleted)
--
Mark I Containment Long Term Program Implementation
- -- s
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Control of Heavy Loads Over Spent Fuel Pool (NUREG-0612) )
- -
Reactor Protection System Power Supply , Technical Specifications Defining Operability for Safety Systems
.
j - Implementation of NUREG-0313, Revision 1 .
--
0 -- NUREG-0737, Item II.B.3.2, Post Accident Sampling System Modifications
--
NUREG-0737, Item II.K.3.30, Small Break LOCA Methods
--
NUREG-0737, Item II.K.3.45, Manual Depressurization
i -- NUREG-0737, Item II.K.3.31, Compliance with 14 CFR 50.46 ' NUREG-0737, Technical Specifications
-- : --
NUREG-0737, Item II.K.3.16, Challenges and Failures of Relief Valves ' ! NUREG-0737 Item II.K.3.28 Verify Qualification of Accumulators on Auto l Depressurization System Valves Plant Soecified Actions (Ca=elete) I
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IntegratedStructuralAnalysis(SEP) , i '
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Miss'les(SEP)(SEP) Seismic Design Motor Operated Valves (SEP)
;
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LeakDetection(SEP) .
;
Water Chemistry (SEP)
--
, Battery Instrumentation and T5 Limits (SEP) :
--
Activity Limits SEP
;
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! -- Audits of Emergen(cy a)nd Security Plans Relating to Generic Letters i ! 82-23 ! -- !
-- Review of Modified Amended Security Plans peo Eisenhut Memorandum May 16, 1983 i --
Integrated Leak Rate Test in Less Than 24 Hours ! ! Evaluation of NNECO Quality Assurance Report Submitted by NNEC0 letter June !- 9, 1983 !
-- i
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--
Required ATWS Actions Generic Letter 83-28 1 i
--
Administrative Technical Specification Changes I i Technical Specification Clarification Related to Fire Protection Detection l l ?
;
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. -- --
Response to NNECO November 18, 1983 Station Training
--
Recirculation Line Pipe Crack Clamps
--
New Steam Unnel Ventilation System Isolation by Radiation Signals
--
Eylauation of Advanced-Higher Enrichment-Fuel Assemblies Evaluation of NNECO Isolation Condenser Submittal dated March 27, 1984 Re-lating to Pipe Integrity
--
Reload 9 Evaluation
-- --
Evaluate Recirculation and Connecting Piping Fixes
--
Subcooled Post Design Base's Loss of Coolant Accident Radiolysis Evaluation The Need for Recombiners - Response to GL 84-09
--
Environmental Statement Update
-
Recirculation Loop Decontamination in Preparation for Non-Destructive Weld T4 sting of All Welds
-- --
Inspection of Stainless Steel Piping Per GL 84-11 Delection of Meteorological and Terrestrial Appendix B Technical Specifications In addition to the completed actions listed above, there were specific ongoing activities associated with the requirements relative to Supplement 1 to NUREG-0737 CEmergency Capability," Appendix R - Fire Protection exemption requests, contain-ment purge and vent requirements, the need for post accident hydrogen recombiners, and detection and repair of pipe weld cracks in the primary coolant recirculation pipin .
9
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r i - ( / * f .- . : ..
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' SUPPORTING DATA AND SUMMARIES -
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( Investinations and Allocations ' I . Non Escalated Enforcement Actions
. .- Civil Penalties '
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A civil penalty associated with a Severity Level III Violation was' / issued July 11, 1984. That civil penalty, which was mitigated on-tirely, resulted from installation errors in the Post Accident Sampling Syste < Orders . A June 19, 1984 O ker conf'irmed the implementation schedule for r l outstanding items within the TMI Task Action Plan concerning emer- [ ' gency response plannin , Confirmatory Action Letters < s Non '
- Manaaement Conferences . -
l An enforcement conference was held on November 14, 1983 to discuss vio- / 1ations identified in the implementation of the Haddam Neck Plant Post . Accident Sampling System. A Notice of Violation was issued, in the mat-ter, for the Haddam Neck and Millstone Unit 1 plants on July 11, 1984.
l Licensee Event Resorts t i l Tabular Listine '
!
! Tyne of Events: ,!
,
,
t Personnel Error t
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Design / Man./Const./!nstal '
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l External Cause t 4 i l Defective Procedure 1 i I Component Failure 25 j l Other ,,) ' , Total 38
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c Licensee Event Reports Reviewed: Report Nos. 83-26 to 85-02, including 13 Security and 5 Environmen-tal Reports common to both Units 1 and '
' Causal Analysis .
Seven sets of common mode events were identifie The first two are common to Units 1 and 2: There were ten reports which involved the failure of station security equipment. The predominant failures involved the ' security process computers and their communications link - multiplexers (Security Reports 83-05 and -06; LER's 84-01,
. -02, -10, -13, -14, -16, -20 and 85-02). There were five reports which involved the detection of radio- l
. l nuclides in shellfish or aquatic flora gathered within 500 feet of the discharge into Long Island Sound, of which the concen-trations exceeded the control station average by greater than a factor of ten (Environmental Reports 83-04,-05, and -06; l . LERs 84-03, and -07.) This has been an ongoing situation, and l the licensee has submitted a technical specification change request to change this reporting requirement. Licensee analy-sis (LADTAP code) shows a negligible effect on the "most ex-
posed person," with an increased exposure of 0.15% the normal ' background radiatio . There were two reports of the failure of the motor operator for the Isolation Condenser initiation valve 1-IC-3 due to improper operation of limit switches (LERs 84-15 and -18), There were two reports of inoperability of the Reserve Station Service Transformer, both due to insulator problems, one fail-ure and one excessive salt contaminatio * One report addressed twenty-three welds which were rejected following NOT for IGSCC (LER 84-08). One report addressed ten hydraulic snubbers which failed func-tional testing (LER 84-09). One report addressed three Target Rock safety-relief valves which failed to open at their required setpoint pressure during testing with steam (LER 84-12).
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32 ' I Licensee Event Report Analysis An analysis of Licensee Event Reports (LER) indicates a high level of performanc However, because 10 CFR 50.73 redefined the re-quirements for submitting an LER, there was a change to the data base on January ~1,.198 ' The ratio o'f ' personnel-related events,to' facility-related events I remains very low at 0.06. This compares favorably with a ratio of 0.12,-attained during the previous SALP cycle and 0.18 for a "typi-cal"' BWR of NUREG/CR-2378. s
~
The ratio of management related events to facility-related events increased from 0.09 to 0.12 during the cycle. (The " typical" BWR of NUREG/CR-2378 achieved a management related to facility related event ratio of 0.18.) This increase was due to the failure to cor-rect recurring problems with the security system equipment, the Isolation Condenser Containment Isolation Valve 1-IC-3 and the de-sign deficiencies relating to the containment isolation function of the Post Accident Sampling System.
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TABLE 1 TABULAR LISTING OF LER's BY FUNCTIONAL AREA-MILLSTONE NUCLEAR STATION, UNIT 1 AREA NUMBER /CAUSE CODE TOTAL Plant Operations 1/C 8/E 9 - Radiological Controls 5/X 5 Maintenance & Modifications 1/8 1 Surveillance
. /B, 1/C, 6/E 9 Fire Protection / Housekeeping 1/D 1 Emergency Preparedness O Security & Safeguards 2/A 11/E 13 Refueling & Outage Management 0 Licensing Activities
_0 TOTAL 38 - Cause Codes
,
A - Personnel Error 8 - Design Manufacturing, Construction or Installation Error C - External Cause ,
.D - Defective Procedure '
E - Component Failure X - Other ' -
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TABLE 2 INSPECTION HOURS SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION, UNIT 1 Hours % of Time Plant Operations 714 34 Radiological Controls
.
B .' 318 15 Maintenance 347 16 Surveillance 333 16 Fire Protection / Housekeeping 42 2 Emergency Preparedness 169 8 Security and Safeguards 63 3 Refueling and Outage Management 124 6 Licensing Activities -- --
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TOTAL 2110 100 Nate: Licensing personnel time is not included in SALP.
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TABLE 3 ! VIOLATION SUMMARY (9/1/83 - 2/28/85) . MILLSTONE NUCLEAR STATION, UNIT 1 - Number a'nd Severity Level of Violations
.
Severity Level I O Severity Level II O 1 Severity Level III 2
- Severity Level IV 8
' Severity Level V 0 Deviation _
Total 10 Violation by Functional Area ' Functional Area Severity Level I II III IV V DEV Plant Operations Radiological Controls 1 4
, . Maintenance & Modifications Surveillance 1 Fire Protection & Housekeeping Emergency Preparedness Security and Safeguards 3 Refueling and Outage Management * 1
, Licensing Activities Totals 0 0 2 8 0 0
, - *In the analysis sections of this SALP, the Level III Violation related to the PASS modification installation and testing is reviewed from the viewpoint of inadequacies
' in managing the non-recurrent evolution of system installation and testing and is included in outage managemen l
.
e
. - - . - , . , , , . - p-- , - - . ,-, ---,---r--- ,.a ,-~
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. Summary Inspection Inspection Severity Functional Report N Dates Level Area Violation *83-16 9/26-30/83 IV 7 Failure to control security key *
IV 7 Failure to acknowledge security alarm /30-11/4/83 IV 2 Failure to properly review procedural chang /2-6/84 VII 8 Failure to properly install the liquid Post-Accident Sampling Syste /6-6/9/84 IV 2 Failure to follow Radiation Work Permit (RWP).
' 84-13 5/29-6/1/84 IV 2 Failure to follow RW ' IV 2 Failure to control internal exposur /14-2/24/85 IV 4 Failure to calibrate nuclear instrumentatio * IV 7 Failure to maintain a clear isolation zon /28/84
' - III 2 Failure to control free-standing liquid in a solid waste shipment.
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* Asterisked lines are common to Units 1 and 2 . _ , _ _ . _ _ _. _ - - * ; ' . : .
37 -
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TABLE 4 REACTOR TRIP AND OUTAGE SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION, UNIT 1 UNPLANNED AUTOMATIC SCRAMS There were no automatic scrams during the eighteen-month appraisal perio . FORCED OUTAGES DATES POWER LEVEL CAUSE /26-28/83 Shutdown from 100 percent Repair of a defective recircu-powe lation pump seal.
' /2-4/84 Shutdown from 100 percent Repack leaking instrument isola-powe tion valve located in the primary containmen *
.
9
*4 . . . - _. _ . _ - _ _ . . _ .
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TABLE 5 INSPECTION REPORT SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION, UNIT 1
. '
Report Number Inspection Inspector (s) . Hours Areas Inspected 83-16 27 Station security program and implementatio (Specialist) 83-17- 65 Routine inspection including followup of gas turbine (Resident) tri Routine inspection including followup on Post-Acci-(Resident) dent Sampling System installation error and reactor core power distribution calculation .5 Quality Assurance Program including storag (Specialist) 83-20 55 Radioactive e'ffluent control and monitorin (Specialist)
.
83-21 39 . Routine inspection, including high containment leak-(Resident) age rat Routine inspection including repairs to turbine (Resident) extraction steam pipin Routine inspection including repairs to safeguards (Resident) pump and potential for containment vent header crackin Emergency Preparedness Progra (Specialist) 84-04 31 Radioactive materials packaging and transportatio . (Specialist) 84-05 91 Routine inspection including emergency diesel oper-(Resident) ability, maintenance and preventive maintenance, emergency gas turbine generator voltage regulator operability, liquid effluent analysis, and prepara-tions for. refueling / maintenance outag ' 84-06' 17 Nonradiological chemistry analysis including quality
- (Specialist) control of analytical measurement .
e
,.,-...w.,-. - . , _ _ __ _ _ _ _ _. . _ _ _ _ ___ _ ._ _ _ __. _. _ _ . ' * . * * , . . . .
.
l Report Number Inspection i
'
Inspector (s) Hours Areas Inspected l 84-07 1 89 Post-accident monitoring equipment installations '
(Specialist) made to implement commitments of a Confirmatory Order dated March 14, 198 ,
84-08 135 Routine inspection including refueling / maintenance (Resident) activities, chemical decontamination of reactor re-circulation system, non-destructive examination of Class I and service sensitive Class II per SECY-83-267C and NUREG-0313, inter granular stress corrosion
-
cracking (IGSCC) repair with weld overlay, installa-tion of safeguards electrical bus undervoltage (UV) equipment, and radiation protection during outag Emergency diesel generator maintenanc (Specialist) 84v10 Quality Assurance for design, installation and oper-(Specialigt) ation of PASS.
i 84-11 186 Routine inspection including refueling / maintenance (Resident) activities, inservice inspections, reactor vessel ' inspections, inspection of containment vent header piping, IGSCC repair with weld overlay, and radiation
. -
protection during outag Repair of IGSCC detected in reactor pipin (Specialist) . 84-13 26 Radiation protection during a refueling / maintenance (Specialist) outag Station security program and impiementatio (Specialist)
-
84-15 19 Fire protection / prevention progra (Specialist) t 84-16 6 Emergency diesel generator maintenanc (Specialist) 84-17 None Administration of NRC licensed operator examination (Licensing Examiner) l 84-18 56 (Specialist- Containment local and integrated leak rate testin , Resident) I
$
..~.,-__,__--__._,..__,.._,_m____.__._,_-___,,____ __,,._____,____.,__.______,y . - , _ _ ,.,_, _ _.. ,, _ _ . _ . .....__ __ . .__.._ ., _ _ , _ _, .
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Report Number Inspection Inspector (s) Hours Areas Inspected 84-19 155 Routine inspection including refueling / maintenance (Resident) activities, the primary containment integrated leak rate test, safeguards electrical bus testing, the
,
integrated safeguards system actuation testing, the feedwater coolant injection sub-system test, the reactor vessel and recirculation hydrostatic test ' and reactor startup testing, and maintenanc Routine inspection including licensee response to (Resident- operational. incidents, excessive containment uniden-Specialist) tified leakage, containment isolation valve motor failure, and the review of the licensee's analysis
,
of containment penetration anchor load Routine inspection including licensee response to (Resident) single control rod scrams and a review of the me-chanical snubber surveillance progra Administration of NRC licensed operator examinations (Licensing Examiner) and review of requalification training program.
' 84-23 179 Emergency preparedness exercis (Specialist- , Resident)
<
84-24 2 Radiation protection progra (Specialist) . 84-25 56 Special inspection of NRC Generic Letter 83-28 for ! (Specialist) equipment classification and veridor interface.
I ! 84-26 4 Routine inspection including containment isolation (Resident) '
, function of PASS lines, Emergency Gas Turbine Gener-ator (EGTG) operability after finding an air-start system. failur l Routine inspection including EGTG operability fol-
i (Resident) lowing transmission line transients, and verification of commitments concerning flooding, off-normal i operating procedures, locked containment isolation t ! valves, surveillance testing, Reactor Protective System power supply isolation devices, degraded grid
, voltage procedures, and EGTG improvements.
. 85-01 3 Quality Assurance Audits, Surveillance and Monitor (Specialist)
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l t Report Number Inspection Inspector (s) Hours Areas Inspected 85-02 113 Routine inspection including nuclear instrumentation (Resident) calibration, compliance with 10 CFR 50.54 for a senior licensed operator in the Control Room, a reactor recirculation system flow anomaly resulting s in a reduction in reactor jet pump efficiency, and loss of power at Emergency Operations Facilit None Radioactive waste shipment deficiencie (State of South Carolina) t i e e S e O e
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TABLE 6 -
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- LER SYNOPSIS (9/1/83 - 2/28/85) -
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MILLSTONE NUCLEAR STATION, UNIT 1 t LER N Summary Description *
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83-26 Emergency Gas Turbine Generator shutdown because of a defective speed switch cabl q
; 83-27 Setpoint drift, isolation condenser initiation time delay rela Offgas radiation monitor failure.
" 83-29 Setpoint drift, high drywell pressure switc Inoperable containment isolation valve 1-MS- APRM Channel failed to trip when placed in an inoperable condition.
j 83-32 Excessive drywell leakage due to recirculation pump seal failur Standby Gas Treatment Subsystem B degraded by inoperable heater due to
- a defective rela '
83-34 Reserve Station Service Transformer Inoperable to correct oil lea i
,
83-35 Reserve Station Service Transformer Inoperable due to salt on insulator.
-
*ETS83-04 Ag-110m and Co-60 in oysters, within 500 feet of discharge, in levels
greater than the control station by a factor of ten.
'
*ETS83-05 Co-60 in aquatic flora, within 500 feet of discharge, in levels greater .
than the control station by a factor of ten.
*ETS83-06'Co-60 in oysters, within 500 feet of discharge, in levels greater than
- the control station by a factor of ten.
, "SEC83-05 Security-related computer failure, loss of alarm surveillanc *SEC83-06 Security related computer failure, loss of alarm surveillance.
- *84-01 Security related multiplexer failure, loss of alarm surveillance.
i
*84-02 Security-related computer failure, loss of alarm surveillance.
!' l *84-03 Ag-110m in oysters, within 500 feet of discharge, in levels greater than j the control station by a factor of te .
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* Asterisked lines are common to Units 1 and ____. _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _
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. LER N Summary Description l "84-04 Potential unmonitored access to security are *84-05 Local leak rate testing of containment isolation valves identified 10 needing corrective actions.
4 . 84-06 Electronic noise causing nuclear instrument RPS trip during a refueling
outage, reactor had been in cold shut dow l
*84-07 Co-60 in aquatic flora, within 500 feet of discharge, in levels greater
- than the control station by a factor of ten.
- 84-08 Rejection of 23 piping welds after discovery of intergranular stress
.
corrosion cracking during inservice inspection.
. 84-09 Failure of 10 of a total of 94 hydraulic snubbers during functional testing. Seven were found out of adjustment, two with worn seals, and l one with an incorrectly installed poppet valv *84-10 Security-related computer failure, loss of alarm surveillance.
- >
>
84-11
Failure air of condenser bay area fire detection, low thermal supervisory pressur ' 84-12 Failure of four out of six safety-relief valves to open within one I percent of specified set poin t ! $84-13 Security-related multiplexer failure, partial loss of alarm surveillanc Security related multiplexer switch failure, loss of alarm surveillanc '
.
84-15 Failure of containment isolation valve motor-operator, isolation conden- . ser out of standby service.
i
$84-16 Security-related computer failure, intermittent loss of alarm surveil-
- lanc Excessive primary centainment leakage, valve packing failed.
, 84-18 Failure of containment isolation valve motor-operator, isolation condon-ser out of service.
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*84-19 Security guard not performing duties.
. 884-20 Security-related multiplexer failure, partial loss of alarm surveillance.
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LER N Summary Description 84-21 Failure to maintain primary containment integrity during surveillance testing of post accident sampling system during reactor power operation.
' However, remote manual isolation valves had no automatic containment isolation functio $85-01 Security-related, failed door switc c85-02 Security related computer failure, intermittent loss of alarm surveil-lanc .
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ENCLOSURE 4 t
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-336/85-99 NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR STATION UNIT 2 (870 MWe PRESSURIZED WATER REACTOR, COM8USTION ENGINEERING DESIGN) ASSESSMENT PERIOD: SEPTEMBER 1, 1983 - FEBRUARY 28, 1985 BOARD MEETING DATE, MAY 6, 1985
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e TABLE OF CONTENTS Page INTRODUCTION ......................................................... 1 Purpose and Overview .................... 1 SALP Board Members ..................... ...........:............ Background ............................. ........................ ........................ 1
I CRITERIA AND RATINGS ................................................. .
III. SUMMARY OF RESULTS ................................................... 4 Overall Facility Evaluation ........................... 4 Overall Evaluation of Training ........................ ......... 4 Facility Performance ........................................... ........ 5 I PERFORMANCE ANALYSIS ................................................. 6 i Plant Operations ................................................ 6 Radiological Controls ..................... 10
. Maintenance .................................................... 13 Surveillance ..................................................
Fire Protection / Housekeeping ..................
.................... 17 19 Emergency Preparedness .....................,.. ................ .. 21 Secu ri ty a nd Sa feg ua rds . . . . . . . . . . . . . . . . . . . . . . . . . . .............. ............ Refueling and Outage Management ................................ 25 Li cen s i ng Acti v i ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 SUPPORTING DATA AND SUMMARIES ....................................... 30 Investigations and Allegations Review .......................... .
Escalated Enforcement Actidns ............. 30 Management Conferences .................... ....................
................. 30 Li cen see Even t Repo rt s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . 31 l
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TABLES . TABLE 1 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA . . . . . . . . . . .33. . . . . . . . . . . I I TABLE 2 - INSPECTION HOURS SUMMARY ....................................... 35 i TAB LE 3 - VI O LAT ION S UMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3.5. . . . . . . . . ! '. TABLE 4 - AUTOMATIC SCRAMS AND FORCED OUTAGES ............................. 37 . 3 !. TABLE 5 - INSPECTION REPORT SUMMARY ...................................... 38
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, . INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect information periodically and evaluate licen-see performanc SALP supplements the normal regulatory processes used to ensure compliance with NRC regulations. It is intended to be suffi-ciently diagnostic to support allocation of NRC resources and to be mean-ingful to licensee efforts to improve plant safet An NRC SALP Board met on May 6,1985 to assess licensee performance in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Lic-ensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report assesses licensee performance at Millstone Unit 2, a Combus-tion Engineering designed Pressurized Water Reactor, for the 18-month period from September 1,1983 through February 28, 198 * SALP Board Members R. Starostecki, Otrector, Division Reactor Projects (DRP), SALP Board Chairman W. Kane, Deputy Director, ORP R. Bellamy, Chief, Emergency Preparedness and Radiological Protection -
Branch, Division of Radiation Safety and Safeguards (DRSS) J. Durr, Chief, Engineering Programs Branch, Division of Reactor Safety (DRS) E. Wenzinger, Chief, Project Branch 3, DRP E. McCabe, Chief, Projects Section 38, DRP
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L. Rubenstein, Assistant Otractor, Core and Plant Systems, Division of Systems Integration, Office of Nuclear Reactor Regulation (NRR) D. Osborne, Licensing Project Manager, ORB 5, NRR J. Shediosky, Senior Resident Inspector, Millstone Units 1 and 2
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Other Attendees
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D. Lipinski, Resident Inspector - J. Shea, Licensing Project Manager, NRR R. Summers, Project Engineer, Projects Section 38, DRP Background Licensee Activities This Combustion Engineering designed Pressurized Water Reactor was in an extended refueling / maintenance outage at the beginning of the assessment perio That outage, which began on May 28, 1983, was
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l - extended significantly after it was ,found that the reactor vessel thermal shield had cracked at the points at which it was attached to the core support barrel. The thermal shield was removed. The
outage ended when the turbine was placed on line on January 15, 1984., A forced outage occurred, after a month of Bperation, when testing l identified multiple resistance temperature detector channels with
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excessive sensor response times. Following repairs the plant
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operated at full power for 271 days until a scram wa,s caused by_ main ' steam isolation valve closure due to a valve actuator failure on 1 November 1 ' There was a shutdown on November 28 to protect the turbine after a feedwater heater tube rupture. Then, the plant i operated at full power from December 1 until the end of. core full i power life on January 24, 1985. The reactor was shut down for a
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fourteen week refueling / maintenance outage on February 1 ! Extensive inspections and maintenance of the steam generators were l' scheduled for the outage. The Itcensee committed significant re-sources to remove sludge from the steam generator secondary. The sludge has been considered responsible for pitting degradation of i steam generator tube The reactor availability and capacity factors for 1983 were 3 percent and 32.4 percent, respectively; and 93.5 and 87.6 percent i in 198 However, excluding the 1983 and 1985 refueling outages, - i these factors were 99.3 and 93.6 percent, respectively, for the - eighteen month assessment perio (These factors were computed by the resident inspectors using data from the Itcensee's monthly l operation report.) Inspection Activities
i One NRC resident inspector was assigned to Millstone Units 1 and * 2 for the entire appraisal period. A second resident inspector was on site for eight months of the eighteen month period.
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! Total NRC inspection hours (both resident and region-based) expended l on Unit 2 were 2158. .This is equivalent to 1439 inspection hours l per yea NRC Emergency Preparedness Inspection Teams observed full scale emergency exercises on October 5, 1983 and October 12, 198 There were no investigations conducted during the assessment period.
Tabulations of Violations and Inspection Activities are appended f to this report, i
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I CRITERIA AND RATINGS Licensee performance is assessed in prescribed functional areas significant to nuclear safety and the environment. One or more of the following criteria is used to assess each are ,
, Management involvement in assuring quality Approach to resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Reporting and analysis of reportable events Staffing (includingmanagement) Training effectiveness and qualification These criteria are not limiting; others are used where. appropriat Based upon the SALP Board assessment, each functional area evaluated is clas-sified into one of three performance categorie These are:
Category Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to safety is being achieve Category NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuc-lear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to safety is being achieve Category Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to safety is being achieve The SALP Board also trended licensee performance over the SALP assessment period by comparing the overall performance for the last fourth of the as-sessment period to the overall performance for the entire SALP period. The
"trend is identified as " Improving," " Consistent" (essentially unchanged), or Declining."
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-III. SUMARY OF RESULTS Overall Facility Evaluation
! t ! * Overall, licensee performance was good during this SALP period. Plant operator performance was considered highly professional. There are two unplanned trips during the 18-month SALP. period, but overall effective 2' operator and operations support performance and coordination was sho'wn by a 271 day continuous run at power in 1984. Licensee event report review showed a typfhal ratio of personnel-related to facility-related i
* events and a relatively low (and decreasing) ratio of management-related to facility-related events. Onsite safety review committee performance * * ' was assessed as thorough and effective overall. QA auditing and moni- * toring of operational activities were found to be good and well received by facility management. Instances of deficient Itcensee self-appraisal *
t were, however, eviden * j
* The pliedradiation to major protection and housekeeping programs were effectively ap-activities.
j Good housekeeping has resulted in the primary containment being accessible without protective clothing. Major activi-i ties involving high radiation fields (ex: steam generator work) were !
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carefully planned and controlled. But there were multiple lapses in
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! * worker adherence to routine radiation requirements and repetitive prob-
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1ess with low level radwaste shipments to South Carolina. These lapses
* indicate a need to upgrade first level supervision of such activities
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* as well as to improve worker compliance with radiation protection con-j trols, *
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* In some cases, the licensee has not provided timely resMnses to the NR * One such case involved shelf-life control for perishables and environ-
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mental controls for welding electrodes. Another involved untimely re-
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sponses in the Licensing area. Untimeliness was not noted, however,
. in the more significant issues.
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* In summary, iteensee performance has been strong in plant operations and
! 1 * control of major activitie Significant lapses were noted in radiation
' protection.
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* Responses to the NRC need to be more timely. There is a need for more effective licensee self-appraisa Overall Evaluation of Training * * As shown by the operational performance of the plant, the training pro- *
gram has been effective overall. Licensee training initiatives have been
* noteworthy, including upgrading through training staff expansion in size *
and authority. A training department screening process has been imple-
* mented to correct a problem at Unit I with operator performance on in- *
itial NRC licensing examinations. An onsite plant specific simulator
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project is in process. Requalification training has been satisfactory
* and is expected to improve when the simulator is placed in operatio * Training of non-operators was good, with Instrument and Controls depart-ment training noted to be particularly effectiv * Asterisked lines are common to Units 1 and * . ' *
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5 Facility Performance Category Category Recent Functional Area Last Period This Period Trend (9/1/82- (9/1/83- ,
. 8/31/83) 2/28/85) Plant Operations 2 1 Consistent Radiological Controls 1 2 Consistent' Maintenance 1 1 Consistent ' Surveillance 1 1 Consistent Fire Protection / Housekeeping 1 1 Consistent Emergency Preparedness 2 1 Consistent Security & Safeguards 1 1 Consistent Refueling & Outage Management 1 1 Improving Licensing Activities 2 1 Consistent
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I PERFORMANCE ANALYSIS l i Plant Operations (748 hrs., 35%) ^
- Analysis ; 3 Operations, which includes engineering support, design changes and modifications, and management effectiveness received resident in-spection and the attention of twenty-one region based inspector During the preceding SALP period, a rating of Category 2 was as-signed. Performance during that period was marred by several oper- i attonal errors and unplanned releases of radioactive materia '
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During this SALP period, two unplanned reactor scrams from power occurred. Operator attentiveness has minimized unexpected transi-ents and avoided a challenge to safeguards equipment operation on ; several occasions._The best examples were events involving the steam ' generator feedwater system. All occurnd from full power. In each l case corrective actions stopped the transient and dampened steam generator level oscillations. On June 5,1984, the inadvertent trip of a high pressure heater drain pump was detected and corrective > actions taken before the steam generator level transient caused a l reactor trip. (Forty percent of total feedwater flow is from the ! heater drain system.) In a second event, a reduction in feedwater : heating resulted from the failure of an extraction steam valve positioner on November 5,1984. Although no control room annunciator ! alarmed, operators minimized the reactivity addition. On January i 13, 1985 operators recognized the failure of a steam generator ' feedwater regulating valve automatic control while at full nower and maintained manual valve control through the end of the operating cycle. Such action contributed to safely accomplishing a 271 day turbine generator on line period ending in November 1984. In a later l example, operators manually scrammed the nactor on November 28, 1984 to protect the turbine from damage due to water intrusion when the rupture of feedwater heater tubes flooded the heater.
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* * Overall, control room performance was evaluated as highly profes- 1 *
sional and effective.. Other than normal security measures, control i i
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room access was not restricted. Documents sent to the control room i
* were not specifically pre-screened to avert undue burdening of the !
, operators. But business with the control room was requind to be
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! * j * conducted through one of the two senior licensed operators on duty, ! ! * and specific permission was. required for non-operators to enter the J
* . marked-off a mas near the' control panels. Pre-evolution briefings
! j * of operators were evaluated as thorough, appropriate, and well pre- i sented. Procedures and drawings were readily available. There was , i strong management emphasis on procedure adherence. Despite a lack i i of formal status boards, shift turnover controls and degraded equip-ment lists were found to be adequate in that the operators were ' l , found to be knowledgeable of equipment and activity status. The
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" mimic" control panel layout provided was considered to be an ef-factive operator aid and was updated as changes occurred. Watch-
. ' stander demeanor was considered professional. A change was initiated l L to reposition the operators' desks and seating to provide a better '
view of the control panels. There was a notable absence of ex-
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During this assessment period, there were no unplanned releases of . radioactive material and no personnel errors of an operational l l nature resulted in a reportable event. This is in contrast with
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- ' three 1983 refueling outage events in which personnel errors con- l tributed to part or all of the cause. Past problems have been i i evaluated internally through reviews conducted by Operations Depart- i i
ment supervision and externally through a program supported by re-views by station and INPO personnel. The licensee evaluates the i
human interface in every operational problem to determine the root l
cause and appropriate corrective actions. Occurrences of superior i i performance are also examined in search of procedural, hardware or ! , training improvements. Evaluations are reviewed by station manage- '
, ment, i !
i Of the reportable events during the 1983 refueling outage, two in- ! volved errors with instrumentation and one involved transporting i a heavy load over irradiated fuel. The instrumentation problems were ; improper safety injection tank level and degraded thermal margin / low ' pressure reactor trip functions in two reactor protection system
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i (RPS) channels. The safety injection tank level problem was caused ' by the introduction of water into level instrument reference columns ! incident to modification to those instruments. The degraded RPS trip ! functions were caused by reversed nuclear instrument cables between i upper and lower power range detectors. Contributing to the error ! , in reversing the instrument cables were inadequate system drawings l
: and procedures resulting from modifications made during the initial '
j plant start-up in 1975 and during 1981. In both_ cases, control room ! operators observed and acted promptly on early indications of an j abnormal situatio ,
; - * ! * The onsite Plant Operations Review Committee (PORC) has been ob- (
i * served to examine issues in a deliberate manner which established l
* a reasonably high confidence that issues important to safety have !
i j * been evaluated. The resident inspectors attended 13 PORC meetings i without prior notification and found that the members maintained 1 ',
. , high standards. This was apparent in meetings held after the No- -
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vember 15, 1984 reactor trip to evaluate any potential safety prob- ",
- less. The series of PORC meetings conducted to review both the >
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- stitution of i,r secondary chemical cleaning process and the recon- !
! rradiated fuel assemblies to remove leaking fuel rods
' * patiently examined each process and attempted to thoroughly develop any latent safety issue. The. committee did not hesitate to generate j .
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! * commitments which required resolution or to return packages for additional work. The resident inspectors concluded that PORC review
quality is uninfluenced by the schedule for an activit ! The Itcensee is revising piping and instrument drawings. Drawing l
standards have been developed by the corporate organization. In- !
, dividual drawings are being completely revised following full vert-
fication of components by engineering and operations personnel. The l program involves significant input from operations to select a for- l mat for each drawing in order to provide the best use to those
people. The drawings are to be produced by corporate computer-aided ! design equipment. These initial drawings are the beginning of what
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; * * Inspectors reviewing licensed operator training and requalification
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have observed an ongoing evolutio Training Department responsi- .
* bilities expanded from simply instructing personnel to authority '
for pre-examination screening. An effective requalification train-j *
ing program is administered in a six week classroom series and one ;
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week of contractor simulator training. Region I licensing examiners l
participated in the requalification program, providing a section l j of the examination and conducting in plant walk-throughs. The in- '
spectors observed that the program has developed into a more mean- '
ingful exercise which requires licensed operators to maintain thetr i
* level of plant knowledge. Annual examination quality has been in- .
proving. Operators failing a section of the examination receive l ! * ,
* a performance evaluation by the training department, which reports t
! directly to corporate management, and may be removed from licensed i * duties. Training department staffing, which includes individuals
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and expected to be in use in 1985. There is good communication be- . ! tween the training supervisor and the NRC licensing examiner There is good cooperation between the operating and training staffs, ; and the actions in progress should improve the already sound pro- : gra ,
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The ratio of personnel-related events to facility-related events j ( has increased from 0.21 during the last SALP cycle to 0.28. (The !
" typical * PWR of NUREG/CR 2378 is 0.26.) This ratto reflected per-i sonnel errors associated with transporting loads over irradiated !
l fuel, improper safety injection tank level indication, and missing ! , .
' ..surve.111ance tests. The ratio of management-related events to .'i i
facility-related events decreased from 0.24 in the last SALP cycle i * to 0.19. This compared favorably to the " typical" PWR ratto of 0.2 .
* LERs, both those submitted prior to January 1, 1984 and under the t H
! * new requirements in force since then, were timely and complet !
* When additional information later developed concerning reported events, updated LERs have been submitted.
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* * Region-based inspectors reviewed QA audit schedules and plans, * documentation of 11 QA audits, 3 semi-annual QA review reports to * management, the QA monitor schedule, and 6 QA monitor reports. The * resident inspector observed one monitoring evolution and reviewed *
the documentation of another. QA audits are done by the corporate
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staff and generally have a broad scope. The audit staff is small
* and aggressive, with good communication with senior management and the PORC. QA audit schedules and results are reviewed by the POR * *
The monitor program is conducted by the onsite QA staff. It pro-a vides site managers with a separate view of the performance of personnel and evolutions. Corrective actions on audit and monitor
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findings generally,are implemented promptly. The Itcensee is re-
* viewing the monitor program to identify ways to enhance its ut'11t a Overall, the audit and monitor programs are considered to be post-tive contributors to quality and safet Control of vendor supplied services and equipment was reviewe The licensee was found to be implementing the essential elements of Regulatory Guides 1.33 and 1.38 in an affirmative manner for conventional services and components. Weaknesses were discovered in the Quality Control of computer codes for safety analyse Specifically, procedures did not address measures to notify code users of code changes, corrections to codes in which errors are identified, and re-analysis of studies done with superseded code Communications between the licensee and NRC Vendor Programs Branch inspectors affirmed the Itcensee's commitment to improve. One de-ficiency, however, warrants further emphasis. The liceriaee's of-ficial list of " Qualified Users" of the RETRAN code included per-sons who had never run that code. Many asnects of reactor plant quality are affected by activities by persons whose qualifications are certified by the ifcensee without NRC licensing. The deficient certification of individuals to conduct pressurized water reactor safety analyses using a sophisticated computer code (RETRAN is a significant flaw in management involvement in the assurance)of quality at a fundamental leve . Conclusion .
Ratina: Category 1 Recent Trend: Consisten . ,
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NRC: Non *
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. , Radiological Controls (271 hrs., 12%) Analysis * *
The licensee's performance for this period is degraded from the
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performance noted in.the previous assessmen While no violations
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were noted in the last assessment, five violations were identified
* in the current pericd. _This is of particular note since the radi-a ation protection program was subject to reduced inspection effort due to previously observed good performanc * *
The licensee's radiation protection program continues to be defined
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by generally good policies and procedures. Resident and specialist
* inspector reviews of this area generally indicated consistent good * performance in the area of contamination control, personnel mont-toring, radiological surveillance and job control, instrumentation * *
reliability and effluent control. However, during this period, both
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residents and specialist inspectors observed inceased deficiencies
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involving procedure establishment, implementation and maintenanc * For example, on two separate occasions, the licensee performsd tasks
* that were beyond the work that was authorized and allowed by job *
specific radiation work permits. Though these occurrences were
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identified to the licensee, corrective measures were not effective enough to prevent recurrence a short time late *
* Other procedural deficiencies noted during this period included the * implementation of a change to the liquid waste discharge procedure *
without administrative and technical review, and failure to adhere
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to the containment requirements of a soecial procedure used for fuel
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reconstitution. Additionally, on one occasion, the licensee failed
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to implement precedures to prevent recurrence of conditions that
* resulted in materials byan inadvertent sustained intake of airborne radioactive a worke . *
For this event, corrective action was not initiated until the item was identified by an irispector 30 days
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later. Several other procedural problems noted this period rein-
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forced the perception that violations are repetitive and indicative
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of minor programmatte breakdown, particularly in view of the licen-
* see's previously observed ability to adequately establish, implement and maintain procedure * *
During this assessment period, a special post implementation review
* of the licensee's efforts involving the post-accident sampling and
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*' .... monitoring requirements of NUREG-0737 was performed. The review -
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identified several deficiencies including the improper installation
* of a portion of the reactor coolant sample acquisition pipe for Unit 1. That would have prevented sample collection for certain modes *
of operation. This finding was in nonconformance with an associated
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Confirmatory Order previously issued to the licensee, and indicated
* .that the licensee did not subject the implementation of post-acci-dont modifications to thorough or technically sound review and tes . ' Asterisked lines are common to Units 1 and . . ;' . .' .
* * (Thiscasewasindicativeofgenericdeficienciesinthelicensee's * programs for plant modifications and engineering design changes.)
- In response, licensee management initiated an ambitious program to
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revise and upgrade design control practices. Review of the licen-
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see's corrective measures in this area, so far, indicate an under-
* standing of the technical issues as exemplified by technically . sound', thorough approaches and corrective action . * * While reviews by both resident and specialist inspectors generally *
indicate acceptable performance relative to the transportation of
** radioactive materials, the State of South Carolina identified ten * discrepant shipments received at the burial facility in Barnwell, *
South Carolina. The latest of these, identified March 11, 1985
* (outside this current assessment period) caused the State to suspend * the licensee's state radioactive waste transport permit for one year *
and assess a $5,000 civil penalty. Previously, the state assessed
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a $3,000 civil penalty for a discrepant shipment received in Decem-
* ber 1984, and formally notified the ifcensee of a discrepant ship- *
ment received in October 1984. Other deficiencies for the period
* between September 1983 and August 1984 were orally conveyed to the licensee by the State. This indicates that the licensee has not *
been effectively implementing this portion of the program or effect-
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ing sufficient corrective action. Since multiple and repetitive violations were identified, programmatic breakdown is eviden *
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Radioactive waste ma'nagement was not reviewed this period. Effluent
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control and radiochemistry review indicated that the Itcensee was
* effectively implementing the program in accordance with regulatory
. requirement *
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To reduce solid radioactive waste generation, the licensee estab-
* 11shed a corporate performance goal for 1984 of ten percent less *
than the three year 1981 through 1983 average. A sixteen percent
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reduction was attained. The 1985 goal is for a. ten percent reduc-tion from the 1982 through 1984 averag *
- * The licensee has implemented a formal AL. ARA program designed to *
analyze specific tasks and effect dose reduction methods as well
* as to monitor task performance relative to performance goals. Records *
of the effort are generally complete, well maintained and availabl * Reviews of this area indicate that the program is generally effec-
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tive but does not always achieve estabitshed goals. The effective-
",.. , .* " * * ,.., ness of the program has recently been enhanced by a corporate policy . ' *
which make's ALARA goals'the specific responsibility of individual manager *
* Overall, the' 11censee's performance during major projects involving * high levels of radioactivity demonstrated thorough planning and pre- *
paration, good procedure development, and the establishment af ac-captable radiological controls. This was evident for the Unit-2
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Thermal Shield Project and the Unit-1 IHSI/ Weld Overlay, Extraction Steam Line Replacement, and TIP Overhau Adequate management re-
* * view and oversight is usually evident as demonstrated by sufficient * awareness of daily activities, the establishment of generally ef- * factive inter-departmental communications and cooperation, and the * effective use of planning meetings and schedules to reduce personnel exposur <
Steam generator work involving high radiation fields is dis' cussed in the Refueling and Outage Maintenance functional are *
* An adequate staff is available to carry-out the program, and the * personnel involved are qualified and capable of performing satis- ' *
factorily in their assigned areas of responsibility. A formalized
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training program for the radiation protection staff continued to
* be implemented and provided sufficient technical and practical in- *
structicns to assure competence in the organization. The licensee
* also implements a generally effective radiation worker training * program in an effort to assure that radiation workers are aware of radiological safety procedures and are able to implement them com- *
potentl *
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Additionally, the licensee has successfully completed corrective
* actions on several previously identified findings, and has success-fully resolved open items in a timely manne . Conclusion *
Ratino: Category * Recent Trend: Consisten . Board-Recommendations
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Licensee: Continue recent emphasis on improving radioactive mate-
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NRC: Implement full inspection program for all elements of radi-
* ation protection, emphasizing radioactive material transportation a,nd radioactive waste processin .
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L Maintenance (339 hrs., 16%) Analysis P *
* Maintenance received the close attention of both resident and re-
,; k * gion-based inspectors during the assessment period. During the -
* previous two SALP periods, ratings of Category 1 were assigne No areas of general weakness were noted during those periods. The
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i present SALP period included a refueling and maintenance outage extending from the beginning of'the period into January 1984.
g * During mid-1984, the overall maintenance program received a compre-
* * hensive review using a standard NRC Region I audit plan. Job Or-r ders, Maintenance Requests, Licensee Event Reports, Plant Incident *
[ = * Reports, Monthly Operating Reports, and Daily Activities Log were K * audited. No reportable events or equipment failures were disclosed e * which had not been documented as Licensee Event Reports or which
* were missing from the Monthly Operating Reports. Records showed r * no repetitive maintenance activities beyond routine activities such * as valve packing adjustment, lubrication, and cleaning for nine key system * The accuracy and completeness of maintenance documentation * and the close and consistent involvement of supervisors in day-to-day maintenance were noted as particular strength *
a Another aspect of the NRC programmatic assessment involved mainten-
*
m ance personnel. Interviews with maintenance technicians, supervi- =- * i * sors, and Quality Assurance inspectors showed that all had a working A * knowledge of skills necessary to conduct and document maintenance E * evolutions. The involvement of foremen and supervisors in field
* work was found to be consistent and extensive. The maintenance
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* staff is a mix of experienced personnel present since construction,
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* other experienced personnel from aircraft and shipbuilding indus-
" * tries, and newer personnel. A degreed staff engineer is also as- " * signed directly to the maintenance department. The quality of the
* staff and supervision of the maintenance department was found to be a notable programmatic strengt t * * A second programmatic. inspection was conducted during November 1984 by region-based inspectors. The inspection was directed toward h *
post-maintenance and post-modification testing. Inspectors reviewed = *
* 24 safety-related work packages from the Maintenance Department and s
7 packages from the Instrumentation and Controls Department to ver-l '
* * ify correct classification and appropriate post maintenance testin * The program was found to include written procedures, criteria, and responsibilities for post-maintenance testing. The inspection con-
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* cluded that an acceptable program is in place and is being imple-mented.
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o The licensee has a major program to extend the life of the steam generators (SGs). There has been extensive inspection of SG tubes for pitting defects and potential denting. Chemical cleaning and high pressure water lancing are being used to remove metallic sludge
. from the secondary of the SGs. To arrest tube pitting, tighter SG -
secondary water specifications are being established. Also, the licensee is replacing copper bearing alloys in the feedwater syste Resident inspection of this major SG maintenance has identified strong management controls and careful worker adherence to proce-dure < The licensee demonstrated a sensitivity to incipient component de-gradation and to possible generic issues through an aggressive program to improve charging pump performance. Millstone 2 uses 3 positive. displacement pumps as charging pumps and as high head safety injection pumps. After approximately 5000 hours of opera-
. tion, the licensee observed an increase in the pump packing leakage ar.d an increase in the frequency of pump repacking. Consultation with other owners indicated that this was typical. Non-destructive examination of the pump blocks revealed hairline cracks in the pump bores, apparently induced in-service. Destructive evaluation by an outside laboratory did not disclose major internal flaws in the blocks. Although the phenomenon causes increased packing leakage and wear, it does not render the pumps incapable of delivering the -
high head injection flow rates shown to.be needed by safety analysi The licensee reported the generic aspects of his findings per 10 CFR 21. This issue has received the scrutiny of regional metallurgy specialists and the resident inspectors. The licensee continues the initiative to extend pump performance via an engineering de-partment research progra *
* The licensee implemented a corporate-wide maintenance management *
system during the present SALP period. Maintenance is still per-
*
formed to departmental procedures. However, the authorization and
* control documents which have been replaced by a central computer- * ized system, the Production Maintenance Management System (PMMS).
- * The system is used to schedule preventive and corrective maintenanc * It retains the machinery history type of information which had pre-
*
viously been recorded in departmental records. Since each equipment
* is being identified within the centralized and automated system, * machinery history will be available throughout the corporatio * Preventive maintenance may be reviewed based on equipment history *
and revised or re-scheduled based on performance data. The system's
* data base records material and man power usage and is used for re-source management. Maintenance and surveillance may then be pri- *
oritized and schedule .
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* * The resident inspectors observed portions of 26 maintenance evolu-tions for procedural compliance, safety, work ~ practices, and docu-mentation. Additionally, a region-based inspector conducted a de-tailed review of maintenarce pertaining to the Reactor Protective System (RPS) scram breakers. No breakdowns in program implementation were observe * * Procurement practices and storage were examined by a team of region-based inspectors. Two areas of weakness were noted: * shelf-life * criteria for perishable items and control of the storage environment * for low hydrogen stainless steel and nickel welding electrode * Insufficient management involvement is apparent in both case * Concerns regarding shelf-life controls previously arose during an inspection in mid-1982. A followup inspection late in 1983 found - *
only informal controls. Although the licensee fulfilled his com-
* * mitment to establish a more formal program for shelf-life determin- * ation and control, an audit in late 1984 found little evidence of *
actual program implementation. Specifically, shelf-life data had _
* not been requested from vendors and shelf-life had not been evalu- *
ated during QA acceptance inspection. Additionally, the audit
* sample included solenoid valves with shelf-life limitations due to * certain internal construction materials. Although the valves had * been the subject of both a vendor service letter and an NRC Bulletin, * the valve shelf-lifa had not been included in the licensee's progra * Concerns related to the storage of low-hydrogen welding electrodes . *
arose during an inspection in mid-1983. These electrodes are stored
* in ovens at elevated temperature to limit moisture absorptio * Responsibility for calibration of the oven temperature monitors had not been established. The inclusion of these monitors in a regular
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* * calibration program remained outstanding through the end of the *
inspection period. The temperature monitors were apparently over-
*' looked in calibration program revisions and reviews. Together, * these of items program reflect a lack of sufficent attention to the details implementatio g d i The equipment classification program and post maintenance testing -
programs were reviewe An extensive review of safety-related sys- { tems. purchase orders, and Plant Design Change Requests (PDCRs) j resulted in the conclusion that an adequate program to maintain 9 system integrity is in place. The existing Materials, Equipment, t Parts List (MEPL) is being monitored as part of the computer-based 5 Production Maintenance Management System (PMMS). A sample of 31 & i work orders classified as safety-related and 10 work orders classi- i l fied as non-safety-related were reviewed to evaluate proper classi-fication as well as proper specification and completion of post- %
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maintenance testing. The program and its implementation were found - to be well executed and well supported by plant managemen { d! C t U L 4u
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16 Conclusion
* Rating: Category *
Recent Trend: Consisten . Board Recommendation
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Licensee: Improve shelf-life program and storage program for weld-
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ing electrode * NRC: Non .
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. , . '. - . 17 Surveillance (298 hrs., 14%) Analysis ' Surveillance received.the attention of the resident inspectors and region-based specialists. During the preceding two appraisal per-iods, ratings of Category I were applied. No continuing problems or deficiencies have been observed. The resident inspectors ob-served a total of 56 surveillance test * * A master Surveillance Control List correlates surveillances to lic- *
ense requirements and receives PORC oversight. Individual depart-
* mental controls are effectively used to schedule and track comple- *
tion of surveillances. NRC audit of 12 Unit I and 20 Unit 2 tech-
*
nical specifications confirmed timely completion. The plant design
*
change request system requires a positive statement of the need for
* associated changes to operating procedures, surveillance procedures, *
and technical specification The Engineering Department must make that assessment, and PORC must review i NRC audit of 4 Unit 1
* *
and 7 Unit 2 technical specification amendments verified that sur-ve111ance procedures were updated when technical specifications were change (A Unit 2 exception to this was found involving failure
* to update ex-core power range nuclear instruments after a 1975 design change.) Site QA monitors surveillance testing. NRC witnessed one * * QA " monitor" of surveillance on Unit I and reviewed 4 surveillance " monitor" reports by QA. The reports were found to be critical and * *
to reference INPO guidelines. Such reports are forwarded to the
* unit superintendent for action and to the corporate QA manager for trendin A review of the In-Service Inspection (ISI) program and the factors involved in a request for relief from the ASME Boiler and Pressure Vessel Code Section XI requirement for. volumetric examination of reactor coolant pump casing welds indicate a sound technical ap-proach to ISI problems. Staffing, including the Level III Engineer and inspection personnel, appears be adequate for the tasks at han Contractors are used as required for specific tasks and are ade- ' -
quately controlled by the licensee. The ISI program is presently . ! in the last period of the first 10 year inspection interva Re-gion-based specialist inspectors concluded that the ISI program is of superior quality, indicating effective application of quality assurance principles.
' Several innovations have been included in the licensee's program An Example is computer-based vibration analysis equipment. This has provided a higher degree of automation with a more portable -
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vibration spectral analysis unit. Also, seismic piping snubbers , have been tagged to allow recording inspection data with bar code reading equipment. This provides a positive method of traceability of inspection results to individual snubbers and to the time and
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date of inspection. A third example is the use of computer-based ultrasonic data recording and analysis equipment (UDRPS). This is not required by the NRC or the ASME Boiler Presure Vessel Code but has been used as a tool, in addition to conventional ultrasonic testing, to gather significantly more data during non-destructive . examinations of weld I
*
l * Detailed technical review of procedures and, where appropriate,
~*
independent calculation of results of specific aspects of surveil-lance disclosed no significant problems. The aspects reviewed in- - I /t clude Containment Leak Rate Testing, Chemistry, and Radiation Moni-tor Calibratio An example of particularly good performance is the performance of corporate QA audits to provide positive assurance that the In-Ser-vice Inspection (ISI) program at Unit 2 is attaining the require-ments of Technical Specifications. An example of an area of weak-ness is the low level of QA oversight over key activities such as Containment Leak Rate Testing and post-refueling Start-Up Testin . Conclusion
* Rating: Category Recent Trend: Consisten . Board Recommendation *
Non *
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19 l l l Fire Protection / Housekeeping (42 hrs. , 2%) -
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l Analysis
, q * * The licensee has submitted an Appendix R exemption request and no *
Appendix R inspection has been conducted yet. Fire protection and '
* housekeeping received'both resident and region-based inspection * These efforts included a detailed programmatic inspection by a fire *
protection specialist. Because of incorporation of fire protection
* and housekeeping checks in daily resident inspector tours, the *- actual inspection effort expended on fire protection and housekeep-ing is significantly more than the tabulated tota Unit 2 is generally graffiti free. The licensee has made steady improvements in plant housekeepin Management' inspections are conducted both during the operating cycle and, with greater fre-quency, during outages. Strong emphasis is placed on housekeeping during those inspections. Improvements have been made in the auxiliary building during the SALP appraisal period. Several areas within the auxiliary building have been cleaned and painted and sections of the enclosure building have been cleaned. Areas which need to be improved are the enclosure butiding, equipment access hatch area, the auxiliary building refuelin chase area, and the safeguards pump rooms. g water storage tank pipe Along with plant housekeeping, radiological cleaning anii housekeep-ing have held down the number of contaminated areas. The fuel . storage area has been recovered after extensive work was performed in the cask washdown pit to prepare the thermal shield sections for -
shipment. The containment is accessible during a refueling outag Protective clothing is not required except for the loop areas, the lower (-22 foot elevation) penetration areas and the area adjacent to the refueling cavity. Of these, the penetration areas are can-didates for cleaning. Other than these areas, radiation levels are-so low and contaminated areas so controlled that the containment
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may be entered during outages without the need for a Radiation Work Permit (RWP).
'
* * In contrast with the station interior, large yard areas are heavily * cluttered with spare, excess or staged equipment, including a large *
quantity of material labelled as radioactive. This condition has degraded over the appraisal perio *
* Indoctrination in matters pertaining to housekeeping and fire pro- * tection is provided to new employees, and to all employees on an
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annual basis. Formal lesson. plans and multi media instruction methods are employed. Training for Fire Brigade members includes
* * actual fire-fighting at an off-site training center, formal class- * room training, and fire drills (including back-shift drills). Both *
resident and specialist inspectors commented favo~ rably on the ef-factiveness of fire protection trainin * Asterisked lines are common to Units 1 and }
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* * The programmatic inspection included detailed review, licensee meas- * ures to control ignition sources, solid and liquid combustibles, * transient combustibles, and general housekeeping. These were deemed to be adequate. The organization for fire protection was found to *
be adequately staffe There was one violation: penetrations through fire barriers were
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not appropriately seale . Conclusion
* Rating: Category .
Recent Trend: Consisten . Board Recommendation Licensee: Address the cluttered yard condition. Upgrade house-keeping in areas noted as candidates for improvement. Resolve Appendix R implementatio * NRC: Non .
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21 Emergency Preparedness (250 hrs., 11%) Analysis
* ' * The previous SALP evaluation rated ifcensee performance in this area *
to be Category 2 based principally upon the corrective actions not
* being completed for two significant findings noted during the Emer- * gency Preparedness Appraisal conducted on January 4-14, 1982. These * were (1) installation of the High Range Monitoring and Sampling * Systems for the Unit 1 Stack and the Unit 2 Vent, and (2) estab- * lishment of an integrated emergency plan training / retraining program * to ensure that lesson plans are developed and training is accom- * plished for each functional area of emergency activity (including * radiation protection during emergencies, emergency repair / corrective .
actions, search and rescue, and radwaste operations).
* During this assessment period an inspection was conducted on Febru-ary 21-24, 1984. At that time, it was noted that corrective actions * * were complete on Item (1); however, the " Emergency Preparedness * Training Program" for Item (2) was only prepared in draft format, * but contained a revised training lesson plan format and testing requirements. The training of the emergency response personnel with * * the new program was scheduled to be completed by June 30, 198 *
Re-inspection of this area has not yet been completed. However,
* it does not appear that the final documentation of the Emergency * Preparedness Training Program received adequate management attention since the time to correct the item exceeded two year * *
The licensee conducted a full scale emergency exercise on October
*
5, 1983, and another full scale exercise on October 12, 1984. The
* licensee's execution and participation in both of the exercises was * considered to be satisfactory as evaluated by the NRC inspection -
team. No major discrepancies were noted and the improvement items
* *
observed in 1983 did not recur during the 1984 exercise. It was ,
*
also noted that the corr' ctive e actions described by CAL 84-10 dated l
* June 5, 1984, issued after the May 12, 1984 Haddam Neck exercise, had been completed prior to the October 12, 1984 Millstone exercis * * During 1984, a temporary Technical Support Center (TSC) was estab- * lished within the Millstone EOF as a result of a lack of space in
,
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the reactor buildings. A new TSC for the Millstone site is being
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constructed as a part of Unit 3 and is scheduled to be available ' for the 1985 emergency exercise.
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* * The licensee has been responsive to NRC initiatives and acceptable
* responses were generally proposed with the exception of the training i
item noted abov .
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, * * The licensee's onsite emergency preparedness staff consists of one *
full time coordinator. At least two contractor personnel have pro-
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vided assistance during the past year. Corporate personnel are available as required to support emergency preparedness activitie , . Conclusion
. * Rating: Category *
Recent Trend: Consistent Board Recommendation
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Licensee: Evaluate measures for assuring timely completion of action
* , item , *
NRC: None.
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i Security and Safeguards (62 hrs., 3%)
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Analysis
. ' * * During the assessment period, there were two routine physical pro - *
taction inspections by region-based inspectors. Routine resident ,
- inspections continued throaghout the period.,Two Level IV violations
* *
were identified by a region-based inspector and one Level IV viola-
*
tion was identified by a resident inspector. The violations were
- * administrative in naturel Corrective actions were accomplished im- '
mediatel Similar violations did not recu *
*
Management attention to the security program has been evident and
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* has focused on insuring security effectiveness at the operating ' * units while maintaining separation between the operating units and * the unit still under construction. The licensee plans to bring all * three units under one multiple unit site security program in Decem-ber 1985. Both site and corporate management personnel are directly *
i * involved in this project and in planning for the increased security
* staffing necessary to support the expanded program. Other activi-
* ties involved include system and equipment turnovers, integration
,
*
of existing and new systems and monitoring the installation and i i
*
completion of barrier construction and related modifications. The
* smoothness with which these activities are being accomplished is
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* indicative of management involvement in the planning, scheduling and coordination of the projec * *
The licensee was in the process of modifying and submitting an in-
*
tegrated Site Security Plan and a Unit 3 Low Enriched Fuel Protec- !
*
tion Plan to the NRC. These plans were scheduled to be resubmitted
' in April 1985. The two plans were reviewed on site by a region-
*
- * based inspector for overall content and compliance with NRC regula-
*
tions and were found to be generally consistent with the spirit and
*
intent of the regulations. However, a detailed review of the plans l by NRC/NMSS remains to be conducte * ,
*
A comprehensive corporate security audit program continues to be a strength of this licensee and it demonstrates the licensee's com-
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mitment to a quality security program. Audits are conducted on
* portions of the Security Plan, Safeguards Contingency Plan and
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Training and Qualification Plans throughout the year such that the '
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overall audit pro ^ gram is completed by year's end. The in-depth
* scope of the audit program which uses both USNRC Inspection Proce- * dures and licensee requirements has contributed to reducing inci- *
dents of non-compliance especially during the later portion of this assessment perio This performance improvement is particularly
* *
significant in light of the fact that two major outages occurred during this perio >
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* * The licensee obtained a new security force contractor during this period. The transition went smoothly and satisfactory performance *
was sustained through the changeover and subsequent perio *
* The event reporting system is consistent with NRC requirement * The licensee reported a total of thirteen security event reports *
during this period. Ten of these resulted from computer and/or multiplexer system failures. A potentially unmonitored access path
* *
into the protected area was discovered and reported. One event was
* caused by a failed door alarm switch and one involved a security * officer who was inattentive to his duties. The reports were timely
_and generally complete. Improvement in the qualit
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to include greater details is, however, necessary.y For of the reports example,
* event report 85-001, pertaining to both Units 1 and 2, stated that *
alarm capability had been lost on a locked security door. The re-
*
port failed to describe the type of door (it was not a standard
* personnel door), the area involved, results of a search to identify *
possible tampering, or other material facts needed to determine the significance of the event. More recent reports hav.e, however, shown
*
improvement in the scope of details discusse *
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Security organization staffing is currently adequate to meet the
*
existing security program requirements. Staffing plans and funding
* to meet expanded site needs for inclusion of Unit 3 are already in l place. Additions to the security force are already being made.
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Both corporate and site security management representatives are
* directly involved in assuring the application of quality training and qualification standards for existing and new employees.
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* A potential training weakness in Secondary Alarm Station operations * involving its primary function was identified by an NRC inspector *
early in this period. The ifcensee immediately initiated remedial training to correct the potential deficienc . Conclusion l I
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Ratino: Category * Recent Trend: Consisten , Board Recommendation
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Non .
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25 Refueling and Outage Management (148 hrs., 7%) Analysis This area had been rated Category 1 during the previous SALP perio .' Improvements were noted during the 1983 refueling outage. That outage increased significantly in length and complexity after dis-covery of a. failed reactor vessel thermal shield. The challenge presented by the thermal shield failure was aggressively met by the licensee's management and staff. Special computer-controlled remote milling equipment was designed and developed for the removal pro-cess. That process was complicated by requirements to work under-water for shielding from intense (40,000 R per hour) radiation sources. Since the work was initially started in the refueling , cavity, controls were implemented to maintain water quality and to
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protect the reactor vessel and reactor coolant system from debri A small amount of debris of this type poses a significant threat to the nuclear. fue The installation of steam generator nozzle dams during the 1983 re-fueling outage had been accompanied by problems which demonstrated poor overall coordination and lack of integrated testing prior to assembly in areas of high (30 R per hour) radiation fields. Sig-nificant improvements were made to the entire nozzle dam system and to the installation training conducted for radiation workers. Modf-fications provided.means of testing the seal air inflation systems
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prior to entry into high radiation areas and greatly simplified the installation process. The radiation workers for the 1985 refueling outage were provided with a high quality installation training nro-gra Training lectures included a video tape demonstration and the use of new steam generator mock-ups which included the tent areas and all obstructions within those areas. These modifications demonstrate that the licensee has examined each detail of the in-sta11ation process, including problems experienced'in 1983, and in-i plemented modifications which greatly improved the system. The ( effectiveness of these improvements is indicated by the radiation
- exposure expended in 1985. This was one-fifth of the exposure ex-
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perienced in 1983. A major factor in the reduction was the assign-l ing of direct responsibility for improvement to a single senior - engineer. He was tasked with resolving all 1983 deficiencies and making other improvements considered to be necessary.
' The inspector observed a high level of professional conduct and performance by craft personnel assigned to the actual effort of in-stalling the nozzle dams in 1985. It is the inspector's opinion i that this occurred because of a professional working relatior) ship that developed during the radiation worker mock-up training program between the workers and station engineering and radiation protection personnel. The workers were walked through each detail of the in-I sta11ation procedure by craft supervision. Those individuals per-i
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formed to the standards expected when directing a person within a confined area with significant radiation fields. There was excel- , lent coordination of responsibilities between the craft personnel, l radiation protection technicians and the project engineers. Steam l generator entries had to be limited to from three to five minutes for purposes of exposure control. Personnel performed their tasks within these times, which include entry and exit through a small manwa ,
* * The licensee has committed personnel and financial resources to computer based outage planning. The dstail provided by these sys-
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* tems has proven to be a key ingredient in successful outage plannin .
* Schedules for activities are interfaced and analyzed by the computer,
* which provides schedules along a critical path, identification of
* near-critical activities, and schedules for activities in certain ,
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areas of the plant and by organizations supporting the outag As is evident from the planning for and conduct of the current re-fueling outage, the licensee's performance in this area has shown recent improvemen . Conclusion
*
Ratino: Category j
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Recent Trend: Improvin ' Board Recommendation
*
Non .
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27 Licensina
' Analysis In general, the licensing functions for Millstone Unit 2 are pro-perly carried ou The licensee exhibits a willingness to be re-sponsive and to improve performance. Better coordination of lic-ensing activities to avoid late responses should be pursued. There were delays in getting responses to some licensing action The basis for this appraisal was the licensee's performance in support of ifcensing actions that were either completed or had a significant level of activity during the current rating perio These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions. (Speci-fic' licensing actions are tabulated at the end of this functional area.)
The licensee's management and its staff have demonstrated sound technical understanding of issues involving licensing actions. For the majority of licensing actions, the licensee's submittals are technically sound, thorough, and well referenced. They generally exhibit conservatism when considering safety significance. During the review of the Technical Specification change authorizing the use of the temporary equipment hatch door, the licensee indicated
'a clear understanding of the associated safety and licensing issue Care had been taken in the design of the door as well as in the development of administrative controls to govern its use. Similarly, the licensee's request for relief from Volumetric Examination to AMSE Code Section XI on welds of the cast stainless steel reactor coolant pump casing was found to be adequately prepared and state The reviewer for the snubber Technical Specification change found .
the licensee's staff technically competent, responsive, and willing ! to clarify outstanding snubber issues. In resol.ving the environ-i mental qualification of electric equipment important to safety, the l' reviewer stated that the licensee demonstrated a clear understanding I of issues and provided technically sound and thorough approaches to the resolution of equipment qualification deficiencies in almost
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, i all cases.
. The licensee's responsiveness appears to vary widely on different i t technical issues. For example, questions concerning the technical specification change or snubbers was promptly clarified by the lic-ensee via conference calls and prompt submittals. Likewise, for the review of the containment equipment hatch door, arrangements for the on-site inspection of the door were made promptly by the , licensee along with prompt response to the reviewer's question However, other licensing actions have not received the same degree of responsiveness. An example would be the delay in getting a re- . sponse from the Itcensee on the Pressurizer Level Band. Other is-
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sues such as the Control of Heavy Loads took considorable time to close a number of open items. The request for additional informa-tion on a number of items such as NUREG-0737 Item II.E.4.7 "Contain-ment Isolation Dependability," NUREG-0737 Item II.F.2.3 " Inadequate Core Cooling Instrumentation," and Degraded Grid Voltage Procedure were late and/or incomplete and required additional submittals. The NRC reviewer's efforts to resolve the control room issues on fire protection required the licensee to make a number of submittals with some requested information not always provided in a timely manne The licensee does, however, exhibit a willingness to be responsive as evidenced by the number of briefings given to the staff. Ex-amples include briefings on fuel leakage, spent fuel disposition
' plans and chemical cleaning of steam generators. These briefings have been very thorough and well received by the staf During the present rating period the licensee's management demon-strated active participation in licensing activities and kept abreast of all current and anticipated actions. During the review of Item II.B.3.2 of NUREG-0737, " Post Accident Sampling Modifica- -
tion," there was consistent evidence of prior planning and assign-ment of prioritie However, management control of the " PTS Curve Changes" was not as rigorous. This submittal, although technically sound, was late. In general, the submittals reflect good quality and proper management control to assure quality. However, responses to staff questions need to receive more management control to as-
, , sure timely submittal .
During the appraisal period the licensee lost at least two licensing staff personnel who were directly involved with Millstone Unit The licensee's current level of staffing appears to be adequate and the caliber of personnel is excellen *
*
In summary, licensee performance was good overall, but with recur- , rent response timeliness problems.
! j Conclusion !
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Ratino: Category * , i Recent Trend: Consistent.
- Board Recommendation
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Licensee: Improve management of licensing activities to avoid late
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responsos. Improve coordination of activities with NRR in regard
*
to schedula, prioritization, and project status, t C N,R,C: Non .
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* Asterisked lines are common to Units 1 and _ _ _ _ _ . . _ _ _ _ . _ . . _ . ._ _ __ - _ .. . . _ _ _ _ _ __ , . ' . . *
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i TABULATION OF LICENSING ACTIVITIES 31 Multi-Plantactions(9 completed). Included in this category are:
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,
--
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Control of Heavy Loads (C-10) Technical Specification Surveillance for. Hydraulic / Mechanical Snubbers (B-22
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and B-17)
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Environmental Qualificiation of Electrical Equipment Important to Safety (B-60) 32 Plant-Specific actions (20 completed). Included in this category are:
-- --
Relief from Inservice Inspection Requirements
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Pressurizer Level Band PTS Curve Changes -
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Cycle 6 Reload
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SG Tube Sleeving
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Measurement Uncertainties
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Outage Equipment Hatch Door e i -- Fire Protection (in progress) 23 TMI (0737) actions (9 completed). Included in this category are:
-- -- Item II.F.2.3, Inadequate Core Cooling Instrumentation (F-26) (in progress)
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-- Item II.E.4.2, Containment Isolation Dependability (F-19) (in progress)
Item II.B.3.2, Post Accident Sampling Modification (F-12)- * i .
l r e I i G
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- .* - - - --- .-n--,,,._ _ _ .n , . , , , __, ,_,,.,,.m ,,----.,--,-----.__.w.,._...,,, ------e.., _ . . . , - . ,
_ - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . . _ _ __ ____ .___ __ __________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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! SUPPORTING DATA AND SUMMARIES
' Investigations and Allegations Review I
There have been no investigations conducted at Millstone Unit ' i One allegation was made by a former employee of a contractor after leav- ' ing the site. That allegation reported general information concerning ! drug and/or alcohol abuse at Unit 2 and another reactor licensee by en-ployees of an on-site sub-contractor. Individuals who may have been in- < volved were not identified. The NRC inquiry failed to identify any cor-1 roborating information. The licensee has a drug and alcohol abuse pro-gram in place. That program is suported by the station security personnel - i and program , Escalated Enforcement Actions ' l i Civil Penalties
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,Non ,
i , 4 Orders !
i An order was issued on December 14, 1983 to confirm the implemen-
' tation schedule for outstanding items within the TMI Task Action Pla . An order was issued on June 14, 1984 to confirm the implementation schedule for outstanding items within the TMI Task Action Plan con-cerning emergency response planning.
' Confirmatory Action Letters l Non I
1 Manaaement Conferences
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Non . ! !
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,.,.3 --- __--. ,_ , , ~ _ _.,,,,._.._,,,.____.______m,
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, j Licensee Event Reports u l Tabular Listine
; Troe of Events: . !
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(A) Personnel Error 7 '
- Design / Man./Const./ Instal ;
) External Cause 1
i Defective Procedure 1 .
(E) Component Failure 16 ;
(X) Other 6 '
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TOTAL 39 ' ! Licensee Event Reports Reviewed: ' Report Nos. 83-26 to 85-02, including 13 Security and 5 Environ- f
- mental Reports common to both Units 1 and t
, Causal Analysis Seven sets of common mode events were identifie The first two are site-related, common to Units 1 and 2:
: There were eleven reports which involved the failure'of ' station -
security equipment. The predominant failures involved the ! i security process computers and their communications Ifnk
- multiplexers (Security Reports 83-05 and -06; LER's 84-01,
-02,-10,-13,-14,-16,-20and85-01,-01). ., There were five reports which involved the detection of radio-nuclides in shellfish or aquatic flora gathered within 500 feet of the discharge into Long Island Sound, of which the concea- '
trations exceeded the control station average by greater than
.
a factor of ten (Environmental Reports 83-04, -05, and -06; j' !
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LERs 84-03, and -07). The licensee has evaluated this as not ' significant and has submitted a request for a change to the reporting requiremen ' i Personnel error contributed to the cause in five plant-related events (LERs 83-28, 84-03, -07, -08 and 85-01). : ' , ' One report addressed five pipe restraints which became under-
sized when schedule 40 pipe replaced standard wall pipe (LER 83-31). , l'
; . One report addressed excessive containment leakage through i l : fourteen containment isolation valves (LER 84-05).
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32 Licensee Event Report Analysis An analysis of Licensee Event Reports (LERs) indicates a consistent level of performance. However, because 10CFR 50.73 redefined the requirements for submitting an LER, there was a change to the data base on January 1,198 ,
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The ratio of personnel-related events to facility-related events increased from 0.21 in the last SALP cycle to 0.28. The " typical" PWR ratio from NUREG/CR 2378 is 0.26. This ratio reflected person-nel errors associated with transporting loads over irradiated fuel, improper safety injection tank level indication and missing sur-veillance test The ratio of management related events to facility events decreased from 0.24 in the last SALP cycle to 0.19. This compared favorably to the " typical" PWR of NUREG/CR2378 with a ratio 0.2 .
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TABLE 1 TABULAR LISTING OF LER's BY FUNCTIONAL AREA
% MILLSTONE NUCLEAR STATION. UNIT 2 AREA ,
NUMBER /CAUSE CODE TOTAL Plant Operations 1/A 3/B 1/X 5 Radiological Controls 5/X Maintenance & Modifications 1/A 2/B 1/D 1/E 5 Surveillance 1/A 1/8 1/C 4/E Fire Protection / Housekeeping 1/A 1/B 2 Emergency Preparedness 0 Security & Safeguards 2/A 11/E 13 Refueling & Outage Management 1/A 1/8 2 Licensing Activities _0 TOTAL 39 Cause Codes A - Personnel Error B - Design Manufacturing, Construction or Installation Error C - External Cause 0 - Defective Procedure '
*
E - Component Failure X - Other
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e b S # $
e * <
s
, _ _ _ __ . _ _ _ _ _ _ _ _ _ _ _ _ _ ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .
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34 ' TABLE 2 INSPECTION HOURS SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION, UNIT 2 Hours % of Time Plant Operations 748 35 Radiological Controls 271 12
, C. Maintenance 339 16 e D. Surveillance 298 14 E. Fire Protection / Housekeeping 42 2 F. Emergency Preparedness 250 11 G. Security and Safeguards 62 3 H. Refueling and Outage Management 148 7 I. Licensing Activities not considered TOTAL 2158 100
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TABLE 3
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VIOLATION SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION , UNIT 2 I Number and Severity Level of Violations Severity Level I 0 Severity Level II 0 Severity Level III 1 Severity Level IV 6 Severity Level V 2 . Deviation _ 1
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TOTAL 10 Violation by Functional Area Functional Area Severity Level I II !!! IV V OEV Plant Operations 1 Radiological Controls 1 1 Maintenance & Modifications 1 Surveillance 1 Fire Protection & Housekeeping 1 1 Emergency Preparedness Security and Safeguards 3 Refueling and Outage Management Licensing Activities Totals 0 0 1 6 2 1
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. Summary Inspection Inspection Severity Functional Report N Dates Level Area Violation
*S3-23 9/26-30/83 IV 7 Failure to control security key '
o . IV 7 Failure to acknowledge
'O security alarm /27-27/84 IV & 2/15/84 3 Failure to control a design change and supply proper procedures and drawing /11-15/84 IV 4 Failure to perform surveil-Iance of fire detection instrument IV 5 Failure to provide three- .
hour fire barrier between zones of switchgear room Deviation 5 Sleeves not provided for fire protection piping at
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butiding internal wall /24-26/84 V 1 Failure to follow procedures for fuel storage building integrit /14-2/24/85 V 2 Failure to follow radiation
, protection procedure o IV 7 Failure 'to maintain a clear isolation zone.
- 85-04 28/84 III 2 Failure to control free standing liquid in a solid waste shipmen .
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CAsterisked lines are common to Units 1 and l
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TABLE 4 REACTOR TRIP AND OUTAGE SUMMARY (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION. UNIT 2 UNPLANNED AUTOMATIC SCRAMS QATE POWER LEVEL CAUSE /11/84 Reactor trip from 15 percent Low steam generator level result-powe ing from a transient in manual control which took place during , system alignmen . 11/15/84 Reactor trip from 100 percent Thermal margin / low presssure trip powe resulting from main steam iso-lationvalve(MSIV) closur MSIV actuator piston seals failed due to agin . FORCED OUTAGES QAI{ , , POWER LEVEL CAUSE /13-18/84 Shutdown from 100 percent Reactor Coolant System resistance power, temperature detector response times greater than allowe . 11/28-29/84 Shutdown from 100 percent Low pressure feedwater heater powe tube ruptur .
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TABLE 5 INSPECTION REPORT SUMMARY (9/1/83 - 2/28/85)
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MILLSTONE NUCLEAR STATION. UNIT 2
' Report Number Inspection Insnector(s) Hours Areas Inspected 83-22 221 Emergency preparedness exercis (Specialist &
Resident) 83-23 27 Station security program and implementatio (Specialist) , 83-24 22 Special inspection of fuel cladding failures and (Specialist) manufacturing / design error Routine inspection including activities during ex-(Resident) tended refueling / maintenance outage, removal of reactor core support barrel thermal shield, steam generator tube sleeving and plugging, service water system improvements, fuel assembly and radiation protectio .
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83-26 65 Routine inspection including activities during ex-(Resident) tended refueling / maintenance outage, steam generator welded tube plug repairs, milling crack-arresting holes in reactor core support barrel, modifications to the Emergency Safety Features Actuation System (ESFAS), and spurious initiation of ESFA .5 Quality Assurance Program including Category I (Specialist) storag ' 55 Radioactive effluent control and monitorin (Specialist) . 83-29 55 Routine inspection including reactor refueling and (Resident) surveillance program implementatio CANCELLED 83-31 23 Preventive maintenance and surveillance of RPS trip -
(Specialist- breaker ,
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Resident) 84-01 160 Routine inspection including containment integrated (Specialist- and local leak rate testing, reactor startup and Resident) power ascension testing, partial actuations of ESFA *
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Report Number Inspection Inspector (s) Hours Areas Inspected 84-02 15 Special inspection-two RPS channels partially in-(Resident) operable when nuclear instrumentation detector cables were reverse (Specialist) Special inspection of quality assurance as applied to computer codes used in reactor analysi i 84-04 126 Routine inspection including RpS RTD operabilit (Resident) 84-05 30 Emergency Preparedness Progra (Specialist) 84-06 31 (Specialist) Radioactive material packaging and transportfo Routine inspection including the RCS high point (Resident) vent modification, liquid effluent radiation monitor (Specialist) Nonradioactive chemistry analysis including quality control of analytical measurement . . 84-09 88 Post-accident monitoring equipment installations (Specialist) made to implement a Confirmatory Order dated March 14, 198 . Routine inspection including control rod drop, re-(Resident) - placement and investigation of a charging pump block and Rp5 trip breaker preventive maintenanc .5 (Specialist) Quality Assurance for design, installation and opera-tion of PAS Routine inspection including actions taken following (Resident)
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a control rod drop and removal of fuel pin end caps for metallographic analysi Radiation protectio (Specialist) 84-14 15 Station security program and implementatio (Specialist) 84-15 19 Fire protection / prevention program including admini-(Specialist) stration, equipment maintenance and survet11ance and fire brigade trainin . I I L
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Report Number Inspection : Inssector(s) Hours Areas Inspected ' i i 44-16 ! 8 Repeated cracking of the charging pump blocks, (Specialist) i r
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84-17 20 Inservice inspection program including licensee (Specialist) ': requested relief from reactor coolant pump cast : stainless weld examinations, 84-18 70 Routine inspection including licensee response to f
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(Resident) control rod drop incidents and review of previously I reported open item Administration of NRC licensed operator examinations !
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(Licensing Examiner) and review of requalification training progra j 84-20 140 Routine inspection including licensee response to (Resident- control rod drop incidents and maintenanc Specialist) t
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84-21 73 Routine inspection including licensee response to t
; (Resident) control rod drop incidents, a potential primary to '
secondary steam generator leak, the reconstitution !
- -
of irradiated reactor fuel assemblies, and followup !
* on* radioactive waste shipment problem l 84-22 2 Radiation protection including fuel reconstitutio (Specialist) ('
:
84-23 54 Special inspection of NRC Generic Letter 83-28 for (Specialist) equipment classification and vendor interfac t
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t 84-24 8 Routine inspection including licensee response to
.(Resident) i reactor trip from MSIV closute, manual reactor trip i ' because of flooded feedwater heater, operability of '
feedwater check valves, fuel reconstitution, and Type 13 radioactive waste shipment (53,600 C1). l 84-25 29 Routine inspection including performance of RpS (Resident) and safeguards instrument isolation device [
'e 84-26 19 Licensed operator requalification including the ad- I (Licensing Examiner) ministration and grading of one section of the re- ,
qualification examination, and walk-throughs for 12 . licensed operator None Administration of NRC Itcensed operator examination (Licensingexaminer) ,
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Report Number Inspection Inspector (s) Hours Areas Inspected 85-01 122 Inspection of Bulletins concerning as-bull' seismic (Specialist) pipe restraint and base plate stress analysis and
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valve weights used in stress analysi .5 Quality Assurance Audits, Surveillance and Monitor ' E5-03 65 Routine inspection including preparations for a (Resident) refueling / maintenance outage, and of cycle power coastdo'wn reactor limitations, error to input para-meters of small break Loss Of Coolant Accident e analysis, potential unmonitored radioactive release to the sanitary sewer system, compliance with 10 CFR 50.54 for a senior reactor operator in the Control Room, and review of actions taken in response to NRC Bulletin 84-03, Reactor Cavity Seal Failur ' Radioactive waste shipment deficiencie tate of South Caro $ na)
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d e D l e t
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! TABLE 6 LER SYN 0pSIS (9/1/83 - 2/28/85) MILLSTONE NUCLEAR STATION, UNIT 2
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LER N Summary Description 83-26 Mechanical damage to two fuel assembly upper end fitting component Pressurizer safety valve failed to open at the required set poin pound load transported over irradiated fuel assemblie Lack of seismic support for tubing associated with containment wide range I pressure instrument Potential seismic degradation to Enclosure Building Filtration System during fuel movemen Five pipe restraints became undersized when schedule 40 versus standard wall pipe was installed in portions of the service water syste Failure of emergency diesel generator load sequence Power Operated Relieve Valve Seat leakage due to foreign materia *ETS83-04 Ag-110m and Co-60 in oysters, gathered within 500 feet of discharge, in
.
levels greater than the control station by a factor of te *ETS83-05 Co-60 in aquatic flora, gathered within 500 feet of discharge, in levels
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greater than the control station by a factor of te SETS 83-06 Co-60 in oys.ters, gathered within 500 feet of discharge, in levels greater than the control station by a factor of te *SEC83-05' Security-related computer failure, loss of alarm surveillanc *
., SEC83-06 Security-related computer failure, loss of alarm surveillanc Two ESAS actuations with the reactor in Mode Reactor Scram, low steam generator leve '
84-03 Low level in two of four Safety Injection Tanks due to water in dry reference leg ' 84-04 Thermal margin / low pressure reactor trip inoperable in two of four RPS channels due to reversed nuclear instrument detector cable .
. * Asterisked lines are common to Units 1 and . . . - _ -_ _ _________________ _____________ _________________________ ____ ___-_ -____________________
. .. .. . . .. . _ . . * l .I s . I*
> LER N Summary Description 84-05 Local leak rate in excess of specified due to leakage through 14 valves in closed cooling water and containment sump penetration Reactor Coolant System temperature sensing RTD response time in' excess of allowe ~ Missed monthly surveillance of Thermal Margin / Low Pressure tri Fire Protection - NRC audit found missing surveillance of detectors and fiberglass pipe breaching fire barrier between switchgear room Improperly rated fire protection door between 480 volt switchgear room Failure of spent fuel storage area radiation monitors on three occasions because of defective photomultiplier tubes, in each case three of the four installed monitors were operabl Reactor Trip - Thermal margin / low pressure function resulting from a MSIV closur Manual Reactor Trip to protect turbine from damage due to water flooding the extraction steam system following tube ruptures in a feedwater heate $84-01 Securi,ty-related, multiplexer failure, loss of alarm surveillanc *84-02 Security-related, computer failure, loss of alarm surveillanc *84-03 Ag-110m in oysters, gathered within 500 feet of discharge, in levels greater than the control station by a factor of te Security related, discovery of potential unmonitored access into the protected are Co-60 in aquatic flora, gathered within 500 feet of discharge, in levels
' greater than the control station by a factor of te ' *84-10 Security-related, computer failure, loss of alarm surveillanc Security-related, multiplexer failure, partial loss of alarm surveillanc Security-related, multiplexer switch failure, loss of alarm surveillanc *84-16 Security-related, compuur failure, intermittent loss of alarm surveil- ,
lanc .
* Asterisked lines are common to Units 1 and . . . . . - - - - _ - - - - 1
-___ - _ _
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LER N Summary Description
$84-19 Security-related, guard not performing dutie $84-20 Security-related, multiplexer failure, partial loss of alarm servet11anc Error in assumed parameters for small break LOCA analysi Security related, failed vital area door switc Security related, computer failures, intermittent loss of alarm sur-veillanc .
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* Asterisked lines are common to Units 1 and ]
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3 g as%, EliCLOSURE 5 ,
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%o UNITED STATES NUCLEAR REGULATORY COMMISSION
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$ ,I REGION 1
c 631 PARK AVENUE
***** ,e KING OF PRUSSIA, PENNSYLVANIA 19406 Docket Nos. 50-213; 50-245; 50-336 MAY 2 01985 Northeast Nuclear Energy Company ATIN: Mr. J. F. Opeka Vice President - Nuclear .
Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP) For the eighteen month period ending February 28, 1985, performace at Haddam Neck, Millstone 1 and Millstone 2 have been assessed by NRC SALP Boards. The associated SALP Board Reports for each facility are enclosed. Comments relative to the per-formance of each facility have been included by the Board in each report; the overall performance of Northeast Utilities will be addressed after we have had the '
.
opportunity to discuss with you the Boards' assessments and pertinent comments identified by you and your managers.
f To discuss these SALP Boards findings, a meeting has been scheduled at the Mill-stone site at 8:00 a.m. on Tuesday, June 4, 1984. At that meeting, please be pre-pared to discuss your program for self-identification of problems and self-appraisal of activities in addition to any other regulatory matters affecting your performance that you wish to addres Within 30 days after the SALP meeting, please reply in writing to the SALP Board's findings. That reply should describe your plans to respond to the SALP Board's recommendation It also may include any comments you.have on the SALP Reports or the SALP program. After your reply is received and evaluated, we will supple-ment the SALP reports (if appropriate), transmit the SALP Reports to you, and place the SALP R6 ports and your reply letter in the NRC Public Document Room Your cooperation with us is appreciate
Sincerely, f Thomas E. Murley Regional Administrator Enclosures: Haddam Neck SALP Report 50-213/85-99 Millstone Unit 1 SALP Report 50-245/85-99 Millstone Unit 2 SALP Report 50-336/85-99 Northeast Utilities Letter 811411 dated 3/22/85 . O l
~ < *
a, . ' Northeast Nuclear Energy Company 2 MAY 2 01985 cc w/encls: E. J. Mroczka, Vice President W. D. Romberg, Millstone Station Superintendent R. Graves, Haddam Neck Plant Superintendent D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing Gerald Garfield, Esquire
.
Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector, Millstone Units 1 and 2 NRC Resident Inspector, Haddam Neck State of Connecticut bec w/encls: Region I Docket Room (with concurrences) Senior Operations Officer (w/o encls) DRP Section Chief D. Holody, RI T. Murley, RI J. Taylor, IE SALP Board Members
.
G
* ~ ' * ' , - .' ' - ENCLOSURE 6 ' ' ' NORTHEAST UTIUTIES ""* ' * "" S"" 8 " 8"" " C "" *" ****"**"2"**""",*"," l 5 P.O. BOX 270 l .,,,,,,,,,,,,,,ca,,
HARTFORD. CONNECTICUT 06141-0270 g semesr urures an=ca co
.amest usa eco, cow- (203) 666-6911 -
March 22,1985
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Docket Nos. 50-213 50-245 50-336 B11411 Mr. R. W. Starostecki, Director SALP Board Chairman Division of Project and Resident Programs U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Lester Rubenstein, Assistant Director Core and Plant Systems Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Warren Minners, Chief . Safety Program Evaluation Branch Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission - Washington, D. C. 20535 Gentlemen: , Haddam Neck Plant, ' Millstone Nuclear Power Station Unit Nos. I and 2 i Systematic Appraisal of Licensee Performance As you are no doubt aware from previous meetings with us regarding the SALP , program, Northeast Utilities (NU) places high priority on achieving excellence in ) ' our endeavors. Category I ratings in all areas of activity evaluated by that program would represent one signal that this goal is being realized. Our commitment to strive for Category I ratings originates from NU executive i management and is one element of our primary corporate objective of striving for excellence in the maintenance of nuclear safety. Given the scope and depth l of SALP reviews, achievement of superior ratings provides an indication that our management controls are functioning properly. Ratings lower than Category I identify potential areas for improvemen In the past, SALP meetings have occurred subsequent to publication of the initial NRC SALP report. As a result, we believe that the initial reports have at times failed to take into account pertinent information and otherwise could have been ! strengthened by an exchange between ourselves and the NRC. To minimize the chances of this situation. recurring, we are taking this opportunity prior to the - l &5 % C '%'l N f .
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convening of your SALP Board for our three operating nuclear units to offer some of our perspectives on our level of performance during the past month We believe that doing so may prove useful in your deliberations. We are addressing this document to you in your respective capacities as lead SALP
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participants (SALP Board Chairman, or NRR Senior Executives) for our
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facilitie ' Generally, we believe that the nine functional areas in which the NRC has chosen to evaluate license performance will provide an overall perspective of our operations. However, an evaluation of these areas exclusively does not, in our opinion, comprise the universe of those factors which should be considered in > ' assessing " licensee performance." Perhaps the most significant factor which we believe should be considered and which is not reflected in the nine functional areas is the extent to which a licensee attempts to further the depth and quality of the exchange with the regulators, both in terms of interacting with the NRC and participating actively in efforts to disseminate needed information to industry. NU has consistently adhered to the view that we are obliged to voice ! our disagreement with NRC on any issue involving public health and safety when I we believe such disagreement is justified. We do so in the interest of further i ' improving the regulatory process and assuring that through discussion and debate, all aspects of a proposed action are understood and considered by both NRC and NU. We sense that on occasion this corporate philosophy may have disturbed certain NRC reviewers. However, we do not believe that this philosophy should be counted against us in your SALP evaluation. On the
!
contrary, we believe it necessary and appropriate for us to vigorously interact with the Staff as necessary to ensure that public health and safety is maintained, , particularly given the finite resources at the disposal of both NU and the NRC.
i Examples of some of our attempts to further improve the quality of the regulatory process are enumerated in Attachment (1) to this letter. Many of them have their focus on providing the regulators with an opportunity to become ! more familiar with our plants, procedures and personnel. They are far ranging in scope, involving executive management down through the working level. Our former Chief Executive Officer (CEO) is the current chairman of the board of the Institute of Nuclear Power Operations (INPO). Northeast Utilities executive ' management is extremely active in numerous industry initiatives, having made several presentations at public meetings before the Commission as well as meeting with individual Commissioners where appropriate. NU management personnel are extremely active in, and in many instances chair, various industry
.
groups which are addressing a broad range of nuclear issue Regarding day-to-day activities, our licensing staff attempts to be very responsive to the NRC licensing project managers (LPMs). We attempt to respond to verbal inquiries quickly and accurately, arrange for all necessary meetings and/or conference calls, help the LPMs locate previously docketed material, and provide express mail service for both incoming and~ outgoing correspondence as circumstances require to ensure that priority issues are given priority treatment. We believe that the recent briefings conducted by the new NRR Division of Licensing Director support the above perspective.
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-3-Another element of our corporate efforts to achieve excellence which may not be reflected in the nine functional categories NRC evaluates as part of SALP is the extent to which actions are implemented following a SALP evaluation in order to improve a licensee's level of performance. Examples of these activities which have occurred since the most recent SALP report for our operating nuclear facilities are provided in Attachment (2) to this submittal. Again, it is
,
not all inclusive, but is illustrative of our commitment to strive for excellenc We note that this letter focuses exclusively on those activities which we believe are relevant to the SALP process and which, based upon our knowledge of the process, may not otherwise be fully considered. The fact that many other pertinent issues and documents are not discussed herein is not to suggest they are less importan We are aware that the NRC has developed procedures for the conduct of the SALP process and has acquired considerable experience over the last several years in performing SALP evaluations. In the spirit of further Improving the process, we urge you to consider the areas of activity discussed above, as supplemented by the Attachments to this document. Further, we invite you to ask any questions which may arise during the conduct of the SALP evaluation for our facilities in the interest of eliminating points of confusion and enhancing the overall quality and depth of the SALP evaluation proces ' Feel free to contact us if any questions arise on this matte . Very truly yours,
~
CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY
.
W. G. Counsil ! Senior Vice President l
cc: T. E. Murley W. 3. Dircks V. Stello, J H. R. Denton D. G. Eisenhut ' H. L. Thompson, J D. M. Crutchfield I G. C. Lainas ! 3. A. Zwolinski 3. R. Miller I
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.: . Docket Nos. 50-213 50-245 50-336 i
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Attachment 1 Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Inputs to SALP Evaluation Process
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March,1985
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The following items provide a summary description of various meetings, letters, or other transactions which we believe are relevant to the conduct of the SALP process for our facilities. In the interest of brevity, only a summary of each of the pertinent elements is provided below. Further elaboration can be provided if
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desired by the NR i o Early in 1984, the NRC published its Policy and Planning Guidance as NUREG-0885. By letter dated February 2,1984, we provided unsolicited t comments on.this document. This submittal subsequently lead to a number of meetings with the EDO's Staff regarding possible improvements in { subsequent direction to the NRC Staf o On March 23, 1984, we provided a letter to V. Stello Jr. regarding the proposed Senior Manager Rul We understand that senior staff management believed that this document presented a worthwhile perspective different from that proposed by the Senior Manager Rule and as such, was forwarded to the Commission for their consideration. In November of 1984, the Commission disapproved the proposed rul o In recognition of the importance to safety of reducing unscheduled plant trips, we have adopted corporate goals and initiatives to reduce unplanned trips and their subsequent challenges to safety systems. This program was discussed in summary fashion during a meeting with the CRGR in July of 198 o The issue of environmental qualification is one for which it has proven to be difficult to achieve closure. Given the long standing nature of the issue and the turnover of both NRC staff and contractor personnel, we have periodically provided to the staff a chronological listing of all documents exchanged between us and the NRC for each of our nuclear units. We have done so in the interest of facilitating the process by which the Staff can trace the basis for closure of any individual aspect of the environmental qualification issue.
! o At the request of a senior staff manager, a letter was sent to H. R. Denton on July 15, 1984 regarding the involvement of the Nuclear Utility Task Action Committee (NUTAC) and its attempts to achieve resolution of the SPDS issu o At the request of H. R. Denton, we entertained a visit in June of 1984 by the Environmental Programs Branch of the NRC to allow them to obtain additionalinformation regarding the quality of their work.
, o During the 1984 refueling outage at Millstone Unit No.1, we entertained a visit by NRC contractors from EG&G to allow them to collect information on the decontamination process utilized as part of remedial action associated with the IGSCC issu o In August of 1984, representatives from Brookhaven National Labs, under contract with NRC, visited us to obtain information on implementation of our ALARA program o In October of 1983, we entertained personnel from the NRC and Battelle Pacific Northwest Laboratories regarding their interest in biofouling in raw water system . - - .
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-2-o The issue of the flooding at the Haddam Neck Plant as a result of a Quabbin Reservoir dam failure consumed considerable resources within N Numerous meetings were held involving the State of Connecticut, FEMA, National Weather Service, and other organization NU personnel coordinated several visits on the part of the Staff to ensure that all of their questions were answered satisfactoril .
o Several days before the completion of -the 1984 refueling outage for Millstone Unit No. 1, the staff telephoned us to request that we immediately provide a report of our IGSCC program and results of all inspections. Their originalintention was to write an SER prior to startu While we did not accept the verbal staff position that an SER was necessary prior to startup, all requested information was gathered and submitted promptly by letter dated June 15,198 o As part of the resolution of the hydrogen recombiner issue for inerted , BWR's, the NRC issued Generic Letter 84-09. As a result of questions and inquiries from the BWR community regarding the applicability of previous Northeast Utilities work on this issue, we hosted a seminar in our corporate offices on June 15,1984 to review our analyses and answer questions. This was done in the interest of furthering industry-wide resolution of this issu o On July 17 and 18 of 1984, we entertained a visit of the majority of the members of the Committee to Review Generic Requirements (CRGR).
This visit involved discussions'with numerous licensed personnel as well as discussions with numerous levels of NU management. Significant resources were expended in the interest of further improving communications and obtaining a better appreciation of our respective viewpoint o Generic Letter 84-15 requested a considerable amount of information regarding diesel generator performance in the interest of resolving generic issue B-36. In addition to this information, we included voluntarily information regarding the performance of the gas turbine at Millstone Unit No.1.
" o On July 31, 1984, W. G. Counsil was one of several industry spokesmen who provided information to the commission on the important-to-safety issu At this meeting, Mr. Counsil represented the Utility Safety Classification Group. This presentation ultimately led to a visit by four members of the
NRC the following week at our Millstone facility to gather information on the treatment of equipment and components not classified as safety related. It is our understanding that this information was utilized in the , development of the subsequent draft generic letter regarding the ATWS rule.
i o In August of 1984, we entertained a visit on the part of several members of the NRC on the maintenance issue. This visit also consumed significant NU resources and was done in the interest of improving the then draft Staff Maintenance Program Plan.
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l o In September of 1984, Harold Denton and several other staff members of NRR visited the Haddam Neck site as part of the resolution of a Differing Professional Opinion on the fire protection issu o In light of the safety significance of the reactor cavity pool seal issue at
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the Haddam Neck Plant, NU initiated, and remains in the process of implementing, broad corrective actions. While many of these actions are utility specific, we have attempted to share our view of the safety significance of this issue throughout the industry. In October of 1984 we hosted a seminar in our corporate offices in an attempt to explain the details of the event, its safety significance, and answer any question Because of short notice for this meeting, a subsequent seminar was cohosted by Northeast Utilities and INPO on December 13, 1984. We believe this meeting was helpful in heightening industry awareness of the significance of this issu Regarding the Order Modifying License which was issued as a result of this issue in December of 1984, our response was submitted to the NRC some two months earlier than require This action reflects our resolve to address any potential safety issues swiftly and effectivel o One of the elements of our corporate strategy regarding steam generators at Millstone Unit No. 2 concerns a chemical cleaning process planned to occur during the 1985 refueling outage. While this process is governed by the provisions of 10 CFR 50.59 and as such no prior staff involvement is
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required, we voluntarily briefed the staff on December 5, 1984 in considerable detail regarding our planned process and its qualification. No r unanswered questions remained at the conclusion of this meetin o At the request of the Staff in December of 1984, we agreed to have the Staff conduct a review of our plant specific emergency operating procedures as well as the procedures generation package from which the plant specific procedures are prepared. It is our understanding that this differs from the normal process when only the procedures generation package is reviewed by the Staf o As a representative from NUMARC, executive NU management worked with Senior Staff management and the Commission in the last quarter of 1984 and the first quarter of 1985 on the engineering expertise on shift issue. Extensive efforts were devoted towards development of a mutually , agreeable and workable policy statemen . e
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e-4- - o As part of an AIF coordinated effort, NU executive management and other industry executives met with several Commissioners individually in January,1985 to discuss approaches to resolve several issues of importance to both the Commission and the industr o In September of 1984, two NU representatives participated in a Commission briefing on the decommissioning issue. This briefing was intended to facilitate Commission deliberations on a proposed rule on the subject, and familiarize them with the status of utility programs and State PUC activities dealing with decommissionin o On January 3,1985, we were notified of an NRC endorsed activity regarding the National Science Foundation PRA Peer Review Panel. Some two weeks later, NU hosted the first two day meeting of this Panel. The
- . meeting included tours of the Millstone Station and familiarization with PRA applications at NU.
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Docket Nos. 50-213 50-245 50-336
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Attachment 2 Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Follow-up to Previous SALP Report Actions
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Connecticut Yankee The NRC Systematic Assessment of Licensee Performance (SALP) report issued in October of 1983 gave the Haddam Neck Plant Category I ratings in all areas but one. - This one area was surveillance, in which the Staff assigned a Category 2 rating. The Haddam Neck Plant's surveillance plan was broken into e component parts and each component individually analyzed. These components and the plant's corrective actions are enumerated below. These component parts cover all deficiencies identified in Part 4.4 of the SALP report for the Haddam
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Neck Plan '
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_ COMPONENT COMMENTS / ACTIONS 1) _ Data Base All Connecticut Yankee (CY) department heads have updated their portion of the data base for compliance to Technical Specification Additionally, the Quality Assurance Department, as required by procedure, has performed a complete data base revie The data base will be maintained on the computer progra ) Timing Systems Computerized systems have been expanded to include refueling, cold shutdown and all surveillances with frequencies less than a
* wee However, ,timi.ng systems will only schedule any surveillance with frequency greater than a wee The computerized system is the official CY Date Bas ) ' Performance Since most surveillance failings are Improper performance, further procedural guidance and training were neede CYSP-71 has been eliminated, and procedure QA 1.2-11.1 enhanced to pick up any items implemented by CYSP-71 but not covered in QA 1.2-1 Guidance on actions to take with incorrect procedures, procedure corrections and compliance with procedures has been added to ACP Using ACPs as source documents, CYAPCO has prepared departmental level instructions and provided training on the proper use of procedure ) Evaluations and Results Format for surveillance procedure sign-offs is:
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Performed by (Level I) Approved by (Level II or greater) Reviewed by (Level II or greater) The " Approved by" must be Level II qualified as this is the point at which the surveillance
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is considered complete. The " Reviewed by" requires a Level II or greater, but will normally be a LevelII The method of recording acceptance criteria
, on procedures has been upgraded for consistency and clarity and added to ACP QA 1.2-11.2 has been revised to include definitions of approved by and reviewed b . Definition of " performed by" was not . required, being obviou ) Corrective Action QA 1.2-11.2 has been revised to provide guidance on acceptance criteria and need for Plant Incident Report (PIR) initiatio ) Compliance Verification Each department head responsible for surveillances has provided their superintendent a program for continuing ' surveillance compliance verification. Quality Assurance audits, NRC audits, 'etc., are not *
used as the key evaluation factors for ,
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- compliance verification, unless major i
problems are found. Additionally, the I&C " Surveillance Feedback Sheet which requests feedback from personnel performing surveillances when a surveillance is improper, incorrect or is difficult to use has been reviewed by each department for
- implementation as part of their de'partmental i programs.
, 7) Records The computerized schedule has been l evaluated as a "living schedule" to replace i the forwarding schedul Review and approval of surveillance procedures prior to a start-up is a departmental responsibility and is monitored, but results indicate no action is needed at this tim ) Miscellaneous (1) A surveillance as defined in 10 CFR 50.36(c)(3) will mean only technical specification commitments. Other items
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can be on the computerized schedule and proceduralized but will not be a surveillance tes Procedures will be reformatted to meet this definition during the normal biennial procedure review process. Scheduled completion of
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all procedures is July 31,198 '
(2) A standard method for acceptance criteria format has been develope t
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Millstone Unit N The NRC Systematic Evaluation of Licensee Performance (SALP) report issued in October of 1983 gave Millstone Unit No. I Category I ratings in all areas but three. The areas which received a Category 2 rating, the NRC concerns in these areas and NNECO corrective actions are listed below: 1) Plant Operations Concern: On July 20-21, 1983 a radioactive IIquid discharge was unintentionally made for 24 hours due to failure to secure flush water through an effluent radiation monito Corrective Action: All operations personnel, in addition to those directly involved with the incident, have been reminded of their responsibilities and the importance of following station procedures. Procedure changes have been made to eliminate unnecessary flushes by specifying the condition for which flushing is required. Procedure changes have also been made to include dual valve verification for terminating the flush of the sample chambe Concern:
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An incident in March 1983 involved incorrect valve line-ups for sensors in the Reactor Protection System. This problem was previously identified in 198 Corrective Action: Methods were implemented to control safety-related instrument valves to prevent recurrence of incidents of this nature. Personnel involved with the calibration and adjustment of safety-related instruments have been ' reminded of the importance of proper restoration methods when , performing surveillance and maintenance. Surveillance data sheets were revised to include all valve numbers and dual check-off/ initial spaces for l , every valve manipulated during surveillance and' calibration.
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Concern: The Emergency Gas Turbine Generator has been allowed to deteriorate to a point that, during the appraisal period, problems have occurred with the j gas turbine and its controls and the generator voltage regulato . Corrective Action . Instrument folders have been established for the governor control units as j well as the drytest/ analog troubleshooting instrumentatio Key 4
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gas turbine parameters. Maintenance was performed on the voltage { l i
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. -2-regulator during the recent refueling outage to replace defective parts and clean oxidation from contact surfaces. Installation of a dehumidifier for the voltage regulator cabinet precludes moisture intrusion.
2) Surveillance Concern:
Surveillance procedures had not been revised to include an independent verification of system restoratio Corrective Action: Surveillance procedures were reviewed and modified as necessary to include an independent check for system restoration. Also, surveillance data sheets were revised to include all valve numbers and dual check-off/ initial spaces for every valve manipulated during surveillances and i calibratio ) Emergency Preparedness Concern: Installation of the High-Range Monitoring and Sampling Systems for the Unit I stack and the Unit 2 vent was not completed.
l ! Corrective Action: Both monitors have been redesigned to allow proper calibration, and are operational and in service at this tim Concern: . Lesson plans for training of each functional area of the emergency
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response organization were lacking.
Corrective Action: The Training Department individual dedicated to emergency plan training has developed lesson plans and is currently conducting training sessions.
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, Millstone Unit No. 2 The NRC Systematic Evaluation of Licensee Performance (SALP) report issued in October of 1983 gave Millstone Unit No. 2 Category I ratings in all areas but three. These three areas received a Category 2 rating. NRC concerns in these areas and corrective actions taken by NNECO are listed belo ' Plant Operations 1) Concern: An aggressive program for improvement was not evident in the on-site safety committee's performance. The licensee, through the safety committee does not effectively task all personnel, organizations and contractor Corrective Action: The PORC review process was studied and changes implemented. Major - changes were an expansion of the PDCR review process, prior review of major procedure revisions and new procedures, better definition of the use of subcommittees, and responsibilities review during annual PORC training. Particulars of the expansion of the PDCR process are a more detailed line review of the PDCR before being submitted to PORC, prior to review by PORC members and more detailed presentations for the complex changes. In addition to the review of the PORC process, corporate-wide chan'ges have been instituted to more clearly define safety evaluation requirements and these improvements are being monitored by POR ) Concern: In two instances important equipment was out of service for an extended period of time before operations personnel identified the condition. The two pieces of equipment involved were the process computer and the radiation monitor recorde Corrective Action: Concerning the failure to identify the unoperability of the process computer, an alarm which would have indicated a computer failure was inoperative at the time of the computer failure. This alarm has been returned to service and will be maintained operable. The replacement computer, scheduled for 1986, has full alarm capabilities for partial or total failures. To prevent a recurrence of this type, control room operators and licensed supervisory personnel have been briefed on the need to frequently monitor computer displays for up-to-date information and how to determine operability status. A logging requirement has been incorporated to ensure verification of computer updating. The licensed operators were reminded of the importance of newly licensed personnel using a questioning approach to off-normal situations and getting more experienced personnel involved in the investigation as soon as, the * condition is note ~
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With respect to the failure of the radiation monitor recorder, the Operations Department Staff have been instructed and reminded to monitor key Control Room instruments for abnormalities and indications of unusual conditions. In order to ensure that activity is properly monitored in accordance with Technical Specifications, the activity levels being discharged through aerated and clean waste systems is displayed on a second redundant recorder which is on panel C04. This is recorded in view of the reactor operator at his normal station and could be used as a back-up if the multi-point recorder were to fall in the futur . 3) Concern: i On two occasions the unit was operated at a power level exceeding that
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permitted by Technical Specifications for the method of monitoring fuel rod linear heat rate then in use. One instance involved the loss of the computer discussed above and the second a failure to adequately review the results of an INCA print ou Corrective Action: Refer to item (2) for actions resultant from the March 26,1983 inciden Concerning the November 4 event, unit engineering procedures were revised to require verification that the INCA values are consistent with the reactor power level and the reactor engineer provided training for his i personnel in this process.
- 4) Concern
l A series of unplanned or unauthorized releases of radioactive materials on ! September 16, September 24 and December 28, 1982 and January 20, ! 1983, involved common management and personnel errors, particularly lapses in attention to detail and in first and second line management following evolutions. Included were the discharge of the wrong tank discharge on a continuous vice a batch basis, radiation monitor recorder failure duung a discharge and improper valve line-ups. Subsequent performance suggests that corrective actions were applied piecemeal, conducted Informally and without decisiveness and resulted in little effec Corrective Actions: The referenced unplanned or unauthorized radioactiv.e releases have resulted in numerous corrective actions; the most significant are listed belo (a) Procedure changes to ensure the procedures are accurate and easy to understand and use for the plant equipment operators have been implemente (b) Instructions to operating personnel have been issued to ensure they
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.-3-(c) Requirements to have a second radwaste qualified operator verify procedure steps for all radioactive discharges in addition to dual verification of valve line-ups for discharges have been establishe (d) Operations personnel in Unit 2 have been cautioned to critically
review all discharges with respect to possible contamination. The sensitivity of any unplanned radioactive discharge, no matter how slight, dictates that stringent controls be use '
,p (e) Availability of controlled procedures to radwaste operators has -
been improve i i l (f) Hardware changes have been accomplished which more clearly identify valves and controls which must be manipulated for radwaste contro (g) Lastly, an independent review of all Radioactive Waste Operating Procedures and interface procedures (chemistry) was conducted by a Unit 2 senior reactor operator who had not been responsible for procedural review for radwast This review was conducted to ensure usability and compatibility with all other procedure Changes from this review were reviewed and implemented.
- 5) Concern:
The quality of services depends greatly on the abilities of the contractor
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as Illustrated by the success of the steam generator sleeving task and the difficulties with the nozzle dam Installatio .
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! ( Corrective Actiom NNECO agrees that the quality of the service is dependent on the quality
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of the vendor. Therefore, Unit 2 continues to evaluate all projects performed by vendors. This evaluation is utilized during future vendor selections. Concerning the nozzle dam project, modifications performed on the dams and direct NNECO control of the evaluations resolved the problems with the installation. The 1985 effort was accomplished in a timely manne ) Concern: The licensee has not been effective in dealing with the fuel vendo Corrective Action: NUSCO Engineering is in discussion with the fuel vendor to resolve the manufacturing and design problem Extensive examinations were ' completed by NNECO, NUSCO and the vendor to identify the failed rods and potential failure mechanisms. A likely mechanism is debris from the thermal shield removal and other primary work. A stringent material inventory control system has been initiated for this refuel to prevent further failures. In addition a full core off-load and fuel sipping is being
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_4 accomplished during the 1985 refueling outage to improve fuel performance for the next operating cycle. The above efforts complement the fuel reconstitution effort which was completed last fall and which was presented to the NRC in a meeting in NRC Bethesda offices on October 3,198 ) Concern:
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The Safety Committee, PORC, conducts most reviews through subcommittees rather than having all members perform the review. This has resulted in a decrease in committee effectiveness in some of its review wor Corrective Action: , See Item I, corrective actio ) Concern: A breach of a vital area security boundary was made in the course of a planned facility modificatio Corrective Action: The breach of the security barrier was a failure of a portion of the PDCR process. A task force on PDCRs has presented recommendations and the recommendations have been implemented. Among.these improvements is . a greater consistency during PDCR generation. This and the increased PORC review identified in item I will help prevent future deficiencies of all types from occurring during plant design change Emergency Preparedness . I, See Item 3 for Millstone Unit N Licensina Activities ! We did not agree with the Category 2 rating in this functional area, for reasons ! stated in the December 19, 1983 letter to R. W. Starostecki. Accordingly, no significant corrective actions were implemented. It is re-emphasized that the principles and concepts behind our licensing activities for Millstone Unit No. 2 are identical to those applied to the Haddam Neck Plant and Millstone Unit
- No.1, which were given a Category I rating for this assessment interva ,
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ENCLOSURE 7 NORTHEAST UTILITIES o.nor.i Orric.. . s io.n sir.. . e.riin. Connecticut w cowacecut vs.' a.e ao ea cow =
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HARTFORD. CONNECTICUT 06141-0270 L L J [[ "d,U.N ",**'.'" (203) 66s-s000
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July 5,1985 Docket No. 50-213 50-245 50-336 A04906 Dr. Thomas E. Murley, Regional Administrator Region I U. 5. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen: Millstone Nuclear Power Station, Unit Nos. I and 2 Haddam Neck Plant Systematic Assessment of Licensee Performance The Staff recently forwarded the SALP Board Reports (l) for the 18 month period ending February 28, 1985, for Haddam Neck, Millstone 1, and Millstone Subsequent to receipt of SALP Board Reports, a meeting was held on June 4 between members of the Staff and members of Connecticut Yankee Atomic Power Company (CYAPCO), and Northeast Nuclear Energy Company (NNECO).
The purpose of this letter is to respond to and comment on the findings of the SALP Board with particular emphasis on the Board recommendations for the individual evaluation categories. Attachment A to this letter contains the response to each of the Board's recommendations for the Haddam Neck Plan The responses to the Board's recommendations for Millstone Unit No. I and Millstone Unit No. 2 are contained in Attachments B and C, respectivel Both NNECO and CYAPCO take very seriously the ratings and recommendations given by the Board as one input to evaluating and improving our overall performance. As reflected by our comments and observations during the June 4 meeting, we generally concur with the Board's observations and previously have taken or are taking steps to address the concerns identified. It remains our objective to achieve Category I ratings in all functional areas for subsequent SALP evaluations, and the attachments to this letter describe some of the steps we will be taking to fulfill that objectiv Notwithstanding our general agreement with the SALP evaluation, there is one NRC comment with which we disagree. Specifically, page 27 of the Connecticut Yankee evaluation discusses the Design Change Control / Quality Assurance are After discussing various facets of the reactor cavity seat failure recovery effort, the NRC states that: l (1) T. E. Murley letter to 3. F. Opeka, dated May 20,198 % _;i,~ . m
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We disagree with this statement and request that it be changed in the final SALP repor Significant management initiatives were undertaken to re-emphasize the importance of quality in design change activities. As discussed in detail in previous correspondence, these intiatives included: o A memorandum to all Nuclear Engineering and Operations personnel which stressed the importance of doing it right the first time, o A safety ethic training program, o A series of management briefings stressing the importance of safety and quality in all nuclear activities, o Significant, intensive efforts to remedy the specific deficiencies revealed as a result of the cavity seal failure, and o Co-sponsorship of an industry-wide seminar in cooperation with the Institute of Nuclear Power Operations (INPO) to strengthen industry awareness of the issue, in light of the above and other related efforts, we believe that the previously quoted excerpt from the SALP report should be amende We trust that the actions presented in the attachments for addressing the concerns of the Board and our general comments will be considered in subsequent SALP evaluations. We will be updating you regarding the status of implementing the corrective actions discussed herein prior to the next SALP evaluatio Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY b (d-- J. F.Wka L Senior Vice President cc: D. M. Crutchfield G. C. Lainas
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Docket No. 50-213
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Attachment A Connecticut Yankee Atomic Power Company Haddam Neck Plant Response to SALP Report 'I !- ! !
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A-1 i Functional Areat PLANT OPERATIONS Board Recommendations:
(A) Improve the quality and aggressiveness of self appraisal (B) Continue emphasis on operator requalification 1 (C) Continue initiatives to improve procedural review (D) Assess the adequacy and timeliness of PIR/CR disposition <
RESPONSE:
(A) The sal.P report resu.Its have increased management concern for self appraisal and self-identification programs in that an upgrading of the following existing programs ~ is under consideration: * '
Plant Information Reports Nonconformance Control Report System " Quality Assurance Monitors
- Employee Beneficial Suggestion Program Radiological incident Report
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Station Housekeeping and Inspection Program Additionally, the onsite Safety Review Group began conducting a review of
" work in progress" starting June,1985 and the Quality assurance audits will '
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become more performance oriente j (B) The licensed operator requalification program is being strengthened in 1985 by the addition of a theory upgrade program for operators who received j license training prior to 1981. Additionally, a written examination will ' determine which other operators will be required to take the theory upgrade program.- Strengthening of the requalification program is being , achieved by the administration of more comprehensive annual examinations I i
(including oral, walk-through, and written sections) and background training on ERG-based qualified third-party examination of the 1985 program and r trainee knowledge.
l- Beginning operation in 1986, the Connecticut Yankee Plant Reference
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Simulator will become a part of operator requalification training.' The i 1986 requalification program will be executed on a one-in-six rotation with l a combination of upgraded classroom materials and trainin These , actions, coupled with improvement and expansions of learning objectives,
- training materials, evaluation methods, and operator feedback is expected .
' to provide the licensed operators with an effective requalification progra ' !
.(C) The following existing programs will continue to improve procedural review j and adherence:
- (1) Use of standard review checklist during procedural review to increase overall quality of procedure ,
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, (2) Continuation of emphasis of strict procedural adherence. A method currently used at the Millstone site involving management review and <-
reissue of appropriate standing memos to remind station personnel of
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the importance of following procedures and initiating changes to those procedures found to be weak, will be considered for use at Haddam Neck, r
. ,, (3) Continued preparation of Emergency Procedure Guidelines (EPC's).
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(4) Finalization of all applicable annunciator response procedure (D) The PIR/CR system has had internal reviews conducted by the on-site Safety Engineering Review Group. The results of the review indicated that further root cause analysis is required for PIR's. As a result of this review,
< a root cause analysis form is currently in trial use. The form requires a root cause analysis to be completed for each PIR assigned a controlled
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routing (CR).
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', It should be noted that during the first two quarters of 1985 the total number of outstanding controlled routings was reduced by approximately 25%. During the same period 748 contro!!ed routings were assigned while h942 were completed it is anticipated that this positive trend will continue in'the coming month As additional root causes are identified and corrected the number of PIR/CR's is expected to drop even further which should aid in improving the timeliness of PIR/CR dispositionin CYAPCO will continue to evaluate the adequacy and timeliness of PIR/CR dispositioning during the next six month . .
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. . A-3 Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:
(A) Efforts should be made to strengthen management oversight and intradepartmental communications. An effective system for evaluating and correcting self-identified deficiencies should be develope (B) The licensee should expedite efforts to seek a Technical Specification Amendment for PASS containment isolation valves to allow resumption of full system surveillanc RESPONSE: (A) Efforts to strengthen management oversight were described previously in Licensee Event Report 50-213/84-020-00. A task force of experienced plant personnel was assembled to evaluate the current method of coordinating work schedules among departments and to improve intradepartmental communications. The efforts are continuin As a result of the findings of NRC Inspection 84-30, we modified the Radiation Work Permit (RWP) Discrepancy Report and implemented a s Radiological incident Report for more serious event The RWP Discrepancy Report, the Radiological Incident Report and the corrective actions associated with both have reduced and almost eliminated RWP discrepancies. No further action is require (B) The subject License Amendment request will be submitted to the Staff during July,1935, and we will continue attempts to expedite amendment issuanc _ _ _ _ _ _ _ - _ _ _ _ _
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A-4 Functional area: SURVEILLANCE Board Recommendations: -
(A) Continue initiatives to upgrade surveillance procedure (B) Improve management control over items like CLRT issues in order to assure that resolution is not unduly delaye RESPONSE: (A) A previously existing initiative to upgrade the surveillance program is expected to be completed in June,198 (B) We have reviewed the overall management control issue regarding Local Leak Rate Testing (LLRT) and Integrated Leak Rate Testing (ILRT) and '
agree with the findings of the board. It is our intention to strengthen our existing management controls by reshaping our ILRT/LLRT program to be consistent for all of our operating nuclear units. A Nuclear Engineering and Operations Procedure on ILRT, now undergoing internal review, will include specific assignment of responsibilities to ensure timely and accurate responses to NRC questions. This reshaping will be completed prior to the next scheduled ILRT (Connecticut Yankee-first quarter 1986).
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A-5 Functional Area: FIRE PROTECTION / HOUSEKEEPING Board Recommendations:
(A) Maintain attention to Fire barrier (B) Discuss with NRC the status of findings and corrective actions related to the Appendix R implementation progra RESPONSE: (A) CYAPCO will maintain its attention to Fire barriers with the following:
Training on fire barriers has been added to General Employee Training (GET) and maintenance staff training as appropriate. A memorandum concerning fire protection barriers has been sent to station personne Maintenance personnel conduct a bimonthly fire door inspection under our preventive maintenance progra Procedures in place to address fire barriers include: o Control of Betterment Construction Work Activities - requires a prejob walkdown to include locating and inspecting all fire barrier o Control of Fire Doors -- establishes procedures for fire door requirement o Performance of Fire Protection Reviews - to conduct plant design change request reviews, o Installation, Repair and Inspection of Fire Barrier Penetration Seals -
- to inspect all fire seals and ensure any barrier penetrated is reseale (B) The initial comprehensive submittal of our Appendix R approach was in March, 1982. Subsequent clarification letters and new interpretations
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i issued by the Staff resulted in a complete third party review (2) to validate and update our original submittals and incorporate new NRC interpretations. It is noted that Generic Letter 85-01 strongly suggests that still further NRC guidance, or requirements, can be expected. In early 1985 this third party reanalysis was completed. Subsequent internal review of this re-evaluation has revealed the need for new exemptions and hardware modifications. The documentation associated with this effort is being prepared and is planned to be submitted within the next few month (2) See the W. G. Counsil letter to R. H. Vollmer, dated June 18,198 __
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A-6 The non-outage related hardware modifications are planned to be completed in accordance with 10CFR50.48 schedules. Some outage related 1 work is expected to be completed by the second quarter of 1986, and schedular relief .will be requested for the extensive switchgear room modification m- -_ ___----_-------______-2 - _ . - _- - -
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A-7 Functional area: EMERGENCY PREPAREDNESS Board Recommendations:
(A) Continue efforts to improve the coordination of emergency response activitie RESPONSE: (A) As noted in the SALP report, the March 30, 1985 annual exercise was arranged to re-demonstrate areas where corrective actions were necessary after the NRC findings in the 1984 exercise. These were successfully demonstrate In regard to the one violation for failure to train six (6) personnel assigned Emergency Planning duties in 1983, there have been changes made to formalize the commitments contained in the February 16, 1984 letter (3) to the NRC. The six items of concern (recommendations) related to the dose assessment program have been reported on in our letter dated August 8, 1984.(4) All items except one have been resolved. The remaining item, 50-213/84-06-03, systematic computational comparison between licensee dose models and those used by the State, is in progress and is scheduled to be completed by the end of the calendar year 1985.
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(3) W. G. Counsil letter to T. T. Martin, Response to I&E Inspection 50-213/83-28, dated February 16,1984.
l (4) W. G. Counsil letter to T. T. Martin, Response to I&E Inspection 50-213/84-06, dated August 8,1984.
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Functional Area: DESIGN CHANGE CONTROL / QUALITY ASSURANCE Board Recommendations:
(A) Continue implementation of DCC/QA program improvements and review the effectiveness of the QA/QC surveillance effor RESPONSE: (A) We have reviewed the Design Change Control (DCC) QA issue and agree with the findings. Connecticut Yankee will continue implementation with DCC/QA improvements as noted in the SALP report. Furthermore, NUSCO QA will conduct a review of the coverage and effectiveness oi the quality control surveillance activities at Connecticut Yankee. This review will be completed by November,193 . . , ..
A-9 Functional Area: LICENSING ACTIVITIES Board Recommendations:
(A) As indicated in Sections B and D, the licensee should agressively pursue licensing resolution in the areas of 10CFR50 Appendix 3 compliance and, (B) operation of the post-accident sample system at powe RESPONSE:
(A) A comprehensive submittal addressing all unresolved items associated with Appendix 3 compliance is planned for the fourth quarter of 198 (B) As indicated in our response (B) in the Radiological Controls Functional Area, the subject License Amendment request will be submitted to the Staff during July, 1985, and we will continue attempts to expedite amendment issuanc /
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Docket No. 50-245
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Attachment B Northeast Nuclear Energy Company Millstone Unit N Response to SALP Report
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July,1935
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. B-1 Functional Area: ' PLANT OPERATIONS Board Recommendation:
(A) Provide a more vigorous self-appraisal function in order to achieve better internal identification of problem areas such as the high failure rate on j initial operator qualificatio RESPONSE: (A) Management evaluations are being conducted during the training process and following final examinations. Trainees not meeting performance criteria during training are evaluated for continued participation. Before candidates are recommended for licensing, management reviews progress examinations conducted during the training program, simulator evaluations, final and written examination results, and performance in training watche .
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B-2 Functional Area: RADIOLOGICAL CONTROLS
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Board Recommendation:
(A) Evaluate specific training for first-level supervisors as a measure for improving adherence to requirement (B) Upgrade adherence to routine radiation protection requirements by individual workers, i RESPONSE: (A) Having evaluated the need for specific training for first level supervisors, NNECO has determined that all station personnel should be instructed / reinstructed in the importance of procedure establishment, implementation and maintenance. This subject material will be included in these training programs:
New Employee Indoctrination (NEI) General Employee Training (CET) Radworker Training (RT)
(B) The Station Superintendent has issued a memorandum to all station personnel which stresses the importance of following all radiation protection requirements. NNECO supervisory personnel have also been assigned to observe radiological protection practices within the units and report all observations and findings to the Health Physics Superviso Additionally the Training Department has been requested to re-emphasize, in their NE!/CET/RT classes, the importance of following all radiation protection requirements, i
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B-3 Functional Area: MAINTENANCE Board Recommendations:
(A)- Improve shelf-life program and storage program for welding electrode RESPONSE: (A) . ACP-QA-06 Revision 0, " Procurement and Evaluation of Shelf Life Material", was SORC approved on July 29, 1984. Its purpose is to identify a method of verifying the acceptability for use of applicable degradable items which may have deteriorated while in storage and defines the procedure for procuring shelf life material. As an upgrade to the original ACP, Revision I was approved on May 7,1985. This revision 1) provides originators and reviewers with procedural guidance related to the shelf life of . component parts, 2) specifies action to be taken when shelf life information is not received, and 3) adds responsibility of including ' documentation of the evaluation of degradable items prior to use to the job superviso The changes serve to improve the shelf-life monitoring progra Regarding storage of welding electrodes, the Unit 2 Instrument and Control Department has the responsibility for calibration of the storage oven temperature monitors. The calibration program for these monitors is defined in procedure IC 2419D, Mandated Non-Safety Related Equipment Calibratio .
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B-4 Functional Area: SURVEILLANCE
, Board Recommendation: (A) Upgrade QA of critical surveillance testing such as containment integrated leak rate testin RESPONSE: (A) Millstone Unit No. I personnel have recognized the previous shortcomings in performance of integrated leak rate testing. This is largely due to infrequent performance of the test. In order to correct this problem, Unit i Engineering Department Instruction 1-ENG-3.01, Primary Containment Integrated Leak Test, was prepared and issued June 3, 1985. This instruction provides detailed information for planning and execution of the ILRT, including training and inter-department involvemen The instruction will be reviewed and revised as necessary prior to the next ILR The QA program / procedures as currently written provide for the NNECO QA/QC Department to perform monitors on surveillance testing. Consistent with this, the QA/QC Department has and will continue to monitor various surveillance testing activities. The QA/QC Department will monitor testing activities deemed critical at the request of the appropriate superintenden . . -
B-5 Functional Area: FIRE PROTECTION / HOUSEKEEPING Board Recommendation:
(A) Address the cluttered yard conditio (B) Resolve Appendix R implementation RESPONSE: (A) The station is aware of and sensitive to the cluttered yard conditions. This situation was aggravated by our being restricted from one of our radwaste burial sites and our self imposed ban on making radioactive waste shipments. We have resumed shipment of radioactive waste and are making a concerted effort to clean up the backyard. A Radwaste Reduction Facility is currently under construction and should be completed by September of this year. This will provide us with additional indoor storage capabilitie Additionally, as the Millstene Unit No. 3 construction approaches completion, the congestion in the yard will be greatly relieved as the common site service groups will be able to expand into the Millstone Unit No. 3 yar (B) The initial comprehensive submittal of our Appendix R approach was in March, 1982. Subsequent clarification letters and new interpretations issued by the Staff resulted in a completed third party review (5) to validate and update our original submittats and incorporate new NRC interpretations. It is noted that Generic Letter 85-01 strongly suggests that still further NRC guidance or requirements can be expecte Subsequent internal review of this re-evaluation (5) has revealed the need for new exemptions and hardware modifications. The documentation associated with this effort is being prepared and is planned to be submitted within the next few month Hardware modifications which are non-outage related are planned to be completed in accordance with 10CFR50.48 schedules. Implementation of the outage related work will be scheduled following receipt of the NRC SE (5) See W. G. Counsil letter to R. H. Vollmer, dated June 18, 198 * ' .. .
I B-6 Functional Area: EMERGENCY PREPAREDNESS Board Recommendation:
(A) Evaluate measures for assuring timely completion of action item RESPONSE: (A) We have more formalized our training program. The NRC's concerns in this area are recognized and are being addresse .
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B-7 Function Area: REFUELING AND OUTACE MANAGEMENT Board Recommendation:
(A) Improve self-assessment to identify items such as failure to follow through on commitments and design modification RESPONSE: (A) Tracking of commitment items will be improve This will be accomplished through issuance of a Millstone Unit 1 Superintendent's assignment number for each commitment item. Additionally, commitment items' will be noted as such on the assignment log. Tracking of design changes has greatly improved as a result of recent major revision of ACP-QA-3.04, Design Change Control. No further action in tracking of design modifications is considered to be required at this tim . _ _ _ _ - ._ _ _ . . _ -
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B-8 Functional Area: LICENSING Board Recommendation:
(A) Improve management of licensing activities to avoid late response (B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project statu RESPONSE: (A) & (B)
A combination of manpower shortages due to unfilled vacancies in the operating plant licensing group and the work loads on the engineering staff resulted in resource limitations regarding schedular requirements in the area of licensing activities. As of the end of the first quarter of 1985, the operating plant licensing staff was at full strength. Increased telephone contact and meetings with NRC Project Managers, coupled with more global resource management via the ISAP, are expected to improve coordination of activities and timeliness of result ,
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Docket No. 50-336
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Attachment C Northeast Nuclear Energy Company Millstone Unit No. 2 Response to SALP Report
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l July,1985
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C-1 Functional Area: PLANT OPERATIONS Board Recommendations:
(A) Upgrade controls over computer codes, particularly of associated qualification certification RESPONSE: (A) A significant effort has been underway for over a year to upgrade computer software in use within NUSCO for Category I engineering analyscs. An overali action plan was prepared and approved in June,1984 by both the Senior Vice President, Nuclear Engineering and Operations (NEO), and the Vice President, Information Resources Group (IRG). Since that time, three NEO level procedures governing this activity have been prepared and issued. Efforts are continuing in this are We disagree with the NRC's characterization that "the deficient certification of individuals to conduct PWR safety analyses using sophisticated computer code (RETRAN) is a significant flaw in management involvement in the assurance of quality at a fundamental level." One of the seven individuals listed as Qualified RETRAN Users had not run the RETRAN code prior to being placed on this list. It was management's judgement that this person's extensive qualifications warranted an exception to our normal requirements for becoming a Qualified RETRAN User and that this action would not compromise the assurance of quality. The individual in question earned a Ph.D. in Nuclear Engineering in 1980 and has significant computer oriented analytical engineering expertise including that with thermal / hydraulic programs comparable to RETRA Nevertheless, his name was subsequently removed from the Qualified RETRAN User list.
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Function Area: RADIOLOGICAL CONTROLS Board Recommendations:
(A) Continue recent emphasis on improving radioactive material transportation . control (B)' Assure better adherence to radiation protection procedures by worker RESPONSE: (A) As a result of the violation that was identified at the Barnwell, South Carolina burial site we have implemented the following actions to correct this problem: Reorganize the Radioactive Materials Handling Department. The Radioactive Materials Handling Supervisor will now report to the Health Physics Supervisor. The Health Physics Supervisor will spend increased time in the Radioactive Materials Handling Area. He will approve all shipments prior to their departure from the site. The Radioactive Materials Handling Group will be divided into three groups: a) Tool Decon Facility, b) Packaging and c) Shipping. Itis our opinion that with this organization we will be able to better supervise and control the activities within the Radioactive Materials Handling Grou . A specific packaging procedure will be developed for LSA boxe This procedore will contain the following provisions; a) Health Physics Technicians will monitor the packaging of LSA boxes, b) only !
material that is less than 160 mr/hr will be placed into these boxes, c) the boxes will be packaged in such a manner as to minimize any movement of the material within the box during shipment and d) fif ty-five gallon drums will not be placed into these boxes.
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- Any material that is greater than 160 mr/hr, that is compactible will be placed into a fif ty-five gallon drum and compacted. if it is non-
compactible, it will be placed into an approved shipping liner and will j be sent to the burial site in a shipping cask.
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(B) The Station Superintendent has issued a memorandum to all station personnel which stresses the importance of following all radiation protection requirements. NNECO supervisory personnel have also been assigned to observe radiological protection practices within the units and report all observations and findings to the Health Physics Supervisor. i Additionally the Training Department has been requested to re-emphasize, in their New Employee Indoctrination, General Employee Training, and Radiation Training classes, the importance of following all radiation protection requirement **
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C-3 Functional Area: MAINTENANCE Board Recommendation:
(A) Improve shelf-life program and storage program for welding electrode RESPONSE: (A) AC P-QA-06 Revision 0, " Procurement and Evaluation of Shelf Life Material", was SORC approved on July 29,1984. Its purpose is to identify a method of verifying the acceptability for use of applicable degradable items which may have deteriorated while in storage and defines the procedure for procuring shelf life material. As an upgrade to the original ACP, Revision I was approved on May 7,1985. This revision 1) provide originators and reviewers with procedural guidance related to the shelf life of component parts, 2) specifies action to be taken when shelf life information is not received, and 3) adds responsibility of job supervisor to include documentation of the evaluation of degradable items prior to us The changes serve to improve the shelf-life monitoring progra Regarding storage of welding electrodes, the Millstone Unit 2 Instrument and Control Department has the responsibility for calibration of the storage oven temperature monitors. The calibration program for these monitors is defined in procedure IC 2419D, Mandated Non-Safety Related Equipment Calibratio _ _ _ _ _ . -. - _____ -- - _
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C-4 Functional Areat FIRE PROTECTION / HOUSEKEEPING Board Recommendations: A) Address the cluttered yard condition. Upgrade housekeeping in areas noted as candidates for improvemen B) Resolve Appendix R implementatio RESPONSE: , A) Improvement in yard housekeeping is addressed in the Millstone Unit I response to Fire Protection / Housekeeping recommendations. Additionally, j other Millstone Unit 2 areas identified as needing housekeeping improvement are the Enclosure Building, Equipment Access Hatch Area,
. the Auxiliary Building Refueling Water Storage Tank Pipe Chase Area and '
the Safeguards Pump rooms. Housekeeping improvement of these areas ) will be mad !
(B) The initial comprehensive submittal of our Appendix R approach was in March, 1982. Subsequent clarification letters and new interpretations issued by the Staff resulted in a completed third party review (6) to validate i and update our original submittals and incorporate new NRC '
interpretations. It is noted that Generic Letter 85-01 strongly suggests that still further NRC guidance or requirements can be expecte Subsequent internal review of this re-evaluation (6) has revealed the need for new exemptions and hardware modifications. The documentation associated with this effort is being prepared and is planned to be submitted within the next few month Hardware modifications which are non-outage related are planned to be completed in accordance with 10CFR50.48 schedules. Implementation of the outage related work will be scheduled following receipt of the NRC SE . 4 ,
, (6) See W. G. Counsil letter to R. H. Vollmer, dated June 13,198 _. _ ._ _ .
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.. , C-5 Functional Area: EMERGENCY PREPAREDNESS Board Recommendation:
(A) Evaluate measures for assuring timely completion of action item RESPONSE: (A) We have more formalized our training program. The NRC's concerns in this area are recognized and are being addresse I .
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g C-6 Functional Area: LICENSING Board Recommendation:
(A) Improve management of licensing activities to avoid late response (B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project statu RESPONSE: (A&B)
A combination of manpower shortages due to unfilled vacancies in the operating plant licensing group and the work loads on the engineering staff resulted in resource limitations regarding schedular requirements in the area of licensing activities. As of the end of the first quarter of 1985, the operating plant licensing staff was at full strength, increased telephone contact and meetings with NRC Project Managers, coupled with more global resource management via the ISAP, are expected to improve coordination of activities and timeliness of result .. }}