IR 05000245/1985099
| ML20128B284 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 05/06/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20128B265 | List: |
| References | |
| 50-245-85-99, 50-336-85-99, NUDOCS 8505240468 | |
| Download: ML20128B284 (92) | |
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w U.S. NUCLEAR REGULATORY COMMISSION REGION I-SYSTEMATIC ASSESSMENT OF LICENSEE 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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LSUMMARY....................................... 34
. TABLE 3 VIOLATION SUMMARY.............................................. 35
' TABLE 4 - AUTOMATIC SCRAMS AND FORCED OUTAGES............................ 37 TABLE 5 - INSPECTION REPORT SUMMARY...................................... 38 LTABLE 6 - LER SYNOPSIS................................................... 42 i
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I.
INTRODUCTION
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A.
Purpose and Overview a
The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect information periodically and evaluate licen-q see performance.
SALP supplements the normal regulatory processes used a'
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 safety.
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An NRC SALP Board met on May 6, 1985 to assess licensee performance in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Lic-
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ensee Performance." A summary of the guidance and evaluation criteria i
is provided in Section II of this report.
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This report assesses licensee performance at Millstone Unit 1, a General I
Electric designed Boiling Water Reactor, for the 18-month period from
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September 1, 1983 through February 28, 1985.
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B.
SALP Board Members J
R. Starostecki, Director, Division Reactor Projects (DRP), SALP Board
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Chairman W. Kane, Deputy Director, DRP R. Bellamy, Chief, Emergency Preparedness and Radiological Protection
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Branch, Division of Radiation Safety and Safeguards (DRSS)
J. Durr, Chief, Engineering Programs Branch, Director, Division of
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Reactor Safety (DRS)
y E. Wenzinger, Chief, Project Branch 3, DRP E. McCabe, Chief, Projects Section 3B, DRP L. Rubenstein, Assistant Director, Core and Plant Systems, Division of
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Systems Integration, Office of Nuclear Reactor Regulation (NRR)
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J. Shea, Licensing Project Manager, ORB 5, NRR j
J. Shediosky, Senior Resident Inspector
Other Attendees
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D. Lipinski, Resident Inspector
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D. Osborne, Licensing Project Manager, NRR
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R. Summers, Project Engineer, Projects Section 3B
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C.
Background
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1.
Licensee Activities 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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Ifor replacement'of a failed recirculation pump seal assembly. A scheduled refueling outage was conducted from April 14 through June 28,.1984..The major. effort during that outage was the non-destruc-tive evaluation of Class.1 and 2 stainless steel piping systems to 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 containment.
There have been no automatic or manual reactor trips during the as-
.sessment period. The last unanticipated reactor trip occurred dur-ing August 1983. 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.)
2.
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 period.
Total NRC inspection hours (both resident and region-based) expended for Unit I were 2110. This correlates to 1407 inspection hours per
_ year.
NRC Emergency Preparedness Inspection Teams observed full scale emergency exercises on October 5, 1983 and October 12, 1984.
There were no investigations during the assessment period.
Tabulations of Violations and Inspection Activities are provided at the end of the SALP report.
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II. 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 are used to assess each functional area.
1.
Management involvement in assuring quality
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Approach to resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management)
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Training effectiveness and qualification 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 1.
Reduced NRC attention may be appropriate.
Licensee management
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l 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 achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee
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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 achieved.
Category 3.
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 i
safety is being achieved.
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-mance during the entire SALP period. This trend was evaluated as " Improving,"
or as " Consistent" (essentially unchanged), or as " Declining."
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III. SUMMARY OF RESULTS
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A.
Overall Facility Evaluation M
N Overall, licensee performance was good during this SALP period.
Perfor-i
mance of the plant operators was notably professional in regard to taking
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prompt action to prevent plant conditions from developing into unplanned
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shutdowns. Operations and operations support have performed well and
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have interacted effectively, and the unit is currently in its longest
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operating run (275 days as of May 6, 1985).
There were no automatic
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reactor trips during the SALP period, and analysis of licensee event
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
and monitoring of operational activities were found to be good and well-i-
received by facility management.
Instances of deficient licensee self-
appraisal were, however, evident.
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The radiation protection and housekeeping programs were effectively ap-
plied to reduce contamination and improve area access. Millstone 1 is I
an exceptionally clean Boiling Water Reactor. Also, radiation protection i
measures were carefully planned and implemented for significant in-ser-vice-inspection work in the primary containment drywell. But there were
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multiple lapses in worker adherence to routine radiation protection
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procedures and repetitive problems with low level radwaste shipments to
South Carolina. These lapses indicate a need to upgrade first level
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supervision of such activities as well as to improve worker compliance
with routine radiation protection controls.
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Design control was noted to be deficient, with improper installation of
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the Post-Accident Sampling System (PASS) the noteworthy example. Cor-
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rective measures on this item are in progress as a result of identifica-q tion of design control problems at the licensee's Haddam Neck plant.
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In some cases, the licensee has not provided timely responses to the NRC.
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One such case involved shelf-life control for perishables and environ-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 issues.
- In summary, licensee performance has been strong in plant operations and
- control of major activities. There has, however, been a significant
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lapse in design control and lapses in radiation protection.
Responses
to the NRC need to be more timely. There is a need for more effective
licensee self-appraisal.
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B.
Overall Evaluation of Training As shown by the operational performance of the plant, the training pro-
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gram has been effective overall.
Licensee training initiatives have been
noteworthy, including an upgrading through training staff expansion in
s.e and authority. A training department screening process has been
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implemented to correct a problem with operator performance on initial 1*.
-NRC' licensing examinations. An onsite plant specific simulator project.
.is in process. Requalification training has been satisfactory and is
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expected to improve when the simulator is placed in operation.~ Training
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of non-operators was good, with Instrument and Controls department
training noted to be particularly effective.
C.
Facility Performance
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Category Category Recent
' Functional Area last Period This Period Trend (9/1/82-(9/1/83-8/31/83)
2/28/85)
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Plant Operations
1 Consistent 2.
Radiological Controls-
2 Consistent 3.
. Maintenance
1 Consistent 4.
Surveillance
1 Consistent 5.
Fire Protection / Housekeeping
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1 Consistent 7.
Security & Safeguards
1 Consistent 8.
Refueling & Outage Management
2 No Basis 9.
Licensing Activities
1 Consistent
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IV. PERFORMANCE ANALYSIS A.
Plant Operations (714 hrs., 34%)
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Analysis j
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This area encompasses engineering support, design control, training,
'and staffing as well as Lthe overall. conduct of. facility operations.
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 in the last SALP.
No unplanned scrams during reactor operation have occurred since August 1983. 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 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-fectiveness is-discussed later in this section.)
Overall, the control room function was assessed as effective.
Other than routine security measures, access to the control room
was not specifically limited.
Documents sent to the control room
were not specifically pre-screened to avert unnecessary burdening of the operators. But, business with the control. room was required
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to be ccnducted 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 panels.
Procedures and drawings were found to be readily available and ap-propriately used. Despite a lack of formal status boards, shift 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 examinations suggest a decline in training program effectiveness.
Approximately one-half of the candidates for initial operator and senior operator licenses were unsuccessful in NRC administered ex-
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k-aminations. Personnel reassignments 7and a perceptible decline'in
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- the morale'of.the' training department'may have contributed to this m
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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
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series and_one week of contracted simulator. training. The examina-
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be removed from. licensed duties. A plant specific simulator is to
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be installed as part of a program to significantly upgrade licensed
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operator. training.. Training department. staffing includes licensed
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operators and is expanding to meet. simulator training needs._.These-
. factors are indicators of a sound and improving __ operator training.
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program.
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A strong' sense of forehandedness was-evident during-several planned power reductions.for corrective maintenance. These ranged from-routine 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 Valve.
Two brief-shutdowns'were conducted-to correct significant failures.~ During'
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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
,W 2, 1984, a rise in measured drywell_' sump leakage was. observed.-
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Power was reduced to less than 1% and a variety of problems with '
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smal1 valves were repaired. The unit was returned to power and'
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drywell sump leakage returned to a typically low value. Overall,
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the success of plant' operators and technicians ir.the' diagnosis and r'epair of problems _is noteworthy.
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During the preceding'SALP, the perception of a lack of licensee sensitivity toNissues affecting the reliability of onsite-caergency power sources was highlighted. During.the current period, modifi--
cations were made to control the' envinnment '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 v
lon 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, 1A vendor inspection programs and results, and commented favorably on EDG reliability. These efforts in the area of emergency power are typical of licensee efforts in other areas.
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. Region-based-inspectors reviewed QA audit schedules and plans,
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~ documentation of.11 QA audits, 3 semi-annual-QA review reports to..
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management, the QA monitor schedule, and 6 QA monitor reports. The
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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.
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- and aggressive, with good communication with senior management and the PORC. -QAl audit schedules and results are reviewed by the PORC.
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The monitor. program is conducted by the onsite QA staff.
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vides site managers with-a. separate vfew of the performance'of per-
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sonnel and evolutions. Corrective actions on audit and monitor
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findings generally are implemented promptly. ' The licensee is re-
viewing the monitor program to identify ways to enhance its utility.
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Overall, the. audit and monitor programs are considered to be posi--
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Several' meetings'of the PORC were attended by inspectors at inter-vals.during the_ period. The PORC reviews were critical, thorough,
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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
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L cpersonnel than to a shortcoming of PORC oversight of plant opera-
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'tions. Subsequently,-~a detailed review of document control revealed..
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that the vioUation was an isolated event and resulted in the closing i
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of.previously= unresolved or open' issues in~ procedures and drawing
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control.
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Analysis'of LERs indicates a high. level of performance. The ratio
of personnel related events to facility-related events remains very W
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low ati0.'06.
This compares favorably with a ratio of 0.12 attained during the previous SALP cycle and 0.18 for a " typical" BWR of
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NUREG/CR-2378_.
The ratio of management-related events to facility -
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- related events increased from 0.09 to 0.12 during the cycle.
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" typical" BWR achieved a management related to facility-related
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event ratio of 0.18.) This increase was due to the failure.to cor-
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rect recurring problems with the security system equipment, with
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Isolation' Condenser Containment Isolation Valve 1-IC-3, and the de-U
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sign deficiencies relating to the containment' isolation function
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new requirements in force since then, were timely and complete.
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When additional information later developed concerning reported
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Levents, updated LERs-have been submitted.
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Conclusion
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Rating:
Category 1.
p Recent Trend: Consistent.
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Board Recommendation 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 qualification.
t NRC: None.
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B.
Radiological Controls (318 hrs., 15%)
1.
Analysis
.The licensee'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 initial _1y subjected to reduced in-
spection effort due to previously observed good performance.
- The licensee's radiation protection program continues to be defined
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 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 maintenance.
- For example,' on two separate occasions, the licensee performed tasks
that were beyond the work that was authorized and allowed by job
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specific radiation work permits.
Though these occurrences were a
identified to the licensee, corrective measures were not effective
enough to prevent recurrence a short time later.
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 an inadvertent sustained intake of airborne radioactive
materials by a worker.
For this event, corrective action was not
initiated until the item was identified by an inspector 30 days-
1ater. Several other procedural problems noted this period rein-
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forced the perception that violations are repetitive and indicative l
of'a minor programmatic breakdown, particularly in view of the lic-
ensee's previously observed ability to adequately establish, imple-
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ment and maintain procedures.
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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 had as-
sessed a $3,000 civil penalty for a discrepant shipment received
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'in December 1984, and formally notified the licensee of a discrepant
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sh,ipment received-in October 1984. Sevi. cal other deficiencies be-
tween September 1983 and August 1984 were orally conveyed to tne
licensee by the State. This. indicates that the licensee has not
been effectively implementing this portion of the program or ef-
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fecting adequate' corrective action.
Since multiple and repetitive violations were identified, programatic breakdown is evident.
- 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
requirements.
To reduce solid radioactive waste generation,-the licensee estab-
lished a corporate performance goal for 1984 of ten percent less
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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 average.
- The Itcensee 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 of the effort are generally complete, well maintained and available.
. Reviews of this area indicate that the program is generally effec-
tive but does not always achieve established goals. The effective-
ness of the program has recently been enhanced by a corporate policy
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managers.
Overall, the licensee's performance during major projects involving
high levels of radioactivity demonstrated thorough planning and
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preparation, good procedure development, and the establishment of acceptable radiological controls. This was evident for the Unit-1 IHSI/ Weld Overlay, Extraction Steam Line Replacement, and TIP Over-haul. Adequate management review and oversight.is.usually evident
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
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and. schedules to reduce personnel exposure.
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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'
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be implemented and provided sufficient technical and practical in-
structions to assure competence. The licensee also implements a
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generally effective radiation worker training program to assure that radiation workers are aware of radiological safety procedures and
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able-to implement them competently.
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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 manner.
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Conclusion Rating: Category 2
Recent Trend: Consistent.
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Board Recommendations
Licensee:
Evaluate specific training for first-level supervisors as a measure for improving adherence to requirements. Upgrade
~ dherence to routine radiation protection requirements by individual
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NRC: None.
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- Maintenance (347: hrs.,16%)
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Analysis
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Maintenance received the close attention of both resident and re-
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Tgion-based inspectors during:the~ assessment period. During-the
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previous two SALP. periods, ratings of Category I were-assigned.
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No areas-of general weakness ~were noted during those periods.
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In mid-1984, the overall maintenance program received a comprehen-
sive NRC review using a standard NRC Region.I. audit plan.. Job.
~0rders, Maintenance Requests, Machinery History Cards, Plant.Inci-
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dent Reports, Licensee Event Reports, Monthly Operating Reports',
and the Daily Activities Log -were audited. No reportable equipment
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degradation or failures were disclosed which had not been documented
'.as Licensee Event Reports or which were missing from the Monthly
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Operating Reports. Records showed no repetitive maintenance beyond
routine lubrication, cleaning, and valve packing adjustment for nine key systems. Machinery History Cards we're.being maintained manually
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for.each system-to the component 1evel. Machinery History Cards.
. ere found to be accurate and timely. -The. accuracy and completeness
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' of' maintenance documentation and the.close and consistent involve-
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ment of supervisors'.in day-to-day maintenance were noted as signi-ficant strengths.
- Another aspect of the NRC programmatic assessment involved mainten-J
-'ance personnel.
Interviews with maintenance technicians,'supervi -
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-evolutions. The; involvement of foremen and supervisors in field
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work was found to be consistent and extensive. :The maintenance
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staff is a mix of experienced personnel present.since construction,
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 staff and
. supervision'of the maintenance department were found to be notable
strengths.
- A second programmatic inspection was conducted during November 1984
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. by region-based inspectors. The inspection was directed toward
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post-maintenance and post-modification testing. The inspecters re-
' viewed 35 safety-related work packages.from the_ Maintenance Depart-
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ment and 15 packages from the Instrumentation and Controls Department
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to verify correct classification and appropriate post-maintenance
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testing. The program was found to include written procedures, cri-
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teria,.and responsibilities for post-maintenance testing. The in-
spection concluded that an acceptable program is in place and is
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being implemented.
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?The licensee implemented a corporate-wide maintenance management
'
. *
system during the present SALP period. Maintenance is still per-
,
- '
formed to departmental procedures. However,:the autherization and
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 records.
Since each
equipment is being identified within-the centralized and auto-
'*
mated system, machinery. history will be available throughout the
'*
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
- 1 usage and is used for resource management. Maintenance,-and~sur -
.
- veillance~may.then-be prioritized and scheduled.
._
The resioent inspectors observed portions of 39 maintenance evolu-
tions for procedural compliance, safety, work practices, and docu-
- ~
mentation.
No breakdowns in program implementation were observed.
.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
.
Insufficient management. involvement was apparent in.both cases.
- -
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-
c, mitment.to establish a more formal program for shelf-life detarmin-
.ation and control,.an audit conducted late in 1984 found little
evidence of program implementation. Specifically, shelf-life. data
.had not been requested fram vendors and shelf-life had not~been
evaluated during QA acceptance inspection. Additionally, the audit l
- 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-life had not been included in the licensee's program.
'*
"
Concerns related to the storage of low-hydrogen welding electrodes
'
. arose during an inspection in-mid-1983. These electrodes are stored
'*l in ovens at elevated emperature to limit moisture absorption.. Re-
sponsibility for calibration _of the oven temperature monitors had
- .
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 tquipment 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
!
i* Asterisked?1ines are common to Units 1 and 2
.
.
.
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commensurate with system-application. The current manual program was judged to be effective. An automated system is planned for in-
-corporation in the Production Maintenance Management System.
Vendor interfaces'were also examined during the assessment period.
-The program was found to contain the essential attributes of Regu-llatory 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.
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 management.
The involvement of Quality Assurance in modifications was generally 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 operator training, receipt inspection of thermocouple wire, work practices, and documentation packages of a total of 53 QA surveil-lance reports provided the basis for this judgement.
2.
Conclusion Rating:
Category 1
'Recent Trend: Consistent 3.
Board Recommendation
Licensee:
Improve shelf-life program and storage program for
welding electrodes.
NRC: None.
'* Asterisked lines are common to Units 1 and 2.
_
h.
g
.
.
D.
Surveillance (333 hrs., 16%)
1.
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 procedures.
- 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 1 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 it.
NRC audit of 4 Unit 1 and 7 Unit 2 technical specification amendments verified that sur-
veillance procedures were updated when technical specifications were
changed.
(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-lance " monitor" reports by QA. The reports were found to be critical
and to reference INP0 guidelines.
Suct, reports are forwarded to the unit superintendent for action and to the corporate QA manager
for trending.
A detailed review of the Hydrostatic Test Program used at Millstone 1 assess,d the conformance of the program and its implementation u
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. All aspects reviewed either conformed explicitly to code requirements or were reconciled as acceptable.
l The containment leak rate test was performed in accordance with the L-prescribed regulations and guidelines. Test personnel were cogni-zant of the physical meaning of the test results. 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 i
'
- Asterisked lines are common to Units 1 and 2.
_
--
--
- - - --
r
involvement. The licensee considered repair of leaky valves during the-test. That would have resulted in a " failed" test. This shows inadequate technical understanding of these activities.
. Detailed technical._ review of procedures, practices and, where ap-
propriate, independent calculation of results of specific aspects
of Surveillance disclosed no significant problems. The aspects reviewed include Core Power Distribution Monitoring, Chemistry, Radiation Monitor Calibration, and In-Service Inspection. The ap-plication of a computer-aided Ultrasonic Data. Recording and Pro-cessing System (UDRPS) was a technical inovation which was favorably commented upon by both a metallurgist and a Non-Destructive Evalu-ation specialist from the regional office. UDRPS was used for ad-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 available.
In another effort to learn about potential defects, the licensee had a weld radiograph taken during plant construction electronically image enhanced. This was done after a through wall axial defect opened in tNe base metal during induction heating stress improvement
~ (IHSI) 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 metal.
The Instrument and Control Department has develc,ed several programs which hrae improved the reliability of plant equipment. Specifi-cally, these have 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 reli-ability of the Emergency Gas Turbine Generator. By trending the contact resistance of micro-switches within instruments, the licen-see has been able to limit instrument setpoint drift by replacing components at the first sign of degradation.
Likewise, various parameters of the Emergency Gas Turbine Generator are included in trending programs. Those programs, along with new system alignment procedures, have improved the reliability and operating performance of the gas turbine during the SALP assessment period.
2.
Conclusion Rating:
Category 1
.
Recent Trend: Consistent.
- Asterisked lines are common to Units 1 and 2.
__
,...
-
.
.-
- _.
_.
{.,-
- .
._
18-3..
- Board Recommendation
~ Licensee: Upgrade QA of critical surveillance testing such as
- -
.-containment integrated-leak rate testing.
'NRC: None.
.
,
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i L
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-
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.
II
- Asterisked lines are common to Units 1 and 2.
-
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.
. E.'
Fire Protection / Housekeeping (42 hrs., 2%)
, --
1.
- Analysis
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 inspections.
- '
- -
These efforts included a detailed programmatic inspection by a. fire
- '
protection. specialist Because of. incorporation of fire protection
.
land housekeeping checks in daily' resident inspector tours, the
'
- l-actual inspection effort expended.on fire _ protection and housekeep-
'ing is significantly more than the. tabulated total.
The facility is generallyLkept clean and graffitti-free. -A high state of cleanliness is readily observed in the reactor building,-
-
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 fields. But all may be entered without protective clothing. The licensee continues to make steady improvements in-
"
_ plant housekeeping. Management inspections are conducted both dur-ing;the operating cycle and then more frequently during outages.
Supervisors for work-in progress are required to accompany the superintendent inspecting an area. There is a very strong emphasis
-
on housekeeping during these inspections.
,
In contrast with the station interior, large yard areas are heavily
<
,"
cluttered with spare, excess or staged equipment including a large
_
,
'*
- quantity of material and trailers labelled as radioactive. This-
condition has degraded over the appraisal period.
V
'.
-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 employed.
Fire 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-
- -
'
,U
=*
ably on the effectiveness of fire protection training.
('
b LThe programmatic _ inspection included detailed review of licensee measures to control ignition sources, solid and liquid combustibles,
,
L-
. transient combustibles, and general housekeeping. These were deemed
-
to,be adequate..The organization for' fire protection was found c -
to be adequatelyistaffed.
l.
-
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-
'* Asterisked'11nes are common to Units 1 and 2.
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~2.
Conclusion'
'
Rating: Category 1
- '
Recent Trend:
Improving.
- 3.
Board' Recommendation
- ~
Licensee:. Address the cluttered yard condition.. Resolve Appendix
- -
R: implementation.
- -
NRC: 'None.
.
,
I'
.
.
- Asterisked. lines are common to Units 1 and 2.
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_ - - -.. _.. _.._,
. - _ _ _, - _. _ _
_ _
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-.
F.
Emergency Preparedness (169 hrs., 8%)
1.
Analysis
The. previous SALP 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-
- '
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-
'
any 21-24, 1984. At that time, it was noted that corrective actions
were complete on Item (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 requirements.
The training of the emergency response personnel with the new pro-
gram was scheduled to be completed by June 30, 1984. 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 item exceeded two years.
-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 correctite actions described by CAL 84-10
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 exercise.
During 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 exercise.
The licensee has been responsive to NRC initiatives. Acceptable
responses were proposed with the exception of the training item
noted above.
- Asterisked lines are common to Units 1 and 2.
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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 activities.
- 2.'
Conclusion
'
Rating: Category 1.
.
Recent Trend:
Consistent
J3.
Board Recommendation
Licensee: Evaluate measures for assuring timely completion of
action items.
NRC: -None.
~*
.
%
i
+
'* Asterisked lines are common to Units 1 and 2.
.
~
G.
Security and Safeguards (63 hrs., 3%)
1.
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
- -
. IV violations were identified by a region-based inspector. One Level IV violation was identified by a resident inspector. The
violations were administrative in nature. Corrective actions were
accomplished immediately. Similar violations did not recur.
Management attention to the security program has been evident-and
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
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
_
completion of barrier construction and related modifications. The
smoothness with which these activities are being accomplished is
- -
indicative of management involvement in the planning, scheduling
- '
and coordination of the project.
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
by NRC/NMSS remains to be conducted.
- A comprehensive corporate security audit program continues to be
a strength of this licensee and demonstrates the licensee's commit-
ment to a quality security program. Audits are conducted on the Security Plan, Safeguards Contingency Plan and Training and Quali-
- fication Plans throughout the year such that the overall audit pro-gram is completed by year's end. The in-depth scope of the audit
program, which uses both USNRC Inspection Procedures and licensee
requirements, has contributed to reducing incidents of non-compli-
ance especially during the later portion of this assessment period.
This performance improvement is particularly significant in light
of the fact that two major outages occurred during thic period.
- Asterisked lines are common to Units 1 and 2.
_
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-
-
,
---
__
.
,_
_
.
.
_, _. _ _ _...
.
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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 period.
- l TheLevent-reporting system is-consistent with NRC-requirements. The r
.
licensee reported thirteen security events during this period.~ Ten
- .
.of these resulted from computer and/or. multiplexer system failures.
A:potentially:unmonitored access path into a security area was dis-
-
covered and reported. One eventL was caused by' a failed door alarm
- l switch andsone. involved a: security officer who was. inattentive to
- -
his duties. The reports were timely and generally complete.
Im-
- -
.provement in thefquality 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
- -
v 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 event.
More recent repc ts.have, however, shown improvement in the scope
of details discussed.
- Security organization staffing is currently adequate to meet the
existing security program requirements.. Staffing plans and funding-1*
-to meet expanded site:needs for inclusion of Unit 3 are already in l place and demonstrate management's sensitivity to prior planning.
- -
-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 employees.
'*-
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-
'
- -
b correct theLpotential deficiency.
,.
p:
2.-
Conclusion l:
Rating: Category 1.
f p,
'Recent Trend: Consistent.
- -
d 3.
Board Recommendation
None.
~
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'
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- Asterisked lines are common to Units 1 and 2.
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.
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.
.
. -
.
-
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H.
Refueling and Outage Management (124 hrs., 6%)
1.
-Analysis Performance in refueling and allied areas received 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-Inspection (ISI) outage from April 14, 1984 through June 28. 1984.
Refueling preparations received _close scrutiny.
Procedures, in-cluding vendor procedures, were prepared and submitted to the Plant Operations Review Committee well in advance of the outage. Those procedures were independently reviewed by NRC inspectors and_found to contain sufficient detail for the evolutions described. Analyses 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 on the forehandedness of individuals in key positions and strong management support for planning.
.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 were certified jointly by the fuel vendor and the licensee as " Level-I Fuel Inspectors" as a minimum.
Inspections for this type of fuel involve numerous measurements with special
. gauges as well as visual examination. Both inspection conduct and results documentation were well executed.
A major outage objective was the ultrasonic 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 in introducing an automated " Ultrasonic Data Recording and Proces--
sing System" (UDRPS) to aid in flaw evaluation.
Large scale appli-cation of Induction Heating Stress Improvement (IHSI) to 88 Reactor Recirculation System welds, 6 weld overlays, and weld / piping re-
_
placement work efforts were conducted based upon the ultrasonic testing program results. Both region-based and resident inspectors commented upon the highly effective management involvement in con-tractor control and quality assurance as well as in the high degree of technical competence displayed by the Northeast Utilities Non-Destructive Examination engineers.
_
The licensee has committed personnel and financial resources to
computer-based outage planning. The detail provided by these sys-
tems has proven to be a key ingredient in successful outage planning.
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 within cer-tain areas of the plant and by organizations supporting the outage.
- Asterisked lines are common to Units 1 and 2.
_
-
,
[
'
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 inoperable.'
_
'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'
f and conducted as part of the modification. The tests-had been ap-d proved by senior engineering staff as well as.the Plant Operations
-
Review Committee.
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 errors.
Inspection findings documented a-lack of licensee follow-through
.to verifyLcomplete implementation of commitments made to the NRC.-
~The licensee had failed to place locks on all containment isolation
-
valves addressed in the' Systematic Evaluation Program.
In addition,.
- three isolation. valves were not isolated to meet an additional commitment. However, the unlocke'd valves were properly positioned, and blank-flanges' had been _ installed in lieu of-the additional isolation valves. The failure to comply'with the commitments therefore was significant from the administrative control viewpoint but had no safety impact.
2.
Conclusion
..
Rating: Category 2.
.
Recent Trend: No Basis.
p
.3.
Board Recommendation-L
-
Licensee:
Improve self-assessment to identify' items such as failure L
to follow through on commitments and design modifications.
._
NRC: None.
<
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-
- Asterisked lines are common to Units 1 and 2.
.
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Licensina
. -
,
' 1.
- Analysis-
'
This functional area had been rated-Category -1 during the previous-
.SALP. assessment period. Stable performance has been observed.
In
. general', the' licensee's performance in: licensing matters shows
.high-level management.involvment, clear understanding of technical-
' '
tissues and responsiveness to'NRC initiatives. The basis of this
' '
' appraisal:was the-licensee's performance in support-of -licensing actions 1that were either completed or active.during,the-rating period.- 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 ongoing actions.
.The ongoing actions' include " Emergency Capability" (NUREG-0737 Sup--
.plement 1,) Fire Protection (10 CFR 50 Appendix R), containment
-
x D
purge and vent issues, post-accident hydrogen control, and piping i'
integri ty.-
(Specific licensing actions a're tabulated at the end
--
. of_this functional area.) Although additional efforts are needed
- to resolve the' remaining active issues, the licensee ~has thus'far
'
~
been. responsive to staff concerns and priorities.
,
.The licensee has exhibited an understanding of the issuesiin the resolution of technical questions with'a conservative approach rou-
-
tinely' employed when a potential for safety significance _ exists.
- -
One-example of this.related to primary containment inerting. Com-r bustible gas control during reactor operation and post-accident.
'
period depends on_ limiting the oxygen concentration to less than
k 5%.. Millstone 1 has 'a technical specifi. cation _ oxygen limit of 4% -
but normally operates.with levels of about 1%. This extra measure
+
of-conservatism typifies-the importance which the licensee attaches to safety.
-
I A numb'er of commitments for analysis and implementation schedules.
have been missed through the assessment period, however. _' Some of -
..
L~
these omissions have resulted from-confusion' involving. Integrated
~
n
.
System _ Analysis Programs (ISAP) and the implementation of,so-called L
"living schedules.".'One example of a lack 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 y.
commitment difficulties experienced have been given relatively lit-t1e weight in this appraisal. However, additional licensee effort-is needed to assure proper observance of schedules and commitments.
'
In~ summary,' licensee performance was good overall, but with recur-t
- :
rent response timeliness problems.
.
..
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-
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L 2.~
' Conclusion
~ Rating: Category 11.
- ^
'Recent Trend: Consistent.
- 3.
Board Recommendation:
,
.
^
Licensee:
Improve managemen'tofllicensingactivitiestoavoidlate-
- *
- ~
responses.'
Improve' coordination of. activities with'NRR in regard
'*
- to schedule, prioritization, and project status.
TABULATION OF LICENSING ACTIONS
'
-
Multi-Plant Actions'(Completed)
Mark I Containment Long Term Program Implementation.
---
Control of Heavy Loads Over Spent. Fuel Pool (NUREG-0612)
-+
"'--1 Reactor Protection-System Power Supply-
-- sTechnical._ Specifications Defining Operability for Safety Systems l Implementation of-NUREG-0313,'Revisioni1
--
- NUREG-0737; Item II.B.3.2,-Post Accident Sampling _ System Modifications
--
NUREG-0737, Item II.K.3.30,.Sma11 Break LOCA Methods.
--
NUREG-0737,-ItemLII.K.3.45, Manual Depressurization
_ _
-'
NUREG-0737, ItemLII.K.3.31, Compliance with-10 CFR 50.46
--~
~ NUREG-0737,; Technical Specifications.
--
4:
'--?
NUREG-0737, Item II.K.3.16, Challenges and Failures of Relief ValvesL NUREG-0737, ~ Item II.K.3.28, Verify Qualification of Accumulators on Auto
- - ~
.
JDepressurization System Valves l
Plant Specified Actions (Complete)
p
~
Integrated Structural Analysis (SEP)
--
-- ; Missiles (SEP)
(
--- ~ Seismic Design (SEP)
' Motor Operated. Valves (SEP)
!
-
--
L-Leak Detection (SEP) _.
-
--
Water Chemistry (SEP)-
--
'
~
- - - -
~ Battery Instrumentation and TS Limits (SEP)
' Activity Limits.(SEP) '
--
Audits'of_ Emergency and Security Plans Relating to Generic Letters 82-17'and-
---
82-23'
L-
Review of Modified Amended Security Plans per.Eisenhut Memorandum May.16,?1983
--
- Integrated. Leak Rate-Test in Less Than 24 Hours
--
- Evaluation of-NNEC0 Quality Assurance Report Submitted by NNECO letter June
--
19, 1983
' Required ATWS' Actions Generic-Letter 83-28
--
LAdministrative Technical-Specification Changes c
~ - - '
-
Technical Specification Clarification Related to Fire Protection-Detection
--
m v.
.
,
,.
.
e
_
'
Response to NNECO November-18,-1983 Station Training
--
Recirculation Line Pipe Crack Clamps
--
New Steam Unnel Ventilation. System Isolation by Radiation Signals
--
.Evlauation 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
--
Testing 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 I to NUREG-0737-
" Emergency Capability," Appendix R - Fire Protection exemption requests, contain-ment purge and vent requirements, the need for post accident hydrogen recomoiners, and detection and repair of pipe weld cracks in the primary coolant recirculation piping.
V.
SUPPORTING DATA AND SUMMARIES A.
Investigations and Allegations None.
_
B.
Escalated Enforcement Actions 1.
Civil Penalties A civil penalty associated with a Severity Level III Violation was-issued July 11, 1984. That civil penalty, which was mitigated en-tirely, resulted from installation errors in the Post Accident Sampling System.
2.
Orders A June 19, 1984 Order confirmed the implementation schedule for outstanding items within the TMI Task Action Plan concerning emer-gency. response planning.
3.
Confirmatory Action Letters None.
C.
Management Conferences An enforcement conference was held on November 14, 1983 to discuss vio-lations-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 rnd Millstone Unit 1 plants on July 11, 1984.
.
-D.
Licensee Event Reports 1.
Tabular Listing Type of Events:
(A)' Personnel Error
.(B) Design / Man./Const./ Install.
(C) External Cause
>
(D) Defective Procedure
(E) Component Failure
(X) Other
_5 Total
____
e.-
6:
,,
"
.
-
Licensee Event Reports Reviewed:
iReport Nos.-83-26 to 85-02, including 13 Security and 5'Environmen--
tal Reports common to both Units 1 and 2.
- 2.
Causal Analysis Seven sets of common mode events were identified. The first two-are common to Units 1 and-2:
a.
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).
b.
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 concen-trations exceeded the control station average by greater than a factor of ten (Environmental Reports 83-04,-05, and -06; LERs 84-03, and -07.). This has been an' ongoing situation, and 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 radiation.
c.
There we're'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).
d.
There were two reports of inoperability of the Reserve Station Service Transformer, both due to insulator problems, one fail-ure and one-excessive salt contamination.
'e.
One report addressed twenty-three welds which were rejected following NDT for IGSCC (LER 84-08).
f.
One report addressed ten hydraulic snubbers which failed func-tional ~ testing (LER 84-09).
g.
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).
-r
3.
Licensee Event Report Analysis An analysis of Licensee Event Reports (LER) indicates a high level
'of performance. However, because.10 CFR 50.73 redefined the re--
quirements for submitting an LER, there was a change to the data base on January 1,1984.
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 "typi-cal" BWR-of NUREG/CR-2378.
The _ratto 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.
-,
-
. _.
_
-33 TABLE 1 TABULAR LISTING OF LER's BY FUNCTIONAL AREA
.
MILLSTONE NUCLEAR STATION, UNIT 1 AREA-NUMBER /CAUSE CODE TOTAL A.
Plant Operations 1/C 8/E
B.
. Radiological Controls 5/X
'
C.
Maintenance & Modifications 1/8
D.
. Surveillance-2/B, 1/C, 6/E-
.
E.
Fire Protection / Housekeeping 1/D
F.
G.
Security & Safeguards 2/A 11/E
H.
Refueling & Outage Management
I.
Licensing Activities
_0 TOTAL
Cause Codes A --Personnel Error
.B - Design Manufacturing, Construction or Installation Error C - External Cause D - Defective Procedure-E - Component Failure X - Other
. -. -
,
. _,. _.
.
. _.. - -
-,_
.-
-
. - _
-.,
.
.
..
... -
-
-
.
P
-
!
.
.
=
.
r TABLE 2
.
INSPECTION HOURS SUMMARY (9/1/83 - 2/28/85)
~
-
I MILLSTONE NUCLEAR STATION, UNIT 1 f
Hours
% of Time r
i A.
Plant Operations 714
e 8.
Radiological Controls 318
"
-.
[
C.
Maintenance 347
y
+
'f D.
Surveillance 333
E.
Fire Protection / Housekeeping
2 h
F.
~
G.
Security and Safeguards 63-
E'
c H.
Refueling and Outage Management 124
=
.
.
-
I.
Licensing Activities
--
--
TOTAL 2110 100 7-Note:
Licensing personnel time is not included in SALP.
"
I K-'
M
-
"
'"i
=
.
.
_
y
..
i N
-'
,
"
_
.
-
L
.
-
V
.
- - -
-
e
,.,
--
,a
~
-.
- . _c
,
..%-
'
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'.4!
_
X
- 4.-
.35
-
~
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'
-
,
.
u-tQ.
-
-,..
+:
' TABLE 3'
'
VIOLATION SQ9tARY'(9/1/83 - 2/28/85).
~
MILLSTONE NUCLEAR. STATION, UNIT 1
~
m
..
.
..
.
.
.
-
s; A.~ ~ Number and Severity Level of Violations
'
LSev'erity[LevelI
'
Severity, Level. II O
Severity'LevelcIII 2:
, '1 Severity Level IV
Severity Level.V
<
1 ' Deviation
_0 Total
a
,
[
B.
Violation by-Functional Area
'
Functional Area Severity Level I II III IV V DEV'
~
1.
-Plant,0perations i
12.
Radiological Controls
4
'3.
Maintenance'& Modifications 14. -
Surveillance
5.
Fire. Protection & Ho~usekeeping 6.
'7.
-Security and Safeguards
77 8.
Refueling and Outage Management *
'l
.
-
9.-
Licensing Activities Totals
0'
8 0
,.
-. -
'
modification installation and testing is reviewed from the viewpoint of inadequacies
- in managing the_non-recurrent evolution of system installation and testing and is-l included =in outage management.
W
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.
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_
-36 C.
Summary Inspection'
" Inspection Severity : Functional Report No.
Dates-Level Area Violation
- 83-16-
- 9/26-30/83 IV 7-Failure to control security ~'
keys.
IV.
Failure to acknowledge
security alarms.
83-20 10/30-11/4/83
.IV
Failure to properly review procedural change.
84-07 4/2-6/84 VII
Failure to properly install thel 11guid Post-Accident Sampling System.
84-11 5/6-6/9/84-IV
Failure to follow Radiation Work Permit (RWP).
a
.84-13 5/29-6/1/84 IV 2~
Failure to follow RWP.
IV-2 Failure to cantrol internal exposure.
185-02 1/14-2/24/85 IV
Failure to calibrate nuclear instrumentation.
- IV
Failure to maintain a clear isolation zone.
85-03 12/28/84 III
. Failure to control free-standing liquid in a solid waste shipment.
l l-t-
l-:
I l
l'
i'
I
- Asterisked lines are common to Units 1 and 2.
.
.
.
.
.-... -.
.
-.
.
...
..
-
.....
.
--
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - -
._
I1
.'
s:-
. TABLE 4
' REACTOR TRIP AND OUTAGE SUMMARY (9/1/83'- 2/28/85)
MILLSTONE NUCLEAR STATION, UNIT 1
- A.
UNPLANNED AUTOMATIC. SCRAMS
.There were no automatic scrams during the eighteen-month appraisal period.
B.
FORCED OUTAGES-DATES POWER LEVEL.
CAUSE 1.
11/26-28/83 Shutdown from'100 percent Repair of a defective recircu-power.
lation pump seal.
2.
8/2-4/84 Shutdown from 100 percent Repack leaking instrument isola-power.
tion valve located in the primary containment.
g,.
.
_ _ _
___---._-__--_-_-____--_---_2--
- _ - -. - - -. _ - - _ _ _. - - - -.
_ _ _
_
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
_
Station security program and implementation.
(Specialist)'
83-17
.
Routine inspection including followup of gas turbine (Resident)
trip.
83-18-
Routine inspection including followup on Post-Acci-'
(Resident)
dent Sampling System installation error and reactor core power distribution calculations.
83-19
.
14.5-Quality Assurance Program including storage.
(Specialist)
83-20
Radioactive effluent control and monitoring.
(Specialist)
83-21
Routine inspection, including high containment leak-
~
(Resident)
age rate.
84-01
Routine inspection including repairs to turbine (Resident)
extraction-steam piping.
84-02
Routine inspection including repairs to safeguards
- ( Res~f dent)
pump and potential for containment vent header cracking.
84-03
Emergency Preparedness Program.
.(Specialist)
84-04
Radioactive materials packaging and transportation.
(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 outage.
84-06
Nonradiological chemistry analysis including quality (Specialist)
control of analytical measurements
-
.
.
.
._
.
-39 Report Number : Inspection Inspector (s)
Hours Areas Inspected 84-07
Post-accident monitoring equipment installations (Specialist)
made to implement commitments of a Confirmatory Order dated March 14, 1983.
,
84-08-135 Routine inspection including refueling / maintenance f(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 outage.
84-09
Emergency diesel generator maintenance.
.(Specialist)
84-10 5.5 Quality Assurance for design, installation and oper-
_
(Specialist)
ation of PASS.
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 outage.
84-12.
Repai'. of IGSCC detected in reactor piping.
(Specialist)~
84-13
.
Radiation protection during a refueling / maintenance (Specialist)
outage.
84-14
Station security program and impl'ementation.
(Specialist)
84-15
Fire protection /prevencion program.
(Specialist)
84-16
Emergency diesel generator maintenance.
(Specialist)
84-17-None Administration of NRC licensed operator examinations.
-(Licensing Examiner)
-84-18
Containment local and integrated leak rate testing.
(Specialist-Resident)
_
- -.
-
-.-.
.
-
~$
~
'
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_
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4-
'
.
w,
,
!ReportlNumber' Inspection Inspector (s)-.
Hours.
Areas Inspected-
'F
- J84-19 155 Routine inspection including refueling / maintenance
~
.
,
(Resident)
activities ~, the primary containment integrated leak'
rate test, safeguards electrical bus testing,Lthe
'
integrated safeguards system actuation testing, the feedwater coolant. injection:sub-system. test, the reactor vesse1~and~ recirculation hydrostatic test and reactor startup-testing, and maintenance.84-20l 145L
' Routine inspection including licensee response to
'
s(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 loads.
l84-21
_
Routine inspection including' licensee' response to l(Resident)-
single control rod scrams and a review.of the.me-s
,
chanical snubber surveillance program.
'84-22'
Administration of NRC licensed operator examinations (Licensing Examiner)
and review of'requalification training program.
84-23
.
179 Emergency preparedness exercise.
(Specialist-
..
- Resident)
'84-24.
.
26.5 Radiation protection program.
,
~ (Specialist)-
-84-25
. Special-. inspection of NRC Generic Letter 83-28 for-
.(Specialist)'
equipment classification and vendor interface.
.
-
--84-26'.
'
46.5 Routine inspection including containment isolation
-,
,.
!(Resident)'
ator (EGTG) operability after. finding an air-start
'
function of PASS lines, Emergency Gas Turbine Gener-
-
system. failure.
-
- 84-27-
- 117 Routine inspection including EGTG operability fol-
-(Resident)-
lowing transmission.line transients, and verification'
of' commitments concern cg flooding, off-normal.
operating procedures, iccked containment isolation ~
- valves, surveillance testing, Reactor Protective System power' supply isolation. devices, degraded grid voltage procedures, and EGTG improvements.
<
85-01
.
32.5 Quality Assurance Audits, Surveillance and Monitors.
(Specialist)-
-
.
~
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-
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,
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.41 n.
Report. Number: iInspection
, ' Inspector (s)
Hours-Areas Inspected-
-' 85-02-
'113'
- Routine inspection including nuclear instrumentation
'
.
- (Resident)~
. calibration,: compliance with 10 CFR 50.54 for a
.f; senior licensed operator in the Control Room, a
~
m,.
- reactor. recirculation system flow anomaly resulting
-
3-in a reduction in reactor jet pump efficiency, and
&;15.,.,.,. 4 loss 'of power at Emergency Operations Facility.-
.s
-
Ng;&
_.
..
.
85-03
.
None
-
Radioactive waste _ shipment deficiencies.
'
~ J(State _ofSouthCarolina)
.
i
_
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,
e
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V-E-
_
l TABLE 6 LER SYNOPSIS (9/1/83 - 2/28/85)
MILLSTONE NUCLEAR STATION, UNIT 1 LER No.
Summary Description 83-26-Emergency Gas Turbine Generator shutdown because of a defective speed switch cable.
83-27-Setpoint drift, isolation condenser initiation time delay relay.
83-28 Offgas radiation monitor failure.
'83-29-Setpoint drift, high drywell pressure switch.
-83-30 Inoperable containment isolation valve 1-MS-6.
83-31 APRM Channel failed to trip when placed in an inoperable condition.
83-32 Excessive drywell leakage due to recirculation pump seal failure.
83-33 Standby Gas Treatment Subsystem B degraded by inoperable heater due to a defective relay.
83-34 Reserve Station Service Transformer Inoperable to correct oil leak.
- 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 surveillance.
- SEC83-06 Security-related computer failure, loss of alarm surveillance.
- 84-01 Security-related multiplexer failure, loss of alarm surveillance.
- 84-02 Security-related computer failure, loss of alarm surveillance.
- 84-03-Ag-110m in oysters, within 500 feet of discharge, in levels greater than the control station by
- or of ten.
.
- Asterisked _ lines are common to Units 1 and 2.
..
.LER No.
Summary Description 84-04-Potential.unmonitored access to security area.
' 84-05; Local leak rate testing of containment isolation valves identified 10
-
needing corrective actions.
84-06-Electronic noise causing nuclear' instrument RPS trip during a refueling outage, reactor had been in cold shut down.
- 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 one with an incorrectly installed poppet valve.
- 84-10
. Security-related computer failure, loss of alarm surveillance.
84-11 Failure of condenser bay area fire detection, low thermal supervisory air pressure.
84-12 Failure of four out of six safety-relief valves to open within one percent of specified set point.
- 84-13 Security related multiplexer failure, partial loss of alarm surveillance.
- 84-14 Security-related multiplexer switch failure, loss of alarm surveillance.
84-15 Failure-of containment isolation valve motor-operator, isolation conden-ser out of standby service.
- 84-16
'
Security-related computer failure, intermittent loss of alarm surveil-lance.
84-17 Excessive primary containment leakage, valve packing failed.
84-18 Failure of containment isolation valve motor-operator, isolation conden-ser out of service.
- 84-19 Security guard not performing duties.
- 84-20.
Security-related multiplexer failure, partial loss of alarm surveillance.
<.
.
- Asterisked lines are common to Units 1 and 2.
_
v e
e
=
ec
e y
,=
w
._
~44 LER'No.
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 function.
- 85-01 Security-related, failed door switch.
- 85-02'
Security-related computer failure, intermittent loss of alarm surveil-
-lance.'
~
.
-
l i
,
,
.
-* Asterisked lines are common to Units 1 and 2.
.
.
...
-
-
-
.
-
, a' *2 s
_3
-
-
.
?
1s-
_. _ -
-
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, COMBUSTION ENGINEERING DESIGN)
ASSESSMENT PERIOD: SEPTEMBER 1,:1983 - FEBRUARY 28, 1985 BOARD MEETING DATE, NL. 6,1985
...
m
..
y._
_
__
.
_.
'
t
.
TABLE OF CONTENTS Page
"
I.
' INTRODUCTION.........................................................
,
A.
Purpose and 0verview............................................
.
B.
.SALP Board Members...............................................
C.
Background......................................................
1-II. CRITERIA AND RATINGS.................................................
I I I. S UMMARY O F R ES U LTS...................................................
j.
. A.
- Ov e ra ll Fa c i l i ty Eva l ua ti o n..................................... 4 B.
Overall Evaluation of. Training.................................. 4 C.
Facility Performance............................................ 5 IV. P E R FO RMANC E ANA LYS I S.................................................
A.
Plant Operations................................................
8.
Radiological Controls..........................................
C.
Maintenance....................................................
D.
Surveillance...................................................
E.
Fire Protection / Housekeeping...................................
F.
~ Emergency' Preparedness......................................... 21 G.
Security and Safeguards........................................ 23 H.
' Refueling and Outage Management................................
I.
Licensing Activities.......................................... 27 V.
SUPPORTING DATA AND SUMMARIES....................................... 30 A. -
Investigations and Allegations Review..........................
-
B.
Escalated Enforcement Actions..................................
C.
Management Conferences.........................................
- D.
Licensee Event Reports.........................................
. TABLES-TABLE 1 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA..................... 33
- TABLE 2 - INSPECTION HOURS SUMMARY....................................... 35 TABLE 3 - VIGLATION SUMMARY.............................................. 35
' TABLE 4 - AUTOMATIC SCRAMS AND FORCED OUTAGES............................
TABLE 5 - INSPECTION REPORT SUMMARY...................................... 38
. TABLE 6 - LER SYN 0PSIS...................................................
i
.
A I
,
.
'I.
INTRODUCTION cA.
Purpose ~and Overview
,
The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect information periodically and evaluate licen-see performance. -SALP supplements the normal regulatory prccesses 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 safety.
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 report.
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 Feuruary 28, 1985.
B.
'SALP Board Members R. Starostecki, Director, Division Reactor Prcjects (DRP), SALF Board Chairman W. Kane, Deputy Director, DRP R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch, Divis.on 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 3B, DRP L. Rubenstein, Assistant Director, Core and Plant Systems, Division of Systems Integration, Office of Nuclear Reactor Regulation (NRR)
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D. 0:. rne, Licensing Project Manager, ORB 5, NRR
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J. Sheuiosky, Senior Resident Inspector, Millstone Units I and-2 Other Attendees D. Lipinski, Resident Inspector J. Shea, Licensing Project Manager, NRR R. Summers, Project Engineer, Projects Section 3B, DRP C.
Background
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1.
Licensee Activities This Combustion Engineering designed Pressurized Water Reactor was in an extended refueling / maintenance outage at the beginning of the assessment period. That outage, which began on May 28, 1983, was
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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 operation, when testing identified multiple resistance temperature detector channels with excessive sensor response times.
Following repairs, the plant operated at. full power-for 271 days until a scram was caused by main
. steam isolation valve closure due to a valve actuator failure on November 15. There was a shutdown on November 28 to protect the turbine after a feedwater heater tube rupture. Then, the plant operated at full power from December 1 until the end of core full power life on January 24, 1985.
The reactor was shut down for a fourteen week refueling / maintenance outage on February 16.
Extensive inspections and maintenance of the steam generators were scheduled for~the outage. The licensee committed significant-re-sources to remove sludge from the steam generator secondary. The sludge has been considered responsible for pitting degradation of steam generator tubes.
The reactor availability and capacity factors for 1983 were 34.2 percent.and 32.4 percent, respectively; and 93.5 and 87.6 percent in 1984. However, excluding the 1983 and 1985 refueling outages, these factors were 99.3 and 93.6 percent, respectively, for the eighteen month assessment period.
(These factors were computed by the resident inspectors using data from the licensee's monthly operation report.)
2.
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 period.
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Total NRC inspection hours (both resident and region-based) expended en Unit 2 were 2158..This is equivalent to 1439 inspection hours per year.
NRC Emergency Preparedness Inspection Teams observed full scale emergency exercises on October 5, 1983 and October 12, 1984.
There were no investigations conducted during the assessment period.
- bulations of Violations and Inspection Activities are appended
to this report.
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y-II.
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 area.
1.
Management involvement-in assuring quality 2.
Approach-to resolution of technical issues from a safety standpoint 3.
. Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting'and analysis of reportable events 6.
Staffing (including managtiment)
7.
Training effectiveness and qualification These criteria are not limiting; others are used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is clas-s'fied into one of'three performance categories. These are:
L 'Pr Jry 1.
Reduced NRC attention may be appropriate.
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 st.fety is being achieved.
Category 2.
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.dequate and reasonably effective so that satisfactory performance with respect to safety is being achieved.
Category 3.
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 achieved.
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. SUMMARY OF RESULTS
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A '.
Overall Facility Evaluation
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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
. operator and operations support performance and coordination was shown by a -271 day continuous run at power in 1984.
Licensee event report'
review showed a typical ratio of personnel-related to facility-related
. 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
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by facility management.
Instances of deficient licensee self-appraisal
were, however, evident.
The radiation protection and housekeeping programs were effectively ap-
plied to major activities. Good housekeeping has resulted in the primary
containment being accessible without protective clothing. Major activi-ties involving high radiation fields (ex: steam generator work) were carefully planned and controlled.
But there were multiple lapses in
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worker adherence to routine radiation requirements and repetitive prob-1 ems 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 radiation protection con-trols.
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In some cases, the licensee has not provided timely resnonses to the NRC.
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One such case involved shelf-life control for perishables and environ-
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.
'In summary, licensee performance has been strong in plant operations and
control of major activities. Significant lapses were noted in radiation
~ protection. Responses to the NRC need to be more timely.
There is a
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'need for more effective licensee self-appraisal.
B.
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
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noteworthy, including upgrading through training staff expansion in size and authority. A training department screening process has been imple-
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mented to correct a problem at Unit I with operator performance on in-itial 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.
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Training of non-operators was good, with Instrument and Controls depart-
ment training noted to be particularly effective.
- Asterisked lines are common to Units 1 and y7_
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C.
Facility Performance
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.. Category Category Recen't.
Functional Area
. Last Period-This-Period-Trend
.(9/1/82 -
-(9/1/83-8/31/83)
2/28/85)
1.
_ Plant Operations:
,2
Consistent-
2r. Radiological -Controls :
.1
Consistent 13.
Maintenance
1 Consistent
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4.
Surve111ance'
1 Consistent'
5.
Fire' Protection / Housekeeping
1 Consistent 6.1 Eme'rgency Preparedness
1 Consistent 7.
Security & Safeguards
- 1 Consistent
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8.
Refueling &-Outage Management
1-Improving-9._
Licensing Activities
1 Consistent-
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IV.
PERFORMANCE ANALYSIS
- A.
' Plant Operations (748. hrs., 35%)
1.
Analysis Operations, which includes engineering support, design changes and modifications, and management effectiveness received resident in-spection and the attention of twenty-one region based inspectors.
During the preceding SALP period, a rating of Category 2 was as-signed. Performance during that period was marred by several oper-ational errors and unplanned releases of radioactive material.
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 occurred from full power.
In each 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 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
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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 example, operators manually scrammed the reactor on November 28, 1984 to protect the turbine from damage due to water intrusion when the rupture of feedwater heater tubes flooded the heater.
Overall, control room performance was evaluated as highly profes-sional and effective. Other than normal security measures, control
room access was not restricted. Documents sent to the control room were not specifically pre-screened to avert undue burdening of the
operators. But business with the control room was required to be
conducted through one of the two senior licensed operators on duty,
and specific permission was required for non-operators to enter the marked off areas near the control panels.
Pre-evolution briefings
of operators were evaluated as thorough, appropriate, and well pre-sented. Procedures and drawings were readily available. There was
strong management emphasis on procedure adherence. Despite a lack of formal status boards, shift turnover controls and degraded equip-ment lists were found to be adequate in that the operators were found to be knowledgeable of equipment and activity status. The
- Asterisked lines are common to Units 1 and 2.
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" mimic". control. panel layout provided wasLeonsidered to be an.ef-
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fective operator aid and was updated as changes occurred. Watch-g stander demeanor.was considered professional. A change was' initiated
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to' reposition the operators' desks and seating to provide a better-view of.-thelcontrol panels. There was a notable absence of ex-
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't'raneous' material.
During this assessment period, there were no unplanned releases of radioactive material and no personnel errors of an operational 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--
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tributed to part or all of the.cause. Past problems have been
- evaluated internally through reviews conducted by Operations Depart-
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ment supervision and externally through a program supported by re-views by: station and INPO personnel. The licensee evaluates the human interface in every operational problem to determine the root cause'and appropriate. corrective actions. Occurrences of superior =
performance are.also-examined 1n search of procedural, hardware or-
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training improvements.
Evaluations are reviewed by station manage-ment.
'Of the reportable events during the 1983-refueling outage, two in.
volved errors with instrumentation and one involved transporting 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 (RPS) channels. The safety injection tank level problem was caused L
by the introduction of water into level ~ instrument reference columns incident to modification'to those instruments. The degraded RPS trip
"c functions were~ caused by. reversed nuclear instrument cables between upper and lower power range detectors. Contributing to the error in reversing the instrument cables were inadequate system drawings and procedures resulting from modifications made during'the initial plant start-up in 1975 and during 1981. In both. cases, control room operators observed and acted promptly on early indications of an abnormal situation.
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The onsite Plant Operations Review Committee (PORC) has been ob-
servedoto examine issues in a deliberate manner which established
a reasonably high confidence that issues important to safety have
'been evaluated. The resident inspectors attended 13 PORC meetings
without prior notification and found that the members maintained high standards. This was apparent in meetings held after the No-vember 15,-1984 reactor trip to evaluate any potential safety prob-lems. The series of PORC meetings conducted to review both the steam generator secondary chemical cleaning process and the recon-stitution of' irradiated fuel assemblies to remove leaking fuel rods patiently examined each process and' attempted to thoroughly develop
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any latent' safety issue.-The committee did not hesitate to generate
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^ commitments which required resolution or to return packages for
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. additional work.' The resident inspectors concluded that PORC review-
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quality is ; uninfluenced by the schedule for an activity.
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'The licensee is revising piping and instrument drawings. Drawing
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standards have been developed by the corporate organization.
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dividual drawings are being completely' revised following full veri-
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fication of components by engineering and operations personnel. The
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program involves significant input from operations to select a for-mat.for each drawing _in order to provide the best use to those people. The drawings are to be produced by corporate computer-aided
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design equipment. These initial drawings are the beginning of what is expected to be a larger program.
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Inspectors reviewing. licensed operator training and requalification have observed an ongoing evolution. Training Department responsi-
bilities expanded from simply instructing personnel to authority
_for pre-examination screening. 'An effective requalification train-
ing program is administered in a six week classroom series and one week of contractor simulator training.
Region I licensing examiners-participated in the requalification program, providing a section of the examination and conducting in plant walk-throughs. The in-spectors observed that the. program'has developed into a more mean-
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ingful exercise which requires licensed operators to maintain their-level of pla'nt knowledge. Annual examination quality has been im-
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proving. Operators failing a section of the examination receive-a performance evaluation by the training department, which reports
directly to corporate management, and may be ' removed from licensed
' duties. Training department staffing, which includes _ individuals
with senior operators' licenses, is expanding to meet the require-ments of simulator training. The simulator is under construction
and expected to be in use in 1985. There is good communication be-tween the training supervisor and the NRC licensing examiners.
There is~ good cooperation between the operating and training staffs, and the actions in progress should improve the already sound pro-gram.
The ratio of personnel-related events to facility-related events
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has increased from 0.21 during the last SALP cycle to 0.28. (The
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" typical" PWR of NUREG/CR 2378 is 0.26.) This ratio reflected per-sonnel errors associated with transporting loads over irradiated-fuel, improper safety injection tank level indication, and missing surveillance tests. The ratio of management-related events to facility-related events decreased from 0.24 in the last SALP cycle to 0.19. This compared favorably to the " typical" PWR ratio of 0.29.
LERs, both those-submitted prior to January 1, 1984 and under the
new requirements in force since then, were timely and complete.
- When additional information later developed concerning reported
events, updated LERs have been submitted.
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- Asterisked lines are common to Units 1 and 2.
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Region-based inspectors reviewed QA audit schedules and plans,
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documentation of 11 QA audits, 3 semi-annual QA review reports to
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' management, the QA monitor schedule, and 6 QA nonitor reports. The
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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
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the PORC. QA audit schedules and results are reviewed by the PORC.
The monitor program is conducted by the onsite QA staff.
It pro-
vides site managers with a separate view of the performance of
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personnel and evolutions. Corrective actions on audit and monitor findings generally are implemented promptly. The licensee is re-
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viewing the monitor program to identify ways to enhance its utility.
Overall, the audit and monitor programs are considered to be post-
tive contributors to quality and safety.
Control of vendor supplied services and equipment was reviewed.
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 analyses.
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 codes.
Communications between the licensee and NRC Vendor Programs Branch
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- inspectors affirmed the licensee's commitment to improve. One de-ficiency, however, warrants further emphasis. The licensee'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
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are certified by the licensee 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 level.
2.
Conclusion Rating: Category 1
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j Recent Trend: Consistent.
3.
Board Recommendations
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Licensee: Upgrade controls over computer codes, and particularly of associated qualification certifications.
NRC: None.
- Asterisked lines are common to Units 1 and 2.
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Radiologic'al ControlsL(271 hrs., 12%)
'1.
- Analysisi
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The licensee's performance for this period is' degraded from.the
_ performance'noted in the previous assessment. While no violations
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- c were noted in the last-assessment, five violations were identified
Jin the current period. This is of 'particular note since -the radi-
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- ation: protection program was subject to reduced _ inspection effort 1*-
due~to previously observed good performance.
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J The licensee's-radiation protsction program continues to be defined.
- by generally good. policies;and-procedures.
Resident and specialist
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-inspector reviews of this area-generally indicated consistent good
performance in the area of contamination control, personnel moni-
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toring, radiological surveillance and job control, instrumentation
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reliability and effluent control. However,_during this period, both
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residents and specialist inspectors observed l increased deficiencies
~ involving procedure establishment, implementation and maintenance.
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LFor example, on two separate occasions, the licensee performed tasks
.that were beyond the work that was authorized and allowed by job-
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specific radiation work permits. Though these occurrences were identified to the-licensee, corrective measures were not effective
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enough to prevent recurrence a short time later.
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Other procedural deficiencies noted during this period included the
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implementation of a change to the liquid waste discharge procedure
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-without administrative and technical review, and failure to adhere.
to the containment requirements of a 50ecial procedure used for fuel
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reconstitution. Additionally,.on one occasion, the~1icensee failed
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to implement procedures to prevent recurrence of conditions that
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resulted in an inadvertent sustained intake of airborne radioactive
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materials:by a worker.
For this event, corrective action was not
l initiated until the item was identified by an inspector 30 days
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1ater.
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 programmatic breakdown, particularly in view of the licen-f
'see's previously observed ability to adequately establish, implement
and maintain procedures.
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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
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of a portion of the reactor coolant sample acquisition pipe for Unit 1.
That would have prevented sample collection for certain modes
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~of operation. This finding was in nonconformance with an associated
Confirmatory Order previously issued to the licensee, and indicated'
that the licensee did not subject the implementation of post-acci-
dent modifications to thorough or technically sound review and test.
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' * Asterisked itnes are' common to Units 1 and 2.
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(This case was indicative of generic deficiencies in the licensee's
progt 'ns for plant modifications and engineering design changes.)
In response, licensee management initiated an ambitious program to
revise and upgrade design control practices.
Review of the licen-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 actions.
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While reviews by both resident and specialist inspectors generally
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indicate acceptable performance relative to the transportation of
radioactive materials, the State of So"th 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
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the licensee's state radioactive waste transport permit for one year
and assess a $5,000 civil penalty.
Previously, the state assessed a $3,000 civil penalty for a discrepant shipment received in Decem-
ber 1984, and formally notified the licensee 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-ing sufficient corrective action.
Since multiple and repetitive
violations were identified, programmatic breakdown is evident.
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Radioactive waste management was not reviewed this period.
Effluent
control and radiochemistry review indicated that the licensee was
effectively implementing the program in accordance with regulatory
requirements.
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. The 1985 goal is for a. ten percent reduc-
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tion from the 1982 through 1984 average.
The licensee has implemented a formal ALARA 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 available.
Reviews of this area indicate that the program is generally effec-
tive but does not always achieve established goals. The effective-
ness of the program has recently been enhanced by a corporate policy
which makes ALARA goals the specific responsibility of individual
managers.
Overall, the licensee's performance during major projects involving
high levels of radioactivity demonstrated thorough planning and pre-
paration, good procedure development, and the establishment of ac-
ceptable radiological controls. This was evident for the Unit-2
- Asterisked lines are common to Units 1 and 2.
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Thermal Shield Project and the Unit-1 IHSI/ Weld Overlay, Extraction
' Steam'Line Replacement, and TIP Overhaul. Adequate management re-
view and oversight is~ usually evident as demonstrated by sufficient
awareaess of daily activities, the establishment of generally ef-fective inter-departmental communications.and cooperation, and the
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effective use of planning meetings and schedules to reduce personnel
exposure.
Steam generator work involving high radiation fields is discussed in the Refueling and Outage Maintenance functional area.
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
training program for the radiation protection staff continued to
be implemented and provided sufficient technical and practical-in-
structions 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-
petently.
Additionally, the licensee has successfully completed corrective
actions on several previously identified findings, and has success-
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fully resolved open items in a timely manner.
2.
Conclusion Rating: Cate.jory 2.
- Recent Trend: Consistent.
- 3.
Board Recommendations Licensee: Continue recent emphasis on improving radioactive mate-
rial transportation controls. Assure better adherence to radiation
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protection procedures by workers.
- NRC:
Implement full inspection program for all elements of radi-
ation protection, emphasizing radioactive material transportation
and radioactive waste processing.
- Asterisked lines are common to Units 1 and 2..
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C.
Maintenance (339. hrs., 16%)
1.
. Analysis Maintenance received the close attention of both resident and re-
gion-based inspectors during the assessment period. During the
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previous'two SALP periods, ratings of Category.1 were assigned.
'No areas of general weakness were noted during those periods. The present SALP period included a refueling and maintenance outage extending from the beginning of the period into January 1984.
- During mid-1984, the overall maintenance program received a compre-hensive review using a standard NRC Region I audit plan. Job Or-
ders, Maintenance Requests, Licensee Event Reports, Plant Incident
Reports,' Monthly Operating Reports, and Daily Activities ~ Log were
audited. No reportable events or equipment failures were dist'.ed
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which had not been documented as Licensee Event Reports or whir a
were missing from the Monthly Operating Reports.
Records showed
no repetitive maintenance activities beyond routine activities such as valve packing adjustment, lubrication, and cleaning for nine key
systems. The accuracy and completeness of maintenance documentation and the close and consistent involvement of supervisors in day-to-
day maintenance were noted as particular strengths.
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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
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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 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 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.
Inspectors reviewed
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24 safety-related work packages from the Maintenance Department and
7 packages from the Instrumentation and Controls Department to ver-
ify correct classification and appropriate post-maintenance testing.
The program was found to include written procedures, criteria, and
responsibilities for post-maintenance testiag. The inspection con-
cluded that an acceptable program is in place and is being imple-
mented.
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- Asterisked lines are common to Units 1 and 2.
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, The licensee has a major program to extend the_ life of'the' steam
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generators _(SGs). There has'been extensive inspection of SG tubes -
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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 secon'dary water specifications are being established. Also, the licensee is replacing copper bearing alloys in the feedwater system.
Resident. inspection of-this major SG maintenance has identified
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strong management controls and careful: worker adherence to-proce--
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- 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
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positive displacement pumps as charging pumps and as high head safety' injection pumps. 'After approximately 5000 hours0.0579 days <br />1.389 hours <br />0.00827 weeks <br />0.0019 months <br /> of opera--
tion, the licensee observed an increase in the pump packing leakage and 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 analysis.
-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 program.
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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
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- 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 maintenance.
- -
It retains the machinery history type of information Aich 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. corporation.-
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- -
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 scheduled.
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- Asterisked lines are common to Units 1 and 2
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iThe. resident inspectors observed portions of 26 maintenance-evolu-Ltions for procedural. compliance,= safety, work practices,'and docu-
mentation.. Additionally, a region-based inspector conducted a de-
~
itailed review _of maintenance pertaining to the Reactor Protective-
" System (RPS): scram breakers. No breakdowns 'in program implementation
.
,
,were observed.
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 electrodes.
<
, Insufficient management involvement is apparent in both cases.
. *;
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
- -
Lnot been1 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-life had not been included in the licensee's program.
.
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. absorption.
Responsibility for calibration of th'e oven temperature monitors had
~
- not been' established. The inclusion of these monitors in rl regular
' calibration program remained outstanding through the end of the
v
.
inspection' period. The temperature monitors were apparently over-
, 1
"#t
looked:in calibration program revisions and reviews. Together,
these. items reflect a lack of sufficent attention to the details
'
of program implementation.
The equipment classification-program and post-maintenance testing programs were reviewed. An extensive review of safety-related sys-
'
tems, purchase orders, and Plant Design-Change Requests (PDCRs)
'
_
resulted in the conclusion that an adequate program to maintain system integrity is in place. The existing Materials, Equipment, Parts List (MEPL)_is being monitored as part of the computer-based Production Maintenance Management System (PMMS). A sample of 31
,
work orders classified as safety-related and 10 work orders classi-
. ffed as' non-safety-related were reviewed to evaluate proper classi-fication as well as proper specification and completion of post-maintenance testing. The program and its implementation were found to be well executed and well supported by plant management.
.:
- A'sterisked itnes are common to Units 1 and 2.
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'2.
Conclusion
!.
!
Rating: Category 1.
I f
'Recent Trend: Consistent.
!i 3!
Board Recommendation
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Licensee:
Improve shelf-life program and storage program for weld-
.ing electrodes.
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NRC: None.
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- Asterisked lines are common to Units 1 and 2.
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a D.
Surveillance (298 hrs., 14%)
i 1.
Analysis
_t Surveillance received the attention of the resident inspectors and i
region-based specialists. During the preceding two appraisal per-
?
iods, ratings of Category 1 were applied.
No continuing problems
-
or deficiencies have been observed.
The resident inspectors ob-
served a total of 56 surveillance tests.
f
A master Surveillance Control List correlates survefilances 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 1 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, j
and technical specifications.
The Engineering Department must make
that assessment, and PORC must review it.
NRC audit of 4 Unit 1 m
s
and 7 Unit 2 technical specification amendments verified that sur-
veillance procedures were updated when technical specifications were i
changed.
(A Unit 2 exception to this was found involving fagre a
to update ex-core power range nuclear instruments after a 19/d design
-'
change.) Site QA monitors surveillance testing.
NRC witnessed one
-
QA " monitor" of surveillance on Unit 1 and reviewed 4 surveillance J
" monitor" reports by QA. The reports were found to be critical and
.
to reference INPO guidelines.
Such reports are forwarded to the t
unit superintendent for action and to the corporate QA manager for i
trending.
'
_.
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-
-s proach to ISI problems.
Staffing, including the Level III Engineer
and inspection personnel, appears be adequate for the tasks at hand.
Contractors are used as required for specific tasks and are ade-g ouately controlled by the licensee. The ISI program is presently
'
in the last period of the first 10 year inspection interval.
Re-
gion-based specialist inspectors concluded that the ISI program is
-
of superior quality, indicating effective application of quality assurance principles.
2 Several innovations have been included in the licensee's programs.
j An Example is computer-based vibration analysis equipment.
This has provided a higher degree of automation with a more portable j
q l
vibration spectral analysis unit. Also, seismic piping snubbers-a
]
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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- Asterisked lines are common to Units 1 and 2.
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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 welds.
Detailed technical review of procedures and, where appropriate,
independent calculation of results of specific aspects of surveil-1ance disclosed no significant problems. The aspects reviewed in-
'clude Containment Leak Rate Testing, Chemistry, and Radiation Moni-tor Calibration.
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 Testing.
2.
Conclusion Rating: Category 1.
- Recent Trend: Consistent.
3.
Board Recommendation
None.
- Asterisked lines are common to Units 1 and 2.
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.E.
Fire Protection / Housekeeping (42 hrs., 2%)
1.
Analysis
.
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 inspections.
- 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 total.
Unit 2 is generally graffiti free. The-licensee has made steady improvements in plant housekeeping. 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 building, equipment access hatch area, the auxiliary building refueling water. storage tank pipe chase area, and the safeguards pump rooms.
Along with plant housekeeping, radiological cleaning and 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 outage.
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 thst the containment 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 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 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 favorably on the ef-
fectiveness of fire protection training.
- Asterisked lines are common to Units 1 and *
The programmatic inspection included detailed review, licensee meas-
- -
.ures to control ignition sources,l solid and liquid combustibles,
- l transient combustibles, and general housekeeping..These were deemed
- _
-to be adequate. The organization-for fire protection was found to be adequately staffed.
- There.was one violation
- penetrations through fire barriers were
_not appropriately sealed.
-2.
Conclusion Rating:
Category 1.
- -
Recent Trend: Consistent.
^
3.
Board Recommendation Licensee: Address the cluttered yard condition. Upgrade house-
-keeping in areas noted as candidates for improvement.
Resolve Appendix R implementation.
- NRC:
None.
1
- Asterisked lines are common to Units 1 and 2.
_
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i F.
Emergency Preparedness (250 hrs., 11%)
i 1.
Anilysis
The previous SALP 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-
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, 1984.
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 years.
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 corrective actions described by CAL 84-10 dated
June 5, 1984, issued after the May 12, 1984 Haddam Neck exercise,
had been completed prior to the October 12, 1984 Millstone exercise.
- During 1984, a temporary Technical Support Center (TSC) was estab-
lished within the Millstone EOF 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 exercise.
- The licensee has been responsive to NRC initiatives and acceptable
responses were generally proposed with the exception of the training
item noted above.
- Asterisked lines are common to Units 1 and 2.
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' *l The licensee's onsite emergency preparedness staff-consists of one
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full: time coordinator. At least two ' contractor personne1' have pro-
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vided assistance during the past year. Corporate personnel are
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available as required to support emergency preparedness activities.
- -
2.
. Conclusion
. Rating: Category 1.
- '
- '
Recent Trend: Consistent 3.
Board Recommendation
'
- .
' Licensee: Evaluate measures for assuring timely completion of action
items.
-
NRC: None.
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Security and Safeguards (62 hrs., 3%)
1.
Analysis During the assessment period, there were two routine physical pro-
_
.*
tection. inspections by region-based inspectors. Routine resident
inspections continued throughout 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 nature. Corrective actions were accomplished im-
mediately.
Similar violations did not recur.
- Management attention to the security program has been evident and
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
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
completion of barrier construction and related modifications. The
smoothness with which these activities are being accomplished is
indicative of management involvement in the planning, scheduling and coordination of the project.
- 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
by NRC/NMSS remains to be conducted.
- A comprehensive corporate security audit program continues to be
- '
a strength of this licensee and it demonstrates the licensee's com-mitment to a quality security program. Audits are conducted on
portions of the Security Plan, Safeguards Contingency Plan and
Training and Qualification Plans throughout the year such that the
overall audit program 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 period. This performance improvement is particularly significant in light of the fact that two major outages occurred
during this period.
- Asterisked lines are common to Units 1 and 2.
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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 period.
,
The event reporting system is consistent with NRC requirements.
L*.
The licensee reported a total of'thirtee.n' 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 ' ailed door alarm switch and one involved a security
-
,'
officer who was1 inattentive to his duties. -The. reports were timely
and generally complete. -Improvement in the quality of the reports-
to include greater details is, however, necessary.
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 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 have, however, shown
improvement in the scope of details discussed.
'*
Security organization staffing is currently. adequate to meet the
existing' security-program requirements.
Staffing plans and funding
to meet expanded 1 site needs for inclusion of Unit 3 are already in
- '
place. Additions to the security force are already being made.
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.
- A potential training weakness in Secondary Alarm Station operations
involving.its primary function was identified by an NRC inspector-
early in this period. The licensee immediately initiated remedial
-*
training to correct the potential deficiency.
- 2.
Conclusion Rating: Category 1.
'*
Recent Trend: Consistent.
3.
Board Recommendation None.
- Asterisked lines are common to Units 1 and m
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- Refueling and Outage Management
- (148; hrs., 7%)
-
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JAnalysis'
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?ThisareahadbeenratedCategory1duringthepreviousSALP. period.
-Improvements were noted during the 1983 refueling outage. ~That
,,
- outage increased significantly in length and complexity after dis-x a
covery of a failed reactor vessel thermal shield. -The challenge
ipresented 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-
'
protect the reactor vessel and reactor coolant system from debris.
A'small amount of debris of this type poses a significant threat to the nuclear fuel.
- 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 h_igh (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 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 pro-
~ gram. 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 im-
'
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-perienced in 1983. A major' factor in'the reduction was the assign-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 that this occurred because of a professional working relationship 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-l stallation procedure by craft supervision. Those individvals per-l
- Asterisked lines are common to Units 1 and 2.
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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, radiation protection technicians and the project engineers.
Steam 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 manway.
- The licensee has committed personnel and financial resources to -
' computer based outage planning.
The detail provided by these sys--
tems has proven to be a key ingredient in successful outage planning.
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
areas of the plant and by organizations supporting the outage.
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 improvement.
2.
Conclusion Rating: Category 1.
- Recent Trend:
Improving.
3.
Board Recommendation
None.
'
- Asterisked lines are common to Units 1 and 2.
L
.
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I.
Licensing 1.
Analysis In general, the licensing functions for Millstone Unit 2 are pro-perly carried out..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 actions.
The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period.
These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions. (Spect-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 issues.
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 stated.
The reviewer for the snubber Technical Specification change found the licensee's staff technically competent, responsive, and willing to clarify outstanding snubber issues.
In resolving the environ-mental qualification of electric equipment important to safety, the reviewer stated that the licensee demonstrated a clear understanding of issues and provided technically sound and thorough approaches to the resolution of equipment qualification deficiencies in almost all cases.
The licensee's responsiveness appears to vary widely on different 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 questions.
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 licensee on the Pressurizer Level Band. Other is-
!
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.28 sues such as the Control of Heavy Loads took constaerable 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 manner.
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 staff.
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. priorities. 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 submittals.
During the appraisal period the licensee lost at least two licensing staff personnel who were directly involved with Millstone Unit 2.
The licensee's current level of staffing appears to be adequate and the caliber of personnel is excellent.
In summary, licensee performance was good overall, but with recur-
rent response timeliness problems.
2.
Conclusion
Rating: Category 1.
Recent Trend: Consistent.
- 3.
Board Recommendation Licensee:
Improve management of licensing activities to avoid late
responses.
Improve coordination of activities with NRR in regard
to schedule, prioritization, and project status.
- NRC: None.
l
- Asterisked lines are common to Units 1 and 2.
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TABULATION OF LICENSING ACTIVITIES 31 Multi-Plant actions (9 completed). Included in this category are:
Control of Heavy Loads (C-10)
--
Technical Specification Surveillance for Hydraulic / Mechanical Snubbers (B-22
--
and B-17)
~
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
--
Pressurizer Level Band
--
PTS Curve Changes
--
Cycle 6 Reload
--
SG Tube Sleeving
--
Measurement Uncertainties
--
Outage Equipment Hatch Door
--
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)
--
Item II.E.4.2, Containment Isolation Dependability (F-19) (in progress)
--
Item II.B.3.2, Post Accident Sampling Modification (F-12)
--
,
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- - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^ - - - --
- - - - - - - - - - - ' - - "
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V.
SUPPORTING DATA AND SUMMARIES A..
Investigations and Allegations Review LThere have been no' investigations conducted at Millstone Unit 2.
'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 em-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-roborating information. 'The~1icensee has a drug and_ alcohol abuse pro-gram in place. That program is suported by the station security personnel'
and programs.
B.
Escalated Enforcement' Actions
'1.
Civil Penalties None..
2.
Orders.
An order was issued on' December 14, 1983 to confirm the implemen-tation schedule.for outstanding items _within the TMI Task Action Plan.
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.
3.
Confirmatory Action Letters None.
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C.
Management Conferences None.
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D.
Licensee Event Reports 1.
Tabular Listing Type of Events:
(A)'~ Personnel Error
-(B) Design / Man./Const./ Install.
(C) External Cause
(D) Defective Procedure
.(E) Component Failure
(X) Other
_6 TOTAL
2.
Licensee Event Reports Reviewed:
Report Nos. 83-26 to 85-02, including 13 Security and 5 Environ-mental Reports common to both Units 1 and 2.
'3.
Causal Analysis Seven sets of common mode events were identified. The first two are site-related, common to Units 1 and 2:
a.
There were eleven 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 85-01,-01).
b.
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 concen-trations exceeded the control station average by greater than a factor of ten (Environmental Reports 83-04, -05, and -06; LERs 84-03, and -07).
The licensee has evaluated this as not significant and has submitted a request for a change to the reporting requirement,
,
c.
Personnel error contributed to the cause in five plant-related events (LERs 83-28, 84-03, -07, -08 and 85-01).
d.
One report addressed five pipe restraints which became under-sized when schedule 40 pipe replaced standard wall pipe (LER 83-31).
e.
One report addressed excessive containment leakage through fourteen containment isolation valves (LER 84-05),
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32-4.
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 lfor submitting an LER, there was a change to the data base on LJanuary 1,1984.
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 tests.
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 0.29.
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TABLE 1
- TABULAR LISTING OF LER's BY FUNCTIONAL AREA MILLSTONE NUCLEAR STATION, UNIT 2-AREA'
NUMBER /CAUSE CODE-TOTAL A.
Plant Operations.
1/A 3/B 1/X
B.
Radiological Controls 5/X 5'
C.
Maintenance & Modifications 1/A 2/B 1/D 1/E
,
D.
Surveillance 1/A 1/B 1/C 4/E
E.
Fire Protection / Housekeeping 1/A.1/8
F.
G.
-Security & Safeguards 2/A 11/E
-H.
Refueling & Outage Management 1/A 1/B
I.
Licensing Activities
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_0 TOTAL
Cause Codes A - Personnel Error B - 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 2 Hours
% of Time A.
~ Plant: Operations 748
B.
' Radiological. Controls 271
C.
Maintenance 339
D.
Surveillance 298
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E.
Fire-Protection / Housekeeping
2
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G.
Security and Safeguards
3
. H.
Refueling and Outage Management 148
I.
Licensing Activities not considered TOTAL 2158-100 Y
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35-TABLE 3 VIOLATION SUMMARY (9/1/83 - 2/28/85)
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MILLSTONE NUCLEAR STATION, UNIT 2 A.-
Number and Severity Level of Violations i
Severity Level I 0-Severity Level II
.0 Severity Level'III
Deviation-
_1 TOTAL
~10 B.
Violation by Functional Area Functional' Area Severity Level I -II III IV V DEV 1.
Plant Operations-
2.
Radiological Controls
1 3.
Maintenance & Modifications
4.
Surveillance
5.
Fire Protection & Housekeeping
1 6.
Security and Safeguards
8.
Refueling and Outage Management 9.
Licensing Activities Totals
0 1
2
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C.
Summary Inspection Inspection
~ Severity Functional l Report No.
Dates Level Area
' Violation
'*83-23 9/26-30/83 IV
Failure to control security-keys.
IV
Failure to acknowledge
security alarms.
84-02 1/27-27/84 IV
Failure to control a design
& 2/15/84 change and supply proper procedures and drawings.
~ 84-15 6/11-15/84 IV
Failure to perform surveil-lance of fire detection instruments.
IV
Failure to provide three-hour fire barrier between zones of switchgear rooms.
Deviation
Sleeves not provided for fire protection piping at building internal walls.
84-22 10/24-26/84 V
Failure to follow procedures for fuel storage building integrity.
85-03 1/14-2/24/85 V
Failure to follow radiation protection procedures.
IV
Failure to maintain a clear
isolation zone.
85-04 28/84 III
Failure to control free standing liquid in a solid waste shipment.
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- Asterisked lines are common to Units 1 and 2.
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TABLE 4 REACTOR TRIP AND OUTAGE SUMMARY (9/1/83 - 2/28/85)
MILLSTONE NUCLEAR STATION, UNIT 2 A.
UNPLANNED AUTOMATIC SCRAMS-DATE'
.p0WER LEVEL CAUSE
'1.
1/11/84 Reactor trip from 15 percent Low steam generator level result-power.
ing from a transient in manual control which took place during system alignment.
2.-
11/15/84 Reactor trip from 100 percent Thermal margin / low presssure trip power.
resulting from main steam iso-lation valve (MSIV) closure.
MSIV actuator piston seals failed due to aging.
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B.
FORCED OUTAGES DATE POWER LEVEL CAUSE 1.
2/13-18/84 Shutdown from 100 percent
. Reactor Coolant System resistance power.
temperature detector response times greater than allowed.
2.
'11/28-29/84 Shutdown from 100 percent Low pressure feedwater heater power.
tube rupture.
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l TABLE-5 INSPECTION REPORT SUMMARY (9/1/83 - 2/28/85)
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MILLSTONE NUCLEAR STATION, UNIT 2 l=
Report' Number Inspection j.
Inspector (s)
Hours Areas Inspected 83-22
.
221 Emergency preparedness exercise.
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(Specialist &
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Resident)'
83-23
Station security program and implementation.
(Specialist)
l L
83-24
Special inspection of fuel cladding failures and (Specialist)
manufacturing / design errors.
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83-25
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129 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
'
protection.
83-26
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 ESFAS.
83-27 14.5 Quality Assurance Program including Category I (Specialist)
storage.
.
-83-28
Radioactive effluent control and monitoring.
(Specialist)
l 83-29
Routine inspection including reactor refueling and (Resident).
surveillance program implementation.
83-30 CANCELLED 83-31
Preventive maintenance and surveillance of RPS trip
'(Specialist-breakers.
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 ESFAS.
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Report Number. Inspection Inspector (s)
Hours Areas Inspected 84-02
Special inspection-two RPS channels partially in-(Resident)
operable when nuclear instrumentation detector cables were reversed.
84-03-16 Special inspection of quality assurance 'as applied
' (Specialist)
to computer codes used in reactor analysis.
84-04 126 Routine inspection including RpS RTD operability.
(Resident)-
84-05
Emergency Preparedness Program.
(Specialist)
84-06
Radioactive material packaging and transportion.
(Specialist)
84-07
Routine inspection including the RCS high point (Resident)
vent modification, liquid effluent radiation monitors.
84-08
Nonradioactive chemistry analysis including quality (Specialist)
control of analytical measurements.
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84-09
Post-accident monitoring equipment installations (Specialist)
made to implement a Confirmatory Order dated March 14, 1983.
84-10
Routine inspection including control rod drop, re-(Resident)
placement and-investigation of a charging pump block and RPS trip breaker preventive maintenance.
84-11 5.5 Quality Assurance for design, installation and opera-(Specialist)
tion of PASS.
84-12
Routine inspection including actions taken following (Resident)
a control rod drop and removal of fuel pin end caps for metallographic analysis.
84-13
Radiation protection.
(Specialist)
84-14
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Station security program and implementation.
(Specialist)
84-15
Fire protection / prevention program including admini-(Specialist)
stration, equipment maintenance and surveillance and fire brigade training.
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Report Number Inspection Inspector (s)
Hours Areas Inspected 84-16
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Repeated cracking of the charging pump blocks.
(Specialist)
84-17.
Inservice inspection program including licensee (Specialist)
-requested relief from reactor coolant pump cast stainless weld examinations.
84-18
Routine inspection including licensee response to (Resident).
control rod drop incidents and review of previously reported open items.
-84-19
Administration of NRC licensed operator examinations (Licensing Examiner)
and. review of requalification training program.
84-20 160 Routine inspection including licensee response to (Resident-control rod drop incidents and maintenance.
Specialist)
84-21
Routine inspection including licensee response to (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 problems.
84-22 26.5 Radiation protection including fuel reconstitution.
(Specialist)
84-23
Special inspection of NRC Generic Letter 83-28 for (Specialist)
equipment classification and vendor interface.
84-24 89.5 Routine inspection including licensee response to (Resident)
reactor trip from MSIV closure, manual reactor trip because of flooded feedwater heater, operability of feedwater check valves, fuel reconstitution, and Type 13 radioactive waste shipment (53,600 Ci).
I 84-25
Routine inspection including performance of RPS i
(Resident)
and safeguards instrument isolation devices.
84-26
Licensed operator requalification including the ad-(Licensing Examiner)
ministration and grading of one section of the re-qualification examination, and walk-throughs for 12 licensed operators.
84-27 None Administration of NRC licensed operator examinations.
(Licensing examiner)
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Report Number Inspection Inspector (s)
Hours Areas Inspected
.
85-01 122 Inspection of Bulletins concerning as-built seismic
- (Specialist)
pipe restraint and base plate stress analysis and valve weights used in stress analysis.
85-02
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32.5 Quality Assurance Audits, Surveillance and Monitors.
(Specialist)-
85-03
.
-65 Routine-inspection including preparations for a (Resident)_
refueling / maintenance outage, end of cycle power coastdown reactor limitations, error'to input para-meters of small break Loss Of Coolant Accident analysis, potential unmonitored radioactive release to the sanitary sewer system, compliance with 10 CFR 50.54 for a senior reactor operator in the Control
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Room, and review of actions taken in response to NRC Bulletin 84-03, Reactor Cavity Seal Failure.85-04_
None Radioactive waste shipment deficiencies.
(State of South Carolina)
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TABLE 6 LER SYNOPSIS (9/1/83 - 2/28/85)
MrLLSTONE NUCLEAR STATION, UNIT 2
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LER No.
Summary Description 83-26 Mechanical damage to two fuel assembly upper end fitting components.
83-27 Pressurizer safety valve failed to open at the required set point.
83-28 4500 pound load transported over irradiated fuel assembifes.
83-29 Lack of seismic' support for tubing associated with containment wide-range pressure instruments.
83-30 Potential seismic degradation to Enclosure Building Filtration System during fuel movement.
83-31 Five pipe restraints became undersized when schedule 40 versus standard wall pipe was installed in portions of the service water system.
83-32 Failure of emergency diesel generator load sequencer.
83-33 Power Operated Relieve Valve Seat leakage due to foreign material.
- 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 ten.
- ETS83-05 Co-60 in aquatic flora, gathered within 500 feet of discharge, in levels greater than the control station by a factor of ten.
- ETS83-06 Co-60 in oysters, gathered 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 surveillance.
- SEC83-06 Security related computer failure, loss of alarm surveillance.
84-01 Two ESAS actuations with the reactor in Mode 2.
84-02 Reactor Scram, low steam generator level.
84-03 Low level in two of four Safety Injection Tanks due to water in dry reference legs.
84-04 Thermal margin / low pressure reactor trip inoperable in two of four RPS channels due to reversed nuclear instrument detector cables.
- Asterisked lines are common to Units 1 and 2.
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LER No.
Summary Description
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84-05 Local leak rate in excess of specified due to leakage through 14 valves in closed cooling water and containment sump penetrations.
84-06 Reactor Coolant System temperature sensing RTD response time in excess of allowed.
84-07 Missed monthly surveillance of Thermal Margin / Low Pressure trip.
84-08 Fire Protection - NRC audit found missing surveillance of detectors and fiberglass pipe breaching fire barrier between switchgear rooms.
84-09 Improperly rated fire protection door between 480 volt switchgear rooms.
84-10 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 operable.
84-11 Reactor Trip - Thermal margin / low pressure function resulting from a MSIV closure.
84-12 Manual Reactor Trip to protect turbine from damage due to water flooding the extraction steam system following tube ruptures in a feedwater heater.
- 84-01 Security-related, multiplexer failure, loss of alarm surveillance.
- 84-02 Security-related, computer failure, loss of alarm surveillance.
- 84-03 Ag-110m in oysters, gathered within 500 feet of discharge, in levels greater than the control station by a factor of ten.
- 84-04 Security-related, discovery of potential unmonitored access into the protected area.
- 84-07 Co-60 in aquatic flora, gathered within 500 feet of discharge, in levels greater than the control station by a factor of ten.
- 84-10 Security-related, computer failure, loss of alarm surveillance.
- 84-13 Security-related, multiplexer failure, partial loss of alarm surveillance.
- 84-14 Security-related, multiplexer switch failure, loss of alarm surveillance.
- 84-16 Security-related, computer failure, intermittent loss of alarm surveil-lance.
- Asterisked lines are common to Units 1 and 2.
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LER No.
Summary Description
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- 84-19-Security-related, guard not performing duties.
- 84-20 Security-related, multiplexer failure, partial loss of alarm surveillance.
-85-01 Error in assumed parameters for small break LOCA analysis.
- 85-01-Security-relate'd, failed vital area door switch.
- 85-02-Security-related, computer failures, intermittent loss of alarm sur-veillance.
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- Ast'erisked lines are common to Units 1 and 2.
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