IR 05000245/1988099

SALP Repts 50-245/88-99 & 50-336/88-99 for 880101-890615

ML20248G279
Person / Time
Site:	Millstone
Issue date:	10/02/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248G265	List: IR 05000245/1988099 ML20248G264
References
50-245-88-99, 50-336-88-99, NUDOCS 8910100170
Download: ML20248G279 (52)

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ENCLOSURE-1 U.S. NUCLEAR REGULATORY COMMISSION .

REGION I

SYSTEMATIC ASSESSMENT OF. LICENSEE PERFORMANCE INITIAL' REPORT SALP BOARD COMBINED REPORT 50-245/88-99; 50-336/88-99 NORTHEAST NUCLEAR ENERGY COMPANY

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MILLSTONE 1 (50-245)'

MILLSTONE 2 (50-336)

ASSESSMENT PERIOD: JANUARY 1, 1988 - JUNE 15, 1989 BOARD MEETING DATE: AUGUST 7, 1989 L

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SUMMARY OF RESULTS II.A.I. Millstone 1 and 2 Millstone 1 and 2 demonstrated safe and conservative plant operation. A strong commitment to planning, priority assignments, and training was eviden Operators were experienced and well trained. Both units experienced reductions in safety system actuations. Unit departments provided excellent support to Operations, and cooperation between departments was goo Security performance improved from Category 2 in the last SALP to Category Enhancements included increased management attention, improved equipment reli-ability, and effective security self-assessment A strong emergency exercise performance demonstrated the continued effective-ness of the Emergency Preparedness program. The licensee had effective per-sonnel training, well maintained emergency response facilities, and excellent working relationships with offsite authoritie II.A.2. Millstone 1

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An NRC emergency operating procedure (EOP) inspection found overall capability

[ acceptable but inadequate E0P maintenance. An extensive licensee response re-l sulted in significant and ongoing improvements.

l Radiological controls at Millstone I were effective. Dose reduction initiatives and ALARA program implementation were good overall. Release of a contaminated hydrolysing rig was a significant exception to the generally proficient per-formance.

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. 2 M&intenance and surveillance activities were effectively implemented by experi-E enced and motivated personnel. In contrast to the previous SALP, surveillance

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produced no erroneous engineered safety feature actuations. Engineering pro-

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vided adequate support, but some inaccurate engineering evaluations were note The combined Safety Assessment / Quality Verification area was rated as Cate-gory 1. The incorporated functional areas of Licensing and Assurance of Qual- ',

ity were both rated as Category 2 in the last SALP. Substantal improvements were noted in licensing amendment submittals and licensee self-assessment pro-

- gram II.A.3. Millstone 2 The Millstone 2 radiological controls program was significantly improved. Al-though the high source term and frequent work activities with the steam gene-rators continued to result in high radiation exposures, controls to minimize exposures were effective. ALARA program implementation was much improved. The area was rated as Category 1, an increase over the Category 2 rating of the last perio Surveillance and Maintenance were rated separately in the previous SALP, re-ceiving a Category 2 and Category 1 rating, respectively. The combined area was rated as a Category 2 for this SALP with strengths noted in the procedure upgrade program and ISI program. Improved root cause analyses are warranted, however, as indicated by three outages due to reactor vesse) 0-ring leakag Significant improvements were noted in Engineering and Technical Support; this area was rated as a Category 1 in this SALP, increasing from the previous Category 2. Plant modifications were effectively implemented and were supported by extensive technical evaluations. The licensee showed excellent initiative in addressing the steam generator tube plug repair issu Licensing and Assurance of Quality performance were separately rated as Cate-gory 2 in the last SALP. Safety Assessment / Quality Verification was rated Category 2 in this SALP. Licensee self-assessment efforts were good. Unre-viewed safety question evaluations were extensive, conservative, and showed good regard for safety. Further effort to solicit and resolve employee con-cerns is needed. Some licensing actions which could have been long anticipated by the licensee should have been submitted sooner in order to provide suffi-cient time for NRC actio II.B Facility Performance Tabulation This SALP report incorporates the recent NRC redefinition of the assessment functional areas. As indicated in the tabulations, changes include combining the previously separate Maintenance and Surveillance areas and adding the Safety Assessment / Quality Verification area. The Safety Assessment / Quality  ;

Verification section is largely a synopsis of observations in other functional aress. Additionally, Fire Protection, Licensing, Refueling / Outage, Training, Chemistry Control, and Assurance of Quality have been incorporated into the remaining functional areas as appropriat . l

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, '3 MILLSTONE 1-Rating Rating Last ~This Functional' Area Period * Period ** Trend

. . Plant Operations- 1 1

-- Radiological-Controls 2 2 -- Maintenance / Surveillance *** 1/1 1 -- Emergency Preparedness 1 1 -- Security 2 1 -- Engineering / Technical Support 2 2- --

' Safety Assessment / Quality. Verification # 1

-- Licensing Activities 2 # -- Refueling / Outages 1 # -- Training &' Qualification Effectiveness 1 # -- Assurance of Quality -2 # --

• April 1,1987 to December. 31,1987

• • January 1, 1988 to June 15, 1989

• • • Previously addressed as separate area # 'Not addressed as a separate are .

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MILLSTONE 2 Rating Rating

Last Thi Functional Area Period *- Period ** Trend Plant. Operation . I- -- ' Radiological Controls ~ 2 'l --- Maintenance / Surveillance *** 1/2 2 --

' Emergency Preparedness 1- 1 -- Securit Engineering / Technical Support 2 1

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' Safety Assessment / Quality Verification # 2 -- Licensing Activities 2 # -- Refueling / Outage # -- Training & Qualification Effectiveness 1 # -- Assurance of. Quality 2 #- ---

April'1, 1987 to December'31, 1987

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• • January I', ~1988 to ~ June 15, 1989'

• • • Previously-addressed as separate' area # Not addressed as a separate area.

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III. PERFORMANCE ANALYSIS III. Millstone 1 Plant Operations (1582 hours0.0183 days <br />0.439 hours <br />0.00262 weeks <br />6.01951e-4 months <br />, 46.4%)

III.A.1.a Analysis The previous SALP rated this area as Category 1, noting strengths in operator performance and training, fire protection, and management oversight of opera-

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tion Plant Operations Review Committee (PORC) performance was identified as a maior strength. Two reactor scrams involving operator performance problems occurred. Satisfactory corrective actions were taken, but a need to ensure that lessons are learned from past deficiencies was identifie For the current SALP, this area encompasses Outage Management, for which Millstone 1 received a prior separate rating of Category 1. The rating was based on strengths in planning and oversight, and on an efficient outage staff organization. Isolated configuration control lapses occurred, causing inadvertent engineered safety feature (ESF) actuations. The Board concluded that the high PORC workload during the outage was exacerbated by routine PORC reviews which could have been accomplished prior to the outag During.this assessment period, the unit had three reactor scrams with the reac-tor critical compared to five in the previous period. The NRC observed conser-vative operator responses and timely and thorough post-trip reviews after each scram. One of the scrams was due to operator error: the operating shift al-lowed reactor pressure to uceed 600 psig with insufficient main condenser vacuum. A thorough licensee review, looking beyond the' obvious personnel error, identified a need for more stringent guidance on shift staff composition during changing plant conditions. This guidance was incorporated into proce-dures as a precaution against recurrence. This effort was representative of the licensee's ability to conduct complete event investigations and learn from mistake Another operator error was noted when the standby gas treatment system (SGTS) l was tagged out in a potentially inoperable condition for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with ongoing irradiated fuel movement. The licensee later proved that SGTS oper- ,

ability had not been compromised by drawing the required secondary containment ,

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vacuum under identical conditions. This event was assessed as an isolated lapse in configuration contro Two significant communication weaknesses were noted. The first involved a Shift Supervisor's use of a diver to investigate a failed emergency service water (ESW) pump. That required the other ESW pumps to be removed from service, causing inoperability of the Containment Cooling System. The decision to conduct this evolution was made without first contacting the licensee's duty officer or operations management. The second incident was not notifying the NRC duty officer when unidentified reactor coolant leakage increased from the reported value of slightly above the Unusual Event threshold of 10 gpm to well over 30 gp The next emergency plan threshold, an Alert at 50 gpm, was not reached, and specific reporting requirements were me _ _ _ _ _ _ - _ _ -

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Nonetheless, notification of the NRC would have provided significant data on event progres In both cases, licensee management was responsive, provided additional personnel briefings, and made appropriate procedure revisions. No repeat occurrences were noted. Communications were otherwise goo Three significant failures to follow operations procedures were noted. One ,

involved the discharge of an unsampled floor drain sample tank. Another re-suited in a minor spent fuel pool overflow which caused the contamination of several reactor building areas. No radiation control requirements were exceeded in either event and appropriate actions were taken to minimize recur-rence. The third failure caused the reactor scram discussed earlier. These errors were considered exceptions to the strict procedural adherence normally displayed by Millstone 1 operations personne "

No other significant operator errors were noted. The above events did not sig-nificantly modify or indicate programmatic weakness in the otherwise overall excellent operator performanc Generally, the NRC found operations procedures to be of high quality. The lic-ensee has instituted a procedure upgrade program based on the INPD Writer's Guide and is scheduled for completion by 1995. Operations was appropriately committed to the program as all interim completion goals were me Operations was staffed with capable, experienced, and responsible operators who displayed professionalism and a high regard for safety. Staffing supported a six shift rotation which allowed flexible and thorough plant coverag In addition, most shift control operators (reactor operators) held senior reactor operator (SRO) licenses and many plant equipment operators (PE0s) held reactor operator (RO) licenses. Extremely low personnel turnover contributed to the high knowledge level in the Operations department. The NRC observed that operating shifts took conservative measures in response to equipment failures, and that this conservatism was echoed by unit managemen No forced shutdowns were attributed v.o Operations. Excellent cooperation and ,

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communications were maintained between departments during evolutions, and operations effectively maintained configuration control. The permanent outage scheduling group assisted in planning controlled shutdowns, and fostered good communications and awareness through detailed printed schedule An efficient outage organization comprised of an experienced shift supervisor and a team of operators provided firm control of outage evolutions. Twice ,

daily meetings kept personnel aware of plant status and promoted effective com-munication between department Management provided clear and frequent direc-tion on goals and gave timely feedback. Continuous management representative coverage was effective in timely problem resolution. The outage scheduling group provided a positive contribution through detailed schedules. Overall, the outage proceeded smoothly, with notably good cooperation between depart-ments. When gas turbine generator governor replacement project extended the outage by nine days, safety obviously took precedence over schedul _- ---

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The PORC effectively addressed nuclear and personnel safety. Unrestricted discussions were observed. Critical questioning was encourage Special technical presentations were scheduled as needed to allow informed com-mittee decisions. Unlike the last SALP period, PORC reviews during the outage focused mainly on outage-related items with minimal routine review items. The NRC noted, however, that minor procedure changes consumed valuable PORC time throughout the SALP period. That has the potential to dilute attention to more safety-significant issues. Administrative procedures allow the use of PORC subcommittees for these more routine PORC responsibilitie Management attention to and support of operations was evident in extensive con-trol room and in plant presence, especially during operational evolutions and after scrams. Unit management, most of whom held SRO licenses, was knowledge-able of plant events and issues. The Duty Officer (DO) program provided timely management attention to events, with generally accurate and detailed updates for unit management and the NR An NRC Emergency Operating Procedure (EOP) inspection team identified weak-nesses in the Millstone 1 E0Ps. These included: the procedures had poor use-ability; the licensee had less than complete staging and control of equipment used in E0P contingency procedure., (e.g., alternate boron injection); and a thorough validation and verification (V&V) process had not been complete Several E0P contingency procedures contained in the system operating procedures (ops) had not been walked down. Although the NRC concluded that the deficiencies posed no present safety problem due to the strengths in operator training and knowledge observed during simulator accident scenarios, it was also concluded that, unlike most aspects of Millstone 1 Operations performance, E0P development and maintenance needed significant improvement. In response, the licensee removed two experienced SR0s from shift to develop E0P improve-ments. Their efforts were effective: all NRC-identified potentially safety-significant discrepancies were corrected within three months of the inspectio The NRC attributed an improved attitude, ranging from department supervision to the individual operators, to the program and subsequent additional trainin Operations personnel exhibited a greater appreciation for the safety signifi-cance of the E0Ps and found them much improve The licensee was also responsive in addressing additional E0P concerns identi-fied during licensed operator examinations conducted after the E0P inspectio The concerns involved specific technical improvements which the licensee is incorporating into the Revision 4 E0Ps. (The Revision 4 implementation pro-gram, which incorporates the remaining E0P team findings, is ongoing with completion scheduled in September 1989.)

Initial operator training continued to be successful: seven of the nine candi-dates received licenses. Noted strengths included familiarity with plant equipment and administrative procedures. Weaknesses were identified in com-munications and in E0P step verification. The NRC later verified that these weaknesses were not displayed by licensed operator _ __ __________-_____ - ___ - _ -

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The licensee consistently ensured Technical Specification (TS) compliance while in nonroutine plant configurations. There were initiatives to maintain equipment operability beyond TS requirements during safety-related electrical bus inspections. The licensee recognized the need to improve their custom TS and frequently discussed TS compliance and improvement efforts with the NR The fire protection program continued to ensure compliance with 10 CFR 50 Ap-pendix R with respect to safe shutdown. The fire protection organization was well staffed with knowledgeable personnel who exhibited effective and conser-vr.tive approaches to problem resolution. For example they instituted in-creased surveillance of fire dampers which failed to close during a carbon dioxide discharge test. In addition, corporate fire protection personnel were involved in onsite fire protection activities and drill Housekeeping was acceptable. When the NRC identified drywell housekeeping de-ficiencies, the licensee responded with a prompt and extensive cleaning effor Millstone 1 implemented two projects involving area decontamination and equip-ment painting, with notable improvements achieved in the radwaste area and the turbine deck, respectively. Both projects will continue for several year In summary, operation; were proficiently conducted by a knowledgeable and cap-  ;

able staff who received extensive management support. Problems were consisten-tly approached from a nuclear and personnel safety-first standpoint. Operator errors resulted in events of minor safety significance and operator performance was otherwise excellent. An NRC E0P inspection found examples of inadequate E0P development and maintenance, but an extensive licensee response resulted in significant and ongoing improvement III . A.I.b Performance Rating: Category 1.

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III.A.I.c Recommendations Licensee: Aggressively pursue ongoing E0P improvement NRC: Perform Revision 4 E0P inspection before April 199 III. Millstone 2 plant Operations (1621 hours0.0188 days <br />0.45 hours <br />0.00268 weeks <br />6.167905e-4 months <br />, 38.4%)

l III.A.2.a Analysis i l The previous SALP rated Operations as Category 1. Strengths included good in-terdepartmental communications, strong management involvement and oversight, and good performance in operator licensing. Improvements were recommended in equipment operability overview and housekeeping. This area now includes Outage Management, in which Millstone 2 received a prior rating of Category Strengths were noted in management involvement in planning, identification /re-solution of critical path activities, and control of wor Lapses were noted in control of overtime during refueling outage . . _ _ _ _ _ - _ _ _ _ - _ _ _ _ - _ _ _ -

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Operating shifts maintained an efficient and professional attitude in the con-trol room during this SALP period. Good plant management overview and direction during plant restoration from refueling outages was noted. Use of an additional senior reactor operator to track outstanding work orders and prere-quisites during outages was very successful in controlling outage wor Good operations control and attentiveness to plant conditions prevented plant .

transients during feedwater control malfunctions, circulating water pump losses, heater drain pump seal failure, and loss of a vital instrument bus. The one unplanned trip from power resulted from Maintenance personnel error (see Unit 2 Maintenance,Section III.C.2.a). The accompanying transient involved a loss of normal power (LNP), malfunction of an auxiliary feedwater pump, and potential personnel safety hazards. Control room operator immediate response, follow-up, and control of the plant was very good. The one unplanned trip was a major improvement over the last SALp period, when nine trips occurred. The absence of trips due to operator error was a notable indication of operational excellenc E0P inspection concluded that the operators had good knowledge of and effectively used the emergency procedures to mitigate the consequences of simulated occidents. There was excellent operator utilization of the Safety Parameter Display System (SPDS). One deviation from a licensee commitment was identified, and numerous human factor discrepancies and minor technical observations were noted. The licensee resolved the technical issues and most of the human factors issue Good communications between unit management, operations, and other plant groups continued to be a major strength. A strong safety approach to event resolution was evident in plant recovery from the reactor trip /LNP, safety injection actuations, and loss of a vital instrument bu The quality of operations procedures was good. Operators followed and were knowledgeable of procedures and proposed appropriate changes when discrepancies were identified. Generally, very good adherence to procedures was evident during major plant evolutions such as plant startups and shutdowns. One isolated procedural nonadherence resulted from improper placement of a safety-related breaker jumper, resulting in a loss of normal power (LER 88-005). The licensee's procedural rewrite program is on going, with a strong emphasis on using human factors considerations to minimize personnel error While management and operations department adherence to procedures and TS requirements was good; infrequent instances of operator inattention to detail involving requirements of minor safety significance were noted. Examples included changing modes with the emergency diesel inoperable (LER 88-07), fire penetration seal inoperability (LER 89-01), radiation monitor inoperability (LER 88-10), and an incomplete surveillance for a containment isolation valve (LER 89-06). Also, until the NRC identified the discrepancy, a power-operated relief valve was not tahen out of service during plant cooldown as specified by procedure. In addition, a failure to enter the TS action statement for emer-gency power availability for control room ventilation was note _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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Overall, housekeeping was adequate and improving. Minor problems were identi-fied and corrected. Increased management involvement in improving housekeeping after.the most recent refueling outage was note Management attention to and involvement in operator requalification was demon-strated.by implementation of new simulator scenarios, and in training to ad- .

dress industry events. Requalification instructors displayed a high level of preparation and professionalism. All three senior reactor operator license candidates passed the NRC examination and received license There was excellent use of the unit simulator to review plant behavior prior to in-service tests. Examples included response to a feedwater control circuitry malfunction, and the in-service test to reduce reactor coolant system average temperature. The facility applied for NRC certification of the plant simulator significantly ahead of the initially proposed schedul Initiatives to conduct in plant operational exercises such as local starts of the turbine-driven auxiliary feedwater pump, emergency diesel generator, and emergency containment entries were effectively used to familiarize operators with nonroutine evolution The licensee's fire protection organization was staffed with well trained and knowledgeable personnel. The in plant approach to resolving fire protection '

problems was conservativ For example, surveillance frequency was increased  ;

in order to diagnose problems and implement corrective action for equipment i which failed surveillance testing. The training department staff also received fire protection training and participated in fire fighting activities. Obser-vations of an on-site fire drill found personnel knowledgeable, with a good understanding of fire control and of protection of personnel and equipmen There were two refueling outages during this period. Three other outages oc-curred because of primary system leakage and control rod cooling problems. The outages were well planned, with management involvement in the early stage Good control and resolution of critical path activities was noted, particularly in activities surrounding implementation of NRC Generic Letter 88-17 on Loss of Shutdown Cooling, steam generator (SG) tube plug-in plug installation, turbine l rotor cracking, and service water system configuration during outages.

l Before the Cycle 9 refueling, the licensee undertook several new initiatives to minimize the outage workload. The initiatives included retubing the reactor building component cooling water (RBCCW) heat exchanger and major intake struc-ture work and were considered a positive initiative in effective personnel use and outage managemen Refueling outage activities were extensive and included SG eddy current testing (ECT) and tube plugging, human factors improvements to the control room, incorporation of anticipated transient without scram (ATWS) protection, extraction steam and service water pipe replacement, reactor coolant pump (RCP)

seal and motor replacements, and plug-in plug modification of SG tube plug The outage management organization (the outage coordinator, duty officer, and

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Il staff assistants) provided 24-hour coverage. Twice daily meetings contributed in identifying and resolving problems and to effective schedule contro Good regard for safety was noted in Plant Operations Review Committee (PORC)

meetings. The members exhibited a questioning approach to technical issues, operational events, and evolutions. PORC was highly effective in reviewing licensee event reports (LERs), corrective actions on technical issues, and Plant Incident Reports (PIRs).

In conclusion, the licensee demonstrated continued good performance in plant operations. Personnel errors and plant trips were infrequent. An efficient and professional attitude existed in the control room. Interdepartmental com-munications were good, and there were good management initiatives such as pre-refueling outage work and operational exercises. Improvement in general l housekeeping was noted, but further improvements are needed. Additional emphasis is needed on operator attention to detail for lesser safety significant requirement III.A.2.b Performance Rating: Category III.A.2.c Recommendations: Non II Millstone 1 and 2 Radiological Controls The Radiological Controls program was rated as Category 2 in the last SAL Although the program was judged to be effective, deficiencies in control and supervision of field activities led to weaknesses in outage performance. Also, improvements were needed in the ALARA area and radiological housekeeping was poo Seven routine inspections and one reactive radiation protection inspection were conducted during the current assessment period. The resident inspectors rou-tinely reviewed radiation protection. Two inspections were conducted of radwaste controls, radiological transportation, and environmental monitorin One inspection of radiological confirmatory measurements was complete The Health Physics (HP) organization was found to be stable, qualified, and effective. Adequate staffing levels were maintained to support HP program implementation during routine operations and outages. The program was control-led by well developed and widely disseminated policies and procedures. The responsibilities and authorities of the HP organization were adequately define The radiological control program was significantly challenged this period in that each unit went through at least one refueling outage. In addition, spent fuel pool cleanup activities occurred at Millstone 1, and three unplanned outages to repair leaky primary system valves occurred at Millstone 2. Outage planning and preparation was extensive. Effective outage organizations were

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assembled and well staffed with qualified technicians. ' Appropriate training was provided to plant workers and additional personnel and contamination monitoring equipment was obtained. HP field support was observed to be knowledgeable and diligent. Overall, radiological controls for these activities were effectiv The station's external and internal exposure control programs were found to be  :

well defined and effectively implemented. Good use of engineering controls reduced.the need for respirators by minimizing airborne radioactivity.and, when needed, effective respirator training was provided. (A minor exception at Millstone 2 is discussed later.) Radiation Work Permits were effectively used to control-exposures during routine and outage jobs. Aggressive oversight by both HP and unit management was noted in controlling tasks involving major exposures. Weaknesses identified last period in the areas of posting high radiation areas, adherence to radiation work permits, and supervisory oversight of field activities were correcte Effective ALARA program implementation was observed. ALARA goals were consi-dered challenging. Lessens learned were effectively used for ALARA planning, and ALARA suggestions were actively solicited from facility workers for unit management evaluatio The NRC Region I mobile laboratory conducted one independent measurements in-spection. All split sample results were in agreement. Management support to the radiochemistry program was evident in the acquisition of state-of-the-art gamma spectroscopy equipment and additional staff. Overall, the radiochemical measurements program provided adequate support to plant operatio An effective radiological effluent monitoring and radiological environmental monitoring program was implemented. The licensee met appropriate requirements related to the radioactive effluent control program. Required reports were completed. Adequate surveillance were conducted on air cleaning system Calibration and preventive maintenance for meteorological instrumentation was found to be adequate. The annual environmental monitoring reports showed that the licensee performed all program aspects as required. A noted strength was the extensive study on the bioaccumulation factors of Ag-110 and 2n-65 in shellfish and the upgraded computer code for dose assessment using a new Ag-110 bioaccumulation facto The licensee's radiological environmental monitoring program (REMP) audits in-volved the meteorological monitoring program, comparisons of collocated thermoluminescent dosimeter (TLD) monitoring results, and Quality Services Department (QSD) audits of the analytical laboratory. The audits covered the stated objectives and were thorough. The monitoring results of the Itcensee's TLDs collocated with NRC TLDs were in good agreemen _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ ~

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i NRC review last assessment period found that audits'were compliance-oriented in l nature and lacking in depth. NRC review this period found that the licensee upgraded the audits and performed in-depth programmatic reviews of the radia- J tion protection program. Audit findings were prioritized as the target dates established for resolution of findings. This effort is ongoin '

III. Radiological Controls - Millstone 1 (191 hours0.00221 days <br />0.0531 hours <br />3.158069e-4 weeks <br />7.26755e-5 months <br />, 5.6%)

III.B.1.a Analysis NRC review this period found that good overall radiological controls were pro- ,

vided for ongoing routine activities. The radiological housekeeping weaknesses .I observed during the previous period were not observed. Millstone I completed a l significant decontamination effort in the radwaste area as part of a long-term campaign for facility decontamination. Low dose rates existed through the uni Control of internal exposure during outage and other jobs involving significant exposures was good; examples include the spent fuel pool cleanup and rerack project The previous SALP noted unlocked high radiation area (HRA) doors as a weaknes The problem continued throughout the first eleven months of this assessment period with the last discovery occurring on November 19, 1988. Millstone 1 implemented additional administrative controls involving the use of chains and padlocks where practicable, and reduced the number of locked HRA doors by converting from contact to eighteen inch dose rate readings. The licensee is also pursuing additional action through HRA gate design changes to better alert plant personnel to open HRA gates. The effort indicated responsiveness to NRC concerns, but'the weakness in HRA controls, a fundamental radiation protection l program element, is of concern to the NR A special NRC inspection was conducted to review an event involving release of .

a contaminated hydrolysing rig offsite. The rig was used by the licensec for i reactor cavity decontaminatio Inspection determined that adequate controls were not established to prevent the equipment from becoming contaminated via siphoning of cavity water. This was a significant weakness in the licensee's planning for equipment use and in the protection against the spread of contami-nation outside of the radiological controlled area. That weakness was com-pounded by the absence of equipment release surveys. An additional problem involved the failure by the Millstone 1 radiological controls organization to notify the site group responsible for coordinating movement and shipment of potentially radioactive material. The root causes of this event were poor communication, inadequate evaluation of the potential for equipment contamina-tion, and weak health physics involvement upon completion of the evolution.

l Once the licensee became aware of the problem, quick and comprehensive correc-j: tive actions were take The licensee continued to actively implement dose reduction initiatives to re-duce personnel exposures over the life of the facility. For example, Millstone I 1 developed a drill-like tool to quickly position scram discharge volume valves (located in a locked high radiation area) during surveillance. Dose reduction efforts during the outage included the new reactor vessel head stud Q-D (Quick e

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Disconnect). tensioning system, an aggressive reactor cavity decoritamination effort, and zinc injection which reduced Cobalt-60 buildup in recirculation piping and produced a 50% drywell dose rate reduction. The use of the Mechani- -

cal Stress Improvement Process (MSIP) as an IGSCC counter-measure saved signi-ficant exposure over the Induction Heat System Improvement (IHSI) metho Extensive outage preplanning and preparation was evident. There was a good I cooperation between Health Physics and unit departments. Daily exposure ]

reports to department heads helped to maintain their awarenes .j i'

Overall, the Millstone 1 radiation safety program was effectively implemented by knowledgeable and dedicated personnel. There was good cooperation between Hp and other plant departments. ALARA goals were actively pursued and supported by unit management. However, the release of contaminated equipment was a significant failure to adequately evaluate contamination potential and was indicative of a programmatic weaknesses. That incident and the high radiation area access problem materially impacted the overall performance of Millstone III.B.I.b Performance Rating: Category 2 III.B.I.c Recommendations  ;

Non III. Radiological Controls - Millstone 2 (245 hours0.00284 days <br />0.0681 hours <br />4.050926e-4 weeks <br />9.32225e-5 months <br />, 5.8%)

III.B.2.a Analysis Good radiological controls were provided for on going routine activities. One isolated problem involved failure to properly evaluate airborne radioactivity:

inadequate evaluatica during repair of leaky primary valves early in the assess-ment period resulted in six individuals sustaining limited intakes of airborne radioactivity. The licensee's corrective actions for the problem were timely and thoroug l The licensee's posting, barricading, and access control to radiological con-trolled areas was effective. A weakness in contamination control involving the potential for personnel who might be contaminated to interface with non-contaminated personnel leaving the radiological controlled area was identified, and was quickly corrected by the license The licensee continues to experience high station exposures during steam generator (SG) work. During the 1989 refueling outage, significant exposure (146 man-rem) was incurred to address potentially defective mechanical SG tube plugs. Management took action to stop work for one shift to reevaluate ALARA aspects. Subsequently, significant exposure reductions were obtained. NRC j review of the licensee's efforts to minimize exposure during steam generator i

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. work indicated lessons' learned from previous outages were' applied, effectiv planning and goals were used, and emergent work received acceptable levels of'

review to reduce exposure. Although the high source term and frequent work-

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activities with the. steam generators continued to result in high radiation exposures, radiological controls to minimize . exposures were effectiv 'IV.B.2.b performance Ratino: Category 1 .

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IV.B.2.c Recommendations: None III. Millstone 1 Maintenance / Surveillance (626 hours0.00725 days <br />0.174 hours <br />0.00104 weeks <br />2.38193e-4 months <br />, 18.4%)

III.C.I.a Analysis Maintenance and surveillance have been combined into one functional area. The board separately rated both as Category I during the last SALP; effective work control and a knowledgeable and experienced work force were noted as strength The Production Maintenance Management System (PMMS), a computer data ba:;e used to prepare, track, and trend work orders, was a positive licensee initiativ Department performance during the outage was well planned and executed. Two engineered safety feature (ESF) actuations and one reactor scram were c.used by inadequate surveillance testing control during the last SAL The current assessment is based on resident inspection,. separate NRC regional specialist inspections of the Maintenance and Inservice Inspection (ISI) pro-grams, and an NRC Maintenance team inspectio In response to ESF actuations caused by surveillance errors, the Instruments-tion and Controls (I&C) department instituted innovative measures to improve surveillance controls. Their efforts included color-coded testing devices for the low pressure coolant injection (LPCI) and core spray (CS) system logic tests, and an intricate testing box which reduced the LPCI system logic test duration by 50%. There were no ESF actuations caused by surveillance errors during this SALP period. The NRC frequently observed the presence of line supervision during complicated or high. risk surveillance. Also, the depart-ment developed a detailed evaluation form to observe activities in progress and made improvements as necessary. Another I&C department innovation was a turning tool used to quickly reposition valves located in the scram discharge volume cages; this reflected an appreciation for ALARA consideration Department and first line supervisors were knowledgeable about issues affecting their areas of responsibility; this provided evidence of effective communica-tion between workers and supervision. Extensive field presence by supervision was noted as a strength. Department head familiarity with plant systems was enhanced by the fact that both held SRO licenses. In addition, all but one of the five department engineers held operator licenses, and the remaining engineer was scheduled to begin license training with the next available clas This represented a strong licensee commitment to trainin . _ _ . __ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ _

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Two forced outages occurred due to high reactor coolant pressure boundary leak-age: one was caused by a failed recirculation pump seal and the other by a leaking reactor vessel safety relief valve (SRV). Both problems were repeti-tive. Continued attention to repetitive failures is warrante .

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Corrective maintenance outages proceeded smoothly and efficiently. Excellent '

cooperation and communication existed between departments. Conservative atti-tudes were displayed by all levels of licensee participants. A motivated, ex-perienced and well-trained work force continued to be r. strengt Staffing was adequate and backlogs were judged to be acceptable. The maintenance and I&C departments took advantage of power reductions and shutdowns to conduct cor-rective and preventive activities not possible during normal operation. PMMS work order listings for power reductions and hot and cold shutdown were readily available. Extensive preoutage work was completed by both departments and included refueling grapple improvements, hydraulic control unit rebuilding, the installation of new air compressors and associated equipment, and intake structure work, The maintenance and I&C departments performed especially well during the refueling outag Some maintenance personnel errors were noted. Unqualified charcoal was in-stalled in the standby gas treatment system for approximately thirty hours prior to its discovery. Maintenance personnel worked on the wrong (and ener-gized) motor-operator for a LPCI pump suction valve. A sheared plug was not removed from the internals of a fired standby liquid control (SLC) system squib valve. That would have removed one and potentially both SLC trains from ser-vice if the error had not been discovered by the Quality Services Department (QSD) prior to the system's return to service. In all cases, the personnel involved were counseled and procedure improvements were made. Greater atten-tion to detail appears warranted to minimize such error Two LERs addressed missed surveillance. Both cases were attributed to person-nel error and were addressed by procedure improvements. While no safety conse-quences resulted, missed surveillance (four) were also noted during the prior SALP, and continued emphasis on completing required surveillance is appropriat The NRC maintenance team observed that the Production Maintenance Management System was effective in the preparation and control of work orders and in pro-viding maintenance trending information. A weakness was noted: PMMS planning for Millstone 1 Maintenance required excessive overtime by the planner, indi-cating understaffing for this position. Licensee efforts to improve the situation are ongoin The NRC maintenance team noted superior nonlicensed training facilities, with extensive mockups and training equipment. All I&C personnel were trained to level 2 per the INPO Accreditation Program. (Nonlicensed training is addressed further in Section III.G, Safety Assessment / Quality Verification.)

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Quality Control (QC) overview of maintenance and surveillance was adequate. A ;

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program improvement partially replaced the "hcid point" review process with a comprehensive surveillance review. QC findings on procedure discrepancies were incorporated into maintenance procedures. The development of this program was ongoing at the end of the assessment perio '

The licensee utilized the Mechanical Stress Improvement Process (MSIP) for mitigation of Intergranular Stress Corrosion Cracking (IGSCC) on twenty-two (22) reactor system welds. This method is accepted by the NRC and resulted in i significant radiation dose savings through a reduction in inspection duration and preparation. Also, an acoustic local leak detection system was installed on an inaccessible weld in the Core Spray system. Implementation of the IGSCC program was technically adequate and demonstrated good initiative and commitment to safe operatio Licensee control over the inservice inspection (ISI) program and other non-destructive examinations (NDE) was appropriate. Individuals performing the examinations were properly trained, certified to the appropriate level for the task, and demonstrated proficiency. Defects reported by the NDE examiners were properly dispos tioned by knowledgeable engineering personnel and individuals certified as American Society of Nondestructive Testing (ASNT) Level II Mockups were effectively used to prepare for the cutting and removal of a con-trol rod and drive mechanism that could not be separated during the 1987 re-fueling outage. Maintenance personnel went to the Dresden facility (which had a similar incident years ago) to collect information and specialized cutting tools. Additional tooling was developed at Millstone. The . job was thoroughly planned, well executed, and successfu In summary, the licensee had an effective maintenance program. The Maintenance and Instrumentation and Controls departments were well staffed with experienced and motivated personnel. Department management was knowledgeable and well in-formed. Excellent communications were maintained within and between depart-ments. I&C surveillance resulted in no ESF actuations or plant scrams, which was an improvement over the last SALP period. There were few noteworthy maintenance error III.C.1.b performance Ratina: Category III.C.I.c Recommendations: Non III. Millstone 2 Maintenance / Surveillance (1061 hours0.0123 days <br />0.295 hours <br />0.00175 weeks <br />4.037105e-4 months <br />, 25.2%)

III.C.2.a Analysis Maintenance and Surveillance have been combined into one functional area. In the previous SALP, Millstone 2 Maintenance was Category 1. Strengths included management and control of maintenance by a qualified staff, low backlog, and quality control involvement. Weaknesses included the trending program, Pro-duction Test Department performance, and plant trips due to equipment problem Surveillance was rated as a Category 2 the last assessment period. Weaknesses

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i were noted in contractor control, and assurance of quality in SG ECT data interpretation. Calibration and surveillance of safety-related equipment, local leak rate testing, and SG tube inspection were strength During this SALP, strong management involvement in resolving technical issues from a safety perspective was noted in the reactor vessel 0-ring evaluation /re-placement, SG tube plug modifications, reactor coolant pump seal replacement, and correcting safety-related valve leakage. Corrective actions included pro-cedural modifications, design changes, and acquisition of maintenance-enhancing i support equipment such as the reactor flange cleaning machine. Effective maintenance management was evident in a inw ..k backlog. The establishment of goals and attention to workload trends was assessed as goo Maintenance enhancements to improve component reliability and performance in-cluded retubing the reactor building component cooling water (RBCCW) heat ex-changers, rebuilding the RBCCW pump motors, rebuilding safety-related snubbers, replacing service water piping, and increasing vital inverter preventive main-tenanc No reactor trips were related to equipment failure, and there was a reduction in engineered safety feature actuations (nine during the previous SALP, five during the present SALp).

A reduction was noted in reportable personnel error events in maintenance /

surveillance. Personnel errors in adherence to surveillance procedures nonetheless resulted in an engineered safety feature (ESF) actuation (LER 88-04),

extended inoperability of containment radiation monitors (LER 88-10), and a loss of normal power / reactor trip (LER 88-11-01) during pre-refueling outage maintenance. These events illustrate a continued need to minimize the occurrence of personnel error The procedure upgrade program aided maintenance / surveillance effectivenes That program included technical reviews for content and correctness, improved schematics (including three-dimensional ones) and human factors improvement This three year upgrade program is scheduled for completion in 199 Inadequacies in two surveillance procedures resulted in two ESF actuations (LER 89-05 and 88-03). Overall, however, maintenance / surveillance procedural i

adherence was adequate based on observations of various surveillance and maintenance activities during the SALP perio Quality Control (QC) overview of maintenance was adequate. A program improve-ment partially replaced the " hold point" review process with a comprehensive surveillance review process. QC findings on procedure discrepancies were incorporated into maintenance procedures. This program was still under development at the end of the assessment perio A reactor vessel 0-ring failure was caused by insufficient seating surface cleanliness while setting the vessel head during the early 1988 refueling out-ag Extensive management action was undertaken to address the root cause; ,

however, the corrective action was untimely in that three plant shutdowns resulted over three months. Components affected by reduced heat transfer and

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corrosion due to boric acid deposition resulting from the leakage included the l control rod drive mechanism coil stacks, containment ventilation cooler sur-

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faces, and reactor coolant system hot and cold leg nozzles. Subsequent licensee corrective actions were thorough and included cleaning of boric acid deposits, review of environmental qualification considerations, and increased attention to RCS leakag Licensee control over the inservice inspection (ISI) program and other non- i destructive examinations (NDE) was appropriate. Individuals performing the j examinations were properly trained, certified to the appropriate level for the 1 task, and demonstrated proficiency in using the licensee's implementing pro-cedures. Defects reported by the NDE examiners were properly dispositioned by knowledgeable and certified engineering personnel. Through verification of training and administration of practical tests prior to their conduct of ultra-sonic testing, the licensee assured technical competency of contractor ultra- ]

sonic examiners. Certified QC level III individuals were employed to witness and assess the test results and to perform independent reexamination of selected welds. Overall, the licensee's control of contractor ISI and NDE test activi-ties was assessed as goo Licensee planning for SG eddy current testing (ECT) was thorough. Adequate resources were dedicated to perform the testing, analyze the data. and assure control of individual testn Early in the assessment period, additional precautions were instituted to assure proper identification of defective tubes as a result of a tube plugging error in the last assessment period (LER 88-01).

Overview of testing and resolution of problems was goo Water chemist.y quality was improved, placing it well within owner's group guidelines. Decreased SG tube degradation followed: about 3000 tubes were plugged in 1985; about 380 tubes were plugged in 1988. The NRC identified a need for additional steam generator tube inspections to verify this trend, and the licensee responded by planning a mid-cycle shutdow NRC review indicated that maintenance Associated with cold weather preparations was not properly organized and that maintenance work was left partially

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completed: several heating elements and sockets associated with the primary water storage tank, the refueling water storage tank, and the condensate storage tank were found inoperabl There was timely and adequate management involvement in evaluating and resolv-ing maintenance prob! ems associated with the electrical bus fault and reactor trip (LER 88-011-01). Corrective actions were appropriate and included procedure improvements and increased trainin Witnessing and review of containment leak rate testing found conscientious lic-ensee management involvement. Test briefings were informative. Access to test areas was properly controlled. QA/QC provided ongoing coverage throughout the test period, including test preparation The licensee's responsiveness was excellent, as NRC concerns were appropriately resolve _ _ _ _ _ _ _ _ _ _ _ - _ -__-__-__a

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A comprehensive program of formal classroom and on-the-job training for me- l chanics and technicians was noted. Minor improvements to classroom examina- l tions were developed at the end of the assessment period to better reflect job l descriptions in examination content. Nonlicensed training is addressed further )

in Section III.G, Safety Assessment / Quality Verificatio j Overall, the maintenance program was staffed by dedicated, thoroughly trained, knowledgeable engineers, mechanics and technicians. However, an Instrument and Control (I&C) department staffing deficiency resulted in the removal of numerous preventive maintenance activities on Balance-of-Plant (B0P) instru-ments during the outage. Wnile safety-related maintenance was unaffected, management attention is warranted to assure that B0P maintenance weaknesses do not result in unnecessary challenges to safety system For ventilation radiation monitors, NRC review identified a need to improve procedures and procedural adherence. Safety significance of the issue was low because experienced personnel compensated for the procedure discrepancies and the monitors remained operabl A maintenance team inspection was conducted at the end of the assessment period. Both mar.agement support of maintenance and maintenance implementation were found to be functioning well. The plant physical condition was adequately maintained. Maintenance shops were considered to be excellent. Training 4 facilities were superior. Maintenance management controls included the Production Maintenance Management System (PMMS), a company-wide computer system that effectively tracked maintenance work orders, captured work order history, and provided statistical data regarding maintenance. Minor housekeeping items indicated a need for improvement in the licensee's walkdown inspections as they related to attention to detai In summary, the licensee has an acceptable maintenance / surveillance program, with ongoing procedural upgrades, and good management involvement in the ISI program. Surveillance staffing, more timely root cause analysis (as indicated by the reactor vessel head seal 0-ring problem), personnel errors, and engineered safety feature actuations were noted as aspects where improvements could be beneficial to safet III.C.2.b Performance Rating: Category III.C.2.c Recommendations: Non _ _

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II Millstone 1 and 2 Emergency Preparedney (63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> for Millstone 1, 1.8% and 89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> for Millstone 2, 2.1%)

III. Analysis The previous SALP rated this area as Category I based on excellent performance during the partial participation exercise and support provided to off-site governmental emergency preparedness (EP) agencie Emergency Preparedness is supported by the Corporate Organization for Nuclear Incidents (CONI), which remains closely 1ivolved in EP activities. There is a common Emergency Plan for the three units. Emergency Response Organization (ERO) personnel respond to an incident at any unit and are drawn from unit and site staff Consequently, this assessment applies to all three Millstone unit During the s.urrent assessment period, a Millstone 3 full participation exeidse and a routine safety inspection were conducted. The licensee again demon-strated a strong emergency response capability: operator actions were prompt and t.ffective; event classification was timely and correct; and offsite noti-fications were prompt. Operational event classifications for both units during i

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the SALP 9eriod were generally timely and correct. Use of the Offsite Information System (OFIS) was successfully demonstrated. CONI provided strong support to the site including severe accident analysis, classification of the hypothesized release based on plant conditions, and recommendations to reduce the release rate by modifying emergency coolant flow and control of offsite monitoring teams. The licensee ensured that the Connecticut State Government was well informed and supported by sending a four person team to the State Emergency Operations Center. No exercise weaknesses were identified. The lic-ensee's response indicated a well trained emergency response organizatio Routine inspection examined all areas of the licensee's emergency preparedness I program. Emergency Response Facilities were maintained in a state of readi-ness, plans and procedures were current, and emergency communication systems were operative. The site emergency preparedness program was maintained by a Senior Nuclear Emergency Preparedness Coordinator supported by site organita-tions, by the Corporate Headquarters Emergency Preparedness Section, and by an individual who is assigned to this activity for 80% of his time. Although the emergency preparedness program was well maintained, a concern was identified regarding the independence of auditors performing the annual audit / review. The auditors were members of another section of the branch in which the Emergency Preparedness Section was located. A second concern was for the nature and depth of the audit: the quality of the program and its resource adequacy were not addressed. Although there was no indication of any significant weaknesses in the emergency preparedness program, the licensee needs to be able to rely on better internal audits to avoid any decline in performance.

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ment of lesson plans and training methods. An Emergency Preparedness Training Manual was developed, reviewed, approved and placed in use during this assess-

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ment period. This manual was well organized and clearly stated the Emergency Preparedness training policy, listed Emergency Response Organization positions i and associated qualifications, listed the required training for each position and set the requalification period. Emergency preparedness training was very effective as demonstrated during the annual exercis In summary, the licensee has developed and maintained a strong Emergency Pre-paredness Program as evidenced by very good exercise performance, well main-tained Emergency Response Facilities, excellent working relationships with offsite authorities, and effective trainin III. Performance Rating: Category III. Recommendations: Non II Millstone 1 and 2 Security (Millstone 1,145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br />, 4.3%. Millstone 2, 158 hours0.00183 days <br />0.0439 hours <br />2.612434e-4 weeks <br />6.0119e-5 months <br />, 3.7%)

III. Analysis During the previous assessment period, the licensee's performance was rated Category This was a rating decline which was primarily attributed to a de-crease in management oversight in routine program implementation that resulted in several violation .

During this assessment period, three routine unannounced physical security in-spections were performed by region-based inspectors. Routine inspections by the resident inspectors continued throughout the period. Two violations and one enforcement discretion item were collectively assessed as having minor security significance. The enforcement actions, however, identified a need for improved management focus on engineering interface with the security organiza-tion as it relates to as-built configurations and plant modifications. Near the end of the assessment period, the licensee identified the root causes, took timely and effective action to correct the violations, and strengthened proce-dures to prevent recurrence. Also during this assessment period, a Regulatory Effectiveness Review (RER) was conducted. The RER team identified several potential weaknesses and the licensee again promptly initiated an aggressive program to resolve the issues, showing positive response to NRC concern Corporate security management involvement in the security program was apparent by numerous corporate staff visits to the site to provide assistance, to con-duct program audits, and to support the site organization in budget.ing and planning activitie In addition, two new positions were created and filled in the corporate system security group to assist in these activities. Corporate and site security management personnel also continued to be actively involved in the Region I Nuclear Security Association and other industry groups engaged in nuclear plant security matters. This demonstrated program support by upper level corporate managemen _ ._ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ -

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.The NRC-required annual audit of the security program was performed by person-nel from both the corporate security system and quality assurance groups. The audit focused on program effectiveness as well as compliance. (This was a recommendation of the previous SALP report.) The audit was very' comprehensive in scope and depth. In addition, the licensee continued to conduct self-assess-ments of the program, utilizing experienced security management personne Corrective actions on findings and recommendations identified during the audits and self-assessments were generally prompt and effective, with adequate follow-up to ensure their proper implementation. The strong management commitment to )

the security program and the comprehensive audit and self-assessment program were major factors in the licensee's recent good enforcement histor Management of the site organization was restructured into three specific areas of responsibility. A supervisor was assigned to each area to better control and manage the various aspects of the program. Effectiveness of this action was evidenced by a more cohesive progra The site security supervisor and staff were well trained and qualified security professionals vested with the authority and discretion to ensure that the pro-gram was carried out effectively and in compliance with NRC regulations. Moni-toring of the security force contractor's performance included round-the-clock coverage using proprietary shift security supervisors. Staffing of the con-tractor security force was consistent with program needs; however, the security force continued to experience a high (about 47% during this period) turnover rate. Contractor efforts to reduce turnover were not successful, but the licensee and the contractor continued to pursue this issu The security training group was incorporated into the security operations group in order to make training more aware of and responsive to operational need Additionally, an administrative review committee was formed to provide better management oversight and to review changes to program plans, procedures, systems, equipment, lesson plans, and post orders. A matrix was also developed to cross reference program plan sections to procedures and commitments made as a result of audits, inspections and security event report The licensee's event reporting procedures were found to be clear and consistent with 10 CFR 73.71. Sixteen security event reports (SERs) were submitted for the site during the SALP period. These included: four reports of security of-ficers inattentive on duty; one report of a vital area door alarm being inad-vertently taken out of service; three reports of vital area pathways not being properly protected; two reports on a strike by the security force; one report of failure to deactivate the badge and key card of a terminated empbyee; three reports of security system and computer malfunctions; and two repotts of am-munition being found.in the protected area. All of the events were properly followed up by the licensee, and compensatory measures were implemented as

, required. Two of the reports were late due to personnel error. The licensee's event reporting program was acceptable, but at least two of the more signifi-cant events were repetitive. The recurrent events involving inattentiveness indicate a need for continuing attention to root cause analysis, even though l .the number of reportable events has decreased since the last SAL ._ - . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

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i 1 During this SALP period, the number of security computer events also decreased (three compared to ten during the last period). This increase in security ef-festiveness was attributed to the assignment of dedicated instrumentation and controls (I&C) technicians to the security departmen During this assessment period, the licensee submitted five security plan ,

changes'and one training and qualification plan change in accordance with 10 CFR 50.54(p). The proposed changes were generally clear and well documented, and the licensee was very responsive in providing amplifying information when requested. This indicated a good working knowledge of the security program by personnel responsible for preparing and submitting the change During the previous assessment period, the NRC identified several potentia'l weaknesses with protected area lighting and intrusion detection system The licensee was very responsive and aggressively acted to upgrade the system Similar excellent response was demonstrated when the NRC identified several other potential problem areas, showing the licensee's desire to implement an effective security progra In addition, as a result of allegations by a for-

.mer employee, the licensee provided additional fitness-for-duty training to its contractors' supervisors to strengthen their oversigh In summary, the licensee is. implementing and maintaining an effective and per-formance-oriented nuclear security program. Significant program enhancements were made and indicated management attention to and interest in the progra Improvements in the audits and self-assessments have also been effective in focusing on program effectiveness rather than just compliance. The successful efforts to upgrade the operation and reliability of systems and equipment demonstrated commitment to a high quality security progra Strong management commitment and comprehensive audit and self-assessment programs were assessed as major contributors to good security performanc III. Performance Rating: Category III. Recommendations Non II Millstone 1 and 2 Engineering / Technical Support This is the second SALP in which Engineering and Technical Support is asa,essed as a single area. The evaluation is based on technical support inspections and on observations obtained during inspection of other functional area Engineering support to Millstone was provided by both onsite (Northeast Nuclear Energy Company - NNECO) and corporate (Northeast Utilities Service Company -

NUSCO) staffs. Approximately 1000 engineering employees of various technical disciplines supported the four NU nuclear plants. Based on the licensee's suc-cess in implementing major projects and in providing comprehensive technical

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reviews even on a reactive basis, Millstone 1 and 2 received an equitable share of the corporate engineering support available during this SALP cycle. Over-all, staffing levels for technical support were assessed as adequat ' Additional technical support was provided by the Production Test (PT) depart-

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ment, which was composed of electrical and electronic engineers and technicians who dealt mainly with electrical generation and distribution equipment. PT was observed to be highly knowledgeable and diligent in troubleshooting complex electrical plant problems and in design change installation and testing. The group was a clear asset to Millston Positive aspects of the EEQ program included knowledgeable EQ engineers and the licensee's initiative of engaging contractor aid to conduct an independent re-verification of the EEQ program. However, three violations including a civil penalty were issued for EEQ documentation inadequacies occurring in a previous SALP cycle. While the findings collectively had minimal safety significance, the NRC concluded that the licensee had failed to apply best efforts to complete the EEQ progra III.F.1 Millstone 1 Engineering / Technical Support (363 hours0.0042 days <br />0.101 hours <br />6.001984e-4 weeks <br />1.381215e-4 months <br />,10.6%.) <

III.F.1.a Analysis In the previous SAlp, Millstone I was rated as Category 2 in Technical Suppor Strong engineering was evident in the fire protection program and in the enhancement of normal and emergency power availability. Weaknesses were identified in reporting and in responsiveness to NRC environmental equipment qualification (EEQ) initiatives. In addition, fifteen licensee event reports (LERs) were attributed to a lack of follow-through by the technical staf During the current SALP period, an effective interface between site and cor-porate engineering staffs was observed. Well defined responsibilities and communication lines between organization counterparts were noted during the outage and licensee efforts on masonry walls. Extensive technical corporate presence was observed during implementation of complex projects like the spent fuel pool rerack, the gas turbine generator (GTG) governor replacement, and the loss of normal power (LNP) detection modificatio In reexamining previously completed and accepted technical reviews, corporate engineering was self-critical and identified significant errors such as high ,

energy pipe break (HEPB) analysis discrepancies for the reactor building closed i cooling water (RBCCW) syste (This finding appeared to be generic among BWRs {

with Mark I containments.) The licensee modified the system with a technically {

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sound and comprehensive design change package which illustrated the ability to promptly resolve a significant proble The NRC staff interacted with the licensee's engineering and technical support I group to resolve licensing issues including spent fuel pool expansion, core reload review / removal of cycle specific parameters from technical specifica-tions, ECCS power supply requirements, and ECCS strainer blockag Licensee l

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submittals on these issues were technically well prepared, and anticipated NRC I staff concerns. Modifications that had potential safety impact were promptly i reported to the NRC staff. To assure top management involvement in the timely review and reporting of issues, a monthly status report listing all reportable ,

evaltrations was issued. The current assessment, through April 1989, indicates j there were no past due evaluation ,

i A scram occurred when a moisture separator (MS) normal drain valve failed to open causing low MS level and vibration due to steam intrusion, and tripping .

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the MS high level limit switch. The resulting turbine trip (TT) initiated a reactor scram. As this event had occurred previously at Millstone 1, the licensee had already planned to modify the MS-TT logic during the outage to reduce the potential for spurious scrams. Earlier installation of this modification could have prevented the scram, but modification timeliness was  ;

considered appropriate and the modification was a good license initiativ The licensee performed a safety system functional inspection (SSFI) of the feedwater coolant injection (FWCI) system. That was a positive self-assessment initiative which provided a detailed review. Onsite engineering personnel were persistent in resolving all 96 SSFI findings within four weeks of the inspec-tion's conclusio The licensee's ISI program is well defined and controlled. Training and test-ing of ISI contractors, use of licensee-developed ISI procedures and indepen-dent reexamination and evaluation of contractor inspections were excellent licensee initiatives that enhanced contractor control and inspection qualit The licensee's response to NRC Generic Letter 88-01 regarding stress corrosion cracking in BWR piping was timely and licensee initiatives, such as mechanical stress improvement of piping welds and installation of local acoustic leak detection monitoring, demonstrated good engineering and a safety conscious attitud Instances of ineffective engineering included an error (licensee iden-tified) in an EEQ exemption request for the reactor water cleanup supply line i motor-operators, which necessitated a justification for continued operation (JCO) and a reactive modification to the system's isolation instrumentation. A violation was issued for failing to maintain the material equipment and parts list (MEPL) current. In one instance, that resulted in the emergency diesel 4 generator being inoperable for seventeen hours prior to discovery due to the installation of a nondedicated commercial part. Additionally, the licensee discovered that a previous engineering review failed to identify that the absence cf seismic anchers on a specific non-safety-related 4 KV bus could I result in a total loss of unit AC powr. The performance significance of these engineering lapses was reduced by licensee identification and the quality of the response to the problem l A loss of normal power (LNP) actuation during the outage was attributed to an engineering oversight. The licensee was installing the LNP modification while attempting to keep the original scheme in service. An unintended overlap be-tween the old and new LNP actuation schemes through an auxiliary relay coil ,

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tive errors and missing evaluations in the supporting calculations for the con-tainment control procedures, and concluded that inadequate attention had been allocated to the E0P effort. Upon identification of the errors, dedicated en-gineering support was expended on prompt correction of the Revision 2 E0P '

The licensee displayed an increased sensitivity to NRC reporting requirements, with seven licensee event reports (LERs) made during the SALP cycle because of engineering findings. These included the RBCCW HEPB issue and the EEQ exemp-tion request for RWCU motor-operators. Four LERs were attributed to a lack of follow through by the technical staff, as compared to fifteen in the last SAL In summary, Millstone I technical support was provided by knowledgeable engi-neers who conducted thorough and generally conservative technical review While the group is to be commended for their deficiency discoveries, process improvements are needed to reduce the number of technical evaluation error III.F.1.b performance Rating: Category III.F.I.c Recommendations Licensee: Improve technical evaluation III. Millstone 2 Engineering / Technical Support (284 hours0.00329 days <br />0.0789 hours <br />4.695767e-4 weeks <br />1.08062e-4 months <br />, 6.7%)

III.F.2.a Analysis Millstone Unit 2 was rated Category 2 in this area in the previous SALP. Lack of follow through by the technical staff resulted in ten Licensee Event Report Technical support inadequacies were shown by inconsistency of the reactor cool-ant pump requirements based on the safety analysis in an RBCCW heat exchanger error in service water flow, and by inadequate fire protection for charging pump supports in the main cable vaul During the current SALP period, the engineering staff was adequately staffed with experienced personnel. Extensive interfacing between corporate and plant engineering was evident in corporate engineering involvement in the development of major plant modifications, support to resolution of problems, and partici-pation in the generation of plant design changes. Also, engineering department resolution of technical issues with various vendors was thoroug Examples include the SG plug-in plug (PIP) installation, control rod drive mechanism coil stack replacement, wide-range nuclear instrumentation testing / evaluation, turbine rotor repair, motor-operated valve in-situ testing / torque switch re-placement, and power supply replacement for the reactor protection and engineered safety features actuation system. Engineering actions in evaluating the North Anna SG tube failure and disposition of suspect SG tube plugs late in the refueling outage showed a strong regard for safet _ - ____- _ __ ___ _ -

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The plant took an innovative approach to improving containment monitoring by installing a camera in the loop area for monitoring at power. An in-service test was used to evaluate camera performance for future applications. Vibra-tion testing was used for safety-related and non-safety related pumps, using state of the art equipment to track and analyze vibration signature In meetings with the NRC, the licensee displayed a strong commitment to nuclear safety and reliability as it pertained to plant enhancement. Ongoing programs

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promoting reliability included the Snubber Service Life Program, the Valve Overhaul Program, ILRT Valve Program, and the 480 volt Load Center Breaker During the previous SALP period, the steam generators were returned to service without correcting all tube defects. The licensee took aggressive steps and improved the eddy current test (ECT) analysis technique and training to miti-gate the potential for a steam generator tube leak. In addition, the licensee's evaluation of the steam generator tube working problem was excellent. Engi-neering support of the surveillance program included laboratory evaluations of nondestructive testing techniques, evaluations of a cracked tube previously removed from service, a unique method for evaluating tube stresses to identify susceptible tubes, laboratory evaluations of water chemistry controls to in-hibit cracking, and assessment of corrective actions. These initiatives demonstrated excellent engineering effort Plant engineering interface with other departments was good as it related to leak repair evaluations, support of plant operations, and implementation / con-trol of plant design change request An internal licensee audit was conducted on material equipment and parts list (MEPL) implementation of quality assurance (QA) indicators into the computer-ized Production Management Maintenance System (PMMS). The result indicated incomplete review of safety-related instrumentation: QA status was not identi-fled in numerous cases. The licensee hired a contractor to reevaluate past MEPL evaluations on safety-related instrumentatio In the interim, the lic-ensee assigned work as if QA controls were required if the QA classification was previously assessed as unknow The internal licensee audit was extensive, and licensee short-term corrective actions were conservativ In summary, the engineering and technical support groups were competent and actively involved in plant modifications, design improvements, and resolving problems. The problem of returning the steam generators to service with defi-cient ECT indications was adequately addressed and steps were taken to prevent recurrence. The licensee showed a continuing determination to improve equipment reliability and an in-depth commitment to safet III.F.2.b Performance Rating: Category 1 III.F.2.c Recommendations: Non __ _ ._ _-

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II Millstone I and 2 Safety Assessment / Quality Verification In previous SALP reports, Assurance of Quality and Licensing Activities were evaluated separately. The Safety Assessment / Quality Verification area con- i solidates these areas and encompasses activities such as safety reviews and responses to NRC initiatives (e.g., generic letters and bulletins), and assesses .

of the licensees ability to identify and correct problem '

The licensee has demonstrated an aggressive attitude toward safety. One example was-the safety system functional inspections (SSFI) modeled after NRC 1 SSFIs. SSFIs were conducted by the licensee for the condensate /feedwater/ feed-water coolant injection system in Millstone 1 and the reactor building component cooling water system in Millstone 2. The SSFIs made significant  ;

observations which were promptly addressed. The licensee used other self-assessment programs, both self-initiated and required by technical specifica- ]

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tions, to evaluate the effectiveness of activities that could affect safe plant operation. These included the Nuclear Review Board, Site Nuclear Review Board, Quality Services, Integrated Safety Assessment Program, Human Performance Evaluation System, and licensee corporate assessment to review the Material Equipment Parts List and PMMS interfac High quality nonlicensed training was demonstrated through innovative programs initiated or continued during the perio Examples included: improved instruc-tional techniques to enhance learning and retention; pre purchase assessment and procedure development for new gas chromatography for use in the Millstone 1 and 2 chemistry laboratories; training on the actual Woodward governor in-stalled as a design change on the Millstone I gas turbine generator; use of the Training Management System, a computer database developed by the licensee to track incorporation of industry experience and events into training programs; and implementation of a plant internship program where instructors and plant supervisors exchanged roles for one month assignment Management commitment to training was demonstrated in the nonlicensed training area through the initiation or continuation of programs designed not only to provide a highly qualified work force, but one which also interacted with plant operating activitie Effectiveness and success of the nonlicensed training program was demonstrated by few personnel errors and in the overall good record noted in the conduct of operating activitie III. Millstone 1 Safety Assessment / Quality Verification (440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, 12.9%)

III.G.I.a Analysis In the previous SALP, Assurance of Quality and Licensing Activities both re-ceived Category 2 ratings. For Licensing Activities, the previous SALP noted a well managed and knowledgeable staf It also noted a lack of timeliness in licensee response to NRC initiatives and in licensee submission of Technical Specification change requests. For Assurance of Quality, the previous SALP noted that the work force showed pride in workmanship, professionalism in the discharge of their duties, and strong PORC performance. In addition, the licensee's audit program was found to be particularly strong. The previous

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SALP also noted a need to improve self-assessment by the security force, at-tention to shelf life for material storage, and documentation /recordkeeping for I design change !

During the current SALP, nineteen license amendments and one exemption were {

issued. Many of the amendment requests involved complex issues, were charac- . 1 terized by extensive analysis, and were submitted in well prepared packages {

which facilitated NRC review. There has been improvement in the timeliness of 1 licensee submittal {

During the previous SALP period, it was noted that the licensee maintained ade-quate procedural controls to determine the existence of unreviewed safety ques-tions in accordance with 10 CFR 50.59. The NRC conducted an on-site audit of changes undertaken durfng 1988-89 which were subject to 10 CFR 50.5 Un- <

reviewed safety question determinations were found to be extensive, to contain conservative assumptions, and to be performed with a good overall regard for nuclear safety. plant design change records were found to be complete, well i organized, and in accordance with licensee procedures and regulatory require-

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ment Millstone 1 implemented a conservative approach during routine operations and in resolving equipment failures and other events affecting operations. An ex-ample was the licensee's decision to return to cold shutdown for inspection of all main steam line (MSL) flow instrument tubing after a blocked MSL flow in-strument caused a spurious Group I isolation during a startu Unit management held employees accountable for their efforts and provided strong direction, particularly during the outage. Unit management was well informed by effective communications with worker PORC sessions continued to critically assess issues from both a nuclear and personnel safety perspectiv First line and department supervisors were regularly observed at work sites, particularly during significant or nonroutine evolutions. The absence of sur-veillance-related ESF actuations or reactor scrams provided evidence of the success of this approach and of an improvement over the last SALP period. The NRC observed strict procedural adherence and extensive plant personnel familiarity with administrative controls. The procedural upgrade program, which spans the Engineering, Maintenance, Instrumentation and Controls, and Operations department procedures, was viewed as a positive licensee initiative to provide more accurate direction to plant personnel. All personnel levels exhibited pride and responsibility toward their wor Personnel training was effective, as evidenced by the absence of scrams or forced shutdowns caused by training 11 adequacies. Many operators held licenses ,

in excess of that required by their usual shift position Personnel outside l of operations who held NRC operator licenses included most department heads and  !

engineers. This showed a strong management commitment to trainin i Millstone 1 initiated two long term housekeeping projects, decontamination and equipment and area painting, to improve facility accessibility and appearanc The licensee initiated a thorough cleaning project within the drywell when the NRC Maintenance Inspection Team identified housekeeping inadequacies. Plant housekeeping was assessed as acceptable during this assessment perio . _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -

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Plant Incident Reports and Licensee Event Reports (LERs) continued to be ac-curate and well written, with sufficient detail and root.cause analyse .Also, there was increased sensitivity to reporting of engineering findings, which was an improvement over the last SALP period. A minor weakness was noted: some LERs submitted near the end of the refueling outage did not provide a concise safety assessment of the individual even ,

NRC noted that control and biennial review of station operations procedures could be improved. Some procedures were not updated to include several pre-vious procedure change notices as required by administrative control proce-dures. Also, the licensee's QA organization had not performed any audits to verify the adequacy, effectiveness and timeliness of implementation of cor-rective action commitments for NRC concerns, SALP Board recommendations, or LER The security self-assessment program improved with the addition of an annual security program audit. The inspectors found the audit to be comprehensive, and corrective actions on findings were generally prompt and effectiv The licensee instituted a degradable materials program which starts with procurement and receipt inspection. A systematic evalt.ation process for all onsite degradable materials was ongoing at the conclusion of the perio Overall, the licensee maintained a well managed, knowledgeable staff and was effective in implementing self-assessment programs and corrective' actions. The licensee improved weaknesses identified in the previous SAL III.G.I b Performance Rating: Category III.G.I.c Recommendations: Non III. Millstone 2 Safety Assessment / Quality Verification (762 hours0.00882 days <br />0.212 hours <br />0.00126 weeks <br />2.89941e-4 months <br />, 18.1%)

III.G.2.a Analysis In the previous SALP, Assurance of Quality and Licensing Activities separately received Category 2 ratings. The previous SALP noted that " Licensing Activi-ties" strengths included completeness of submittals, involvement of management, and technical expertis Lack of timely response to NRC initiatives was a noted weakness, particularly in regard to fire protection. For " Assurance of Quality," the previous SALP noted that the work force showed a good attitude, pride in workmanship, and professionalism. The licensee's audit program was found to be particularly strong. The previous SALP also noted a relatively high rate of plant trips, a need for improved in self-assessment by the security force, attention to shelf life for stored materials, and recordkeeping for design change During this SALP period, 39 licensing issues were resolved, including 22 lic-ense amendments. In resolving licensing issues, the licensee made a notable l improvement in the timeliness of responses to NRC initiatives. If a submittal was expected to be late, the licensee almost always contacted the NRC to identify the dela ______ - --- _______- _____-_____ - -_ _ _

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- 32 Licensing issues were characterized by extensive analysis by the licensee. In each case, the submitted application was well prepared and provided adequate support for the proposed license amendment. For the Cycle 10 review, a new fuel vendor, Advanced Nuclear Fuel (ANF), provided both fuel and analytic ser-vices. The licensee provided notable coordination with ANF and addressed the previous short review time provided to the NRC by dividing the review into sub-mittals that could be made more expeditiously available. A request for opera- .

tion at reduced RCS flow rate, however, was submitted at a late stage of the application review for Cycle 10 operation. This allowed the staff a very short time to complete the review and created difficulty in combining the two license amendment applications into one amendment. Better planning on this long expected need could have provided more timely Technical Specification changes and supporting analyse An emergency request for an amendment for the operation of the spent fuel pool cooling system under limiting conditions during the refueling for Cycle 10 operation failed the emergency provisions criteria of 10 CFR 50.91, in that the application was not timel Millstone 2 fire protection licensing reviews continued to be a weakness. The two key difficulties were:

-- Ventilation: The licensee's position on the need for post-fire temporary ventilation in safety-related areas changed substantially during the re-view. Initially, the licensee indicated that no temporary ventilation was needed for certain areas. Subsequent NRC and licensee review indicated a need for temporary post-fire ventilation in several key safety-related plant locations. The NRC staff's May 18, 1989 letter to the licensee indicated that additional licensee evaluation was required concerning post-fire ventilatio In this regard, the NRC found the licensee submittals to be untimely and incomplet Restoration of AC Power: the licensee was initially unresponsive to the NRC staff's attempt to resolve issues associated with post-fire feedback of power from Millstone 1 to Millstone 2. The NRC staff wanted to determine the length of time required to establish feedback power. The licensee appeared unwilling to to demonstrate adequacy via a " walk down."

After repeated requests, the licensee walked down Procedure AOP 2579A, Contingency Fire Procedures for Hot StanJby Appendix 'R' Fire Area F-1, on October 7, 1988. This issue remained unresolved at the end of the SALP perio Review of the licensee's 10 CFR 50.59 program found a very thorough 10 CFR 50.59 procedure which prescribed a detailed and explicit 10 CFR 50.59 deter-mination. The procedure also allowed alternate safety evaluation formats, with the proper approval. As an example, the staff engineering department developed its own instruction for a narrative style of safety evaluation. This provided a well developed description of the change, followed by a logical analysis of the effects on safety. While the narrative style provided less assurance of addressal of all elements of 10 CFR 50.59, no associated evaluation

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inadequacies were found. NRC evaluation of the licensee's 10 CFR 50.59 reviews for. major plant design . changes and modifications included service water pipe replacement, steam generator plug-in plug implementation, and turbine rotor '

cracking modification. Unreviewed safety question determinations were found to be extensive and conservative, with a good regard for nuclear safet l The licensee has instituted a degradable materials program which starts with procurement and receipt inspection. A systematic evaluation process for all onsite degradable materials was ongoing at the conclusion of the perio Two violations and one deviation were issued for post-test configuration and surveillance of containment gaseous and control room radiation monitors. One escalated enforcement action was levied for environmental equipment qualifica-tio Enforcement discretion was used in not issuing citations for control room ventilation operation, inoperable fire seals, controls for vital security areas, and contraband within protected areas. A reduction was noted in cited violations of NRC requirements from previous assessment period During the SALP period, the licensee developed numerous justifications for operations related to: increase in ultimate heat sink temperatures; wide-range I nuclear. instrumentation cabic.s; steam generator mechanical plugs; and motor- !

operated valve melamine torque switches. Extensive engineering support, man-agement oversight, and in-service testing soundly supported the licensee's rationales for continued plant operatio Numerous on-site operational review committee meetings were observed. Good safety evaluation presentation, content, and probing reviews of unreviewed safety question submittals were note The unpredicted decrease. in reactor coolant system flow, repetition of leakage from the reactor coolant system via the reactor vessel head 0-ring, and recur-ring safety-related motor / pump coupling failures indicated a need for improved root cause analyses. The reactor vessel head 0-ring leakage caused three forced outage The licensee had not established a mechanism to administrative 1y control plant quality assurance activitie NRC inspection concluded that the QA audit de-partment was not sufficiently aggressive in ensuring timely station response to their surveillance findings on Millstone Management involvement in assuring quality could be improved in this regar Of.the five allegations brought to the NRC, three were from licensee employees who expressed multiple and ongoing concerns about facility safety, particularly in regard to procedure adherenc Initial NRC follow-up of these multi-faceted allegations found no specific safety inadequacies, but did note procedural noncompliance which did not re- l sult in procedure changes. Associated procedural noncompliance resulted in one notice of violation, one notice of deviation, four unresolved items, and numerous allegation dispositions as having little or no safety significanc :

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Incident to review of the multiple allegations by employees, the licensee's employee concerns program was reviewed with and upgraded by the license Also, an employee survey was conducted by the NRC to obtain anonymous inputs on the credibility of the employee concerns program. The NRC conclusion was that a substantial majority of employees felt their concerns were adequately ad-dressed through existing systems, including discussion with their supervisor Review of the survey also produced the conclusion that the licensee should '

further emphasize soliciting of employee concerns and assuring that employees respect the employee concerns program. NRC review of the ongoing allegations is continuin In summary, the NRC found worker morale to be generally high and noted a sig-nificant improvement in the timeliness of licensee responses to NRC safety in-itiatives. However, several license amendments, including an emergency amend-ment and an amendment for a reduction of reactor coolant system flow (both of which could have been long anticipated) were submitted at the last moment for staff actio Licensee management should give increased attention to resolving outstanding fire protection items. The licensee's management is generally pro-active as reflected in their self-assessment activities. More attention, how-ever, should be paid to timely root cause analyses and to ef fective solicita-tion of employee concern III.G.2.b Performance Rating: Category III.G.2.c Recommendations Licensee: Further emphasize solicitation and resolution of employee concern NRC: Conduct a mid-SALP review of the effectiveness of the licensee's program for soliciting employee concern ,

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l REFERENCE INFORMATION l Criteria  ;

Licensee performance was assessed in areas significant to nuclear safety and/or the environment. The following were evaluated, as applicable.- 1 Asurance of quality, including management involvement and contro . Approach to the resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Operational events (including response to analyses of, reporting of, and corrective actions for). Staffing (including management). Effectiveness of training and qualificatio l Each functional area was rated as being one of the followin . Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially ex-ceeding regulatory requirements. Licensee resources are ample and effec-tively used so that a high level of plant personnel performance is being achieve Reduced NRC attention may be appropriat . Category Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated.so that good plant ard personnel performance is being achieved. NRC atten-tion may be maintained at normal level . Category Licensee management attention to and' involvement in the per-formance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed minimum regula-tory requirements. Licensee resources appear to be strained or not ef-fectively used. NRC attention should be increased above normal level The SALP Board also considered assigning performance trends for the last por-tion of the SALp period. A trend is assigned if it is definitely discernible, if the SALP Board concludes that its continuation might change the licensee's performance level, and if it is considered necessary to either focus attention on declining performance or acknowledge improving performance. The SALP trend definitions are:

Improving: Licensee performance was determined to be improving during the lat-ter part of the assessment perio Decli,nt :: Licensee performance was determined to be declining during the lat-ter par *. of the assessment period and the licensee had not taken meaningful steps t: address this patter RI-1

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l Licensee Activities  !

l B.1 Millstone 1 l

Millstone I was operating at full power at the beginning of the period. On March 12, 1988, the unit scrammed on low reactor vessel water level due to a '

spurious feed pump trip and a subsequent failure in the reactor water level q control system. The unit returned to full power on March 1 i I

Full power was interrupted by power reductions required by Technical Specifi-  !

cations (TSs): loss of emergency service water (ESW) on September 8; loss of I the standby gas treatment system on September 23; and loss of one ESW pump with I simultaneous loss of the emergency diesel generator on October 12. The power l Teductions lasted from two to twelve hours prior to the completion of correc-tive maintenance and subsequent power ascensio On November 13, Millstone I was taken to cold shutdown because unidentified primary leakage exceeded TS limits. The licensee repaired the leakage by re-placing two reactor pressure vessel safety-relief valve (SRV) topworks assem-blies and repairing an SRV tailpipe vacuum breaker. When a primary containment Croup I isolation occurred during startup on November 17 due to a blocked main steam line (MSL) flow instrument sensing line, the licensee chose to return to cold shutdown for further investigatio Startup resumed on November 1 On April 7, 1989, while shutting down for the Cycle 12 refueling outage, the unit scrammed from 80% power due to a turbine trip generated by an erroneous high moisture separator level signal. Cold shutdown was attained on April In addition to the Cycle 13 reload, major outage activities included installa-tion of environmentally qualified (EQ) motor operators on selected containment isolation valves (CIVs), replacement and upgrade of the gas turbine generator governor control system, installation of the degraded grid modification, re-placement of emergency core cooling torus suction strainers, and addition of EQ CIVs for the reactor building closed cooling water syste Cycle 13 startup ommenced on May 2 Full power was achieved on May 29; but recirculation pump seal failure later that day caused primary leakage to exceed TS limits. Cold shutdown was attained on May 30. During the startup on June 2, the unit scrammed when the operating shift allowed reactor pressure to ex-ceed 600 psig with main condenser vacuum less than 23" Hg. Restart occurred l later that da Full power operation was resumed for the remainder of the perio B.2 Millstone 2 Millstone 2 began the Cycle 8 refueling outage at the start of the perio Major outage activities included refueling, steam generator (SG) eddy current testing (ECT), the Containment Integrated Leak Rate Test (CILRT), service water l

pipe replacement, human factors modifications in the control room, and reactor

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coolant pump (RCP) motor replacement. The unit returned to full power on February 2 RI-2 (

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On April 8, the unit shut down to investigate increased unidentified leakag During the shutdown, a control element assembly (CEA) failed. The unit pro- i gressed to cold shutdown to repair various valve leaks inside containment and repair the CEA. The unit returned to full power on /.pril 1 On May 6, the plant was shut down due to increased reactor coolant system leak- . !

age. The leakage was located near the reactor vessel 0-rings. The licensee replaced the. vessel 0-rings and cleaned boric acid from reactor coolant system j components. The unit returned to full power on May 2 '

On June 7, the unit experienced multiple control element assembly (CEA) fail-ures and proceeded to cold shutdown. All Control Element Drive Mechanism (CEDM) coil stacks were replaced and the unit returned to full power on June 1 A loss of normal power (LNP) reactor trip occurred on October 25 due to a pre-refueling maintenance activity that caused a fault on a safety bus. Following inspection of the bus, the unit was returned to power on October 2 The plant began a scheduled shutdown for the Cycle 9 refueling outage on Febru-ary 4, 1989. Major outage activities included implementation of the antici-pated transient without a scram (ATWS) system, SG ECT, installation of plug-in plug modifications to existing SG tube plugs, inservice inspection (ISI) of the reactor coolant system, and service water piping replacement. The unit returned to full power on May 10 and remained there for the rest of the assessment perio Direct Inspection and Review Activities t

One NRC senior resident and three resident inspectors (1 for each unit) were assigned to the Millstone site throughout the assessment period. Total NRC in-spection effort was 3410 hours0.0395 days <br />0.947 hours <br />0.00564 weeks <br />0.0013 months <br /> for Millstone 1 (2339 per year) and 4220 for Millstone 2 (2895 per year).

Several team inspections were conducted. A Regulatory Effectiveness Review (RER) assessed station security program effectiveness (June 7-15,1988). Re-views were conducted for the Millstone 1 and 2 Emergency Operating Procedures (EOPs) (June 13-30, and May 10-17, 1988, respectively) and the station main-tenance. program (May 30 - June 16,1989). Three reactive inspections were con-ducted, two in response to a station security force strike (May 2-3 and May 16-17,1988) and one in response to a radiological transportation incident (May 17-18,1989) involving a contaminated hydrolysing rig being shipped from Mill-stone RI-3

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. Unplanned Trips and Forced Shutdowns MILLSTONE 1 Power Root Functional Date Level Description Cause Area

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1 3/12/88 100% Automatic scram on low reac- FWCS relay None; random tor water level due to a failure component feedwater pump trip and failure, subsequent level control system failur /14/88 100% Controlled shutdown due to RPV SRV top- Maintenance /

primary containment leakage works and Surveillance rate in excess of TS limit tailpipe vacuum breaker failure ,

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4/7/89 80% Automatic scram on turbine Lack of coin- Engineering /

trip due to false high cidence in Technical high moisture separator turbine trip Support level signa logic on high moisture separator leve /29/89 100% Controlled shutdown due to Failed recir- Maintenance /

primary containment leakage culation pump Surveillance in excess of TS limit sea /2/89 IRM Automatic scram during Cycle Operator Operations Range 9 13 startup by exceeding 600 erro psig without 23" Hg vacuum in the main condense MILLSTONE 2 4/6/88 100% A shutdown was required when Reactor Vessel Safety Assess-a control rod became inoper- Head 0-ring ment / Quality able (LER 88-008-001). Pri- lea Verification mary system leakage caused boric acid deposition on the rod operating mechanism, and the consequent loss of cooling caused coil failure from over-heating. The rod dropped during the con-trolled shutdow RI-4

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Power Root Functional Date Level Description Cause Area 5/6/88 100% Unscheduled controlled plant Reactor Vessel Safety Assess- ,

shutdown to locate reactor Head 0-ring ment / Quality i coolant system leakag lea Verification '

Primary leakage from the reactor vessel head 0-rings was identified as the source. The plant remained shutdown until May 23 to evaluate and clean boric acid from the reactor coolant system components and auxiliarie /7/88 100% CEA failure and required Overheating Engineering /

shutdown per TS. The plant coil stack Technical Sup-remained SD until June 15 to from degrada- port replace all CEDM coil stacks tion of CEA (LER 88-09). ventilation cooling result-ing from the previous 0-ring lea /25/88 200% Loss of Normal Power event Personnel Maintenance /

and automatic trip due to Error Surveillance grounding a 4.16 KV emergency bus (LER 88-11-01). Allegations Millstone 1 There were no allegations specific to Millstone 1 during the assessment perio Millstone 2 Five (5) allegations specific to Millstone 2 were reviewed by the NRC during the assessment period. The NRC follow-up of the concerns resulted in one notice of violation, one notice of deviation, and four unresolved items. The open items concerned acceptance criteria checks on Heise pressure gauges, a needed TS amendment to clarify the definition of core alterations, and the disposition of job discrimination complaints by the Department of Labo One allegation (RI-88-A-0029) dealt with procedure compliance in the metrology laboratory. Procedure nonadherence was confirmed with no safety significance; no citation was issue RI-5

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A second allegation (RI-88-A-0040) encompassed a wide scope of concerns. The concerns were procedurai adequacy / implementation of the control room radiation monitors, reactor protection channel response, ex-core /in-core nuclear instru-mentation calibration, licensee handling of employee concerns, incore detector removal, reactor coolant pump oil leakage, and reactor trip breaker operatio NRC follow-up found no nuclear safety inadequacies. One open unresolved item involves the definition of core alterations and changes to TS requirements without prior NRC approva A third allegation (RI-88-0124) concerned motor-operated valve analysis and test system (MOVATS) procedural adherence, radiological controls, and potential job discrimination. The allegation was unsubstantiated. The licensee imple-mented minor procedural improvement A fourth allegation (RI-88-0003) concerned inadequate overtime controls during a refueling outage. The allegation was unsubstantiated. Documentation discre-pancies were noted in overtime paperwork incident to separate, NRC-initiated-inspectio The fifth allegation (RI-88-0015) dealt with health physics concerns in con-tainment during the refueling outage. The NRC found no safety significance and the allegation was unsubstantiate Three of the allegations (RI-88-0029, RI-88-0040, and RI-88-0003) were receiv-ing NRC special team review at the end of the assessment period. That review included previous and newly expressed concerns by the three allegers. These individuals, who are licensee employees, also alleged job discrimination and were referred to the Department of Labor for resolution of the alleged discriminatio Millstone Station There were four (4) allegations specific to site security, (RI-87-A-0137) con- q tractor activities (RI-87-A-0113), and a telephone conversation with a local citize RI-87-A-0113 allegation is still under NRC review, to specifically address a job discrimination settlement agreement. The remaining allegations I were previously reviewed and found to be unsubstantiate Management Conferences On January 27, 1988, the NRC and the licensee met in Bethesda, Maryland to dis-cuss resolution of the combined Senior Reactor Operator / Shift Technical Advisor ,

(SRO/STA) issu l l

On April 28, 1988, a meeting was held at the Millstone site to discuss the pre-vious SALP report finding On June 16, 1988, the licensee met with the NRC to discuss regulatory options for the Millstone I spent fuel pool rerack projec RI-6

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On July 8,1988, the licensee met with the NRC at the Region I office to pre- '

sent and discuss Northeast Utilities initiative On October 4, 1988, a meeting was held at the Region I office in reference to outstanding issues for the Millstone 2 and 3 Fire Protection program On November 10, 1988, an enforcement conference was held in the NRC Region I office to discuss environmental equipment qualification issue On November 15, 1988, the NRC and the licensee held a meeting to discuss the Millstone 1 Emergency Operating Procedures (EOPs).

On November 29, 1988, the licensee conducted a meeting in the NRC Region I of-fice to discuss Millstone 2 status and initiative On January 18, 1989, the licensee conducted a meeting in the NRC Region 1 of-fice to discuss the operator examination proces On March 16, 1989, the licensee conducted a meeting in the NRC Region I office to discuss Millstone I and 3 status and initiative On April 21, 1989, a meeting was held in the NRC headquarters office to discuss the need for a mid-cycle steam generator tube inspection during Cycle 10 opera-tion at Millstone On May 10, 1989, the licensee conducted a meeting in the NRC Region I office to discuss initiatives in responding to employee concern On June 21, 1989, an enforcement conference was held in the NRC Region I office >

to discuss the licensee's release of a contaminated hydrolysing rig used at I Millstone 1.

I Licensee Event Reports

,

G.1 Millstone 1 Licensee Event Reports l

G. Report Quality LERs adequately described the associated events in thorough and clear detai Narrative sections typically included specific event details such as valve l identification numbers, model numbers, and operable redundant systems, which enabled the reader to develop a good understanding of the event. Root causes were clearly identified and previous similar events were appropriately i reference An isolated weakness was noted in that, while supporting information was pre-sent, two Millstone 1 LERs (89-06, 89-13) did not explicitly assess the safety

! significance of the individual events in accordance with NRC NUREG-1022.

l l

RI-7

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i G. Causal Analyses Twenty-eight licensee event reports (LERs) and sixteen safeguards event reports (SERs) were submitted, spanning the entire range of causal areas. NRC review identified no recurring problems, and as the underlying causes seem random, Millstone 1 appears to adequately uncover and correct deficiencie ,

j Fifteen (15) LERs were classified as personnel errors. Within this group, one (89-15) resulted in a reactor scram and ten (10) were associated with station security. Two LERs addressed missed surveillance (88-02, 89-10).

Seven LERs addressed design error Three (88-04, 88-05, 89-03) illustrated positive licensee initiatives to critically examine and identify long-standing plant design deficiencies. The remaining four (88-13, 89-01, 89-12, 89-13)

represented licensee failures to conduct thorough initial design or installa-tion review Thirteen LERs addressed equipment failure Two engineered safety feature ac-tuations (88-06, 88-11), two unit shutdowns per Technical Specifications (88-08,89-14), and two reactor scrams (88-03, 89-05) were involve Five LERs addressed inadequate procedures. Two (89-08, 88-12) resulted in ESF actuations and one (89-02) was identified during the licensee sponsored Safety System Functional Inspection (SSFI).

G.2 Millstone 2 Licensee Event Reports G. Report Quality The LERs adequately described the major aspect of the event, including com-ponent or system failure that contributed to the event, and the significant corrective actions taken or planned to prevent recurrence. The reports were thorough, detailed, well written and easy to understand. The narrative sec-tions typically included specific detail of the event such as valve identi-fication numbers, model numbers, number of operable redundant systems, the date of completion of repairs, etc., to provide a good understanding of the even The root cause of the event was clearly identified in most case The LERs presented the event information in an organized pattern'with separate headings and specific information in each section that led to a clear under-standing of the event informatio G. Causal Analysis Eighteen (18) licensee event reports (LERs) and sixteen (16) safeguards event reports (SERs) were submitted, spanning the entire range of causal areas. NRC review identified no recurring problems and as the underlying causes were as-sessed as random, and Millstone 2 appears to adequately uncover and correct deficiencie RI-8

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Seventeen.(17) LERs were classified as personnel errors. Within this group, 1

- ten (10) were associated with station security. One (88-11-01) resulted in a

' loss of normal power (LNP) and a subsequent reactor tri '

Two (2) LERs addressed design errors. One(89-04-01) illustrated positive-lic-ensee actions to critically examine applicability and failures of SG mechanical tube plugs (a generic issue). -

Five (5) LERs addressed defective procedures. Three (88-03, 88-05, 89-05) re-suited in inadvertent ESF actuations, and a loss of normal power even Two (2) LERc addressed management / quality assurance as it related to root cause identification (88-08-01, 88-06-01).

Seven (7) LERs addressed equipment failures and informational LERs. One equip-ment failure (88-02) resulted in an LNP while shutdow .

RI-9 l

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REFERENCE INFORMATION~H!

TABLE 1 ,

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-l'

MILLSTONE 1 ENFORCEMENT / SEVERITY LEVEL -

AREA 1 2 3 .4 5 DEV Iotal Plant Operations-

-'

Radiological Controls Maintenance / Surveillance Emergency Preparedness Security ..

2**- 2

- Engineering / Technical Support .

1* 2 1* L4 Safety Asseesment/ Quality Verification

• Combined Millstone 1 and 2-Violations

• • Combined Millstone Station Violations

' Note: A Radiological-Controls Enforcement Conference was held; enforcement action-was not issued as of the end of the period.

M-1 T1-1

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. REFERENCE INFORMATION TABLE 2 MILLSTONE 1 INSPECTION HOURS SUMMARY Area Hours % of Time Plant Operations 1582 4 Radiological Controls 191 Maintenance / Surveillance 626 1 Emergency Preparedness 63 Security 145 Engineering / Technical Support 363 1 Safety Assessment / Quality Verification 440 1 Totals: 3410 100.0 l

M-1 T2-1

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- REFERENCE INFORMATION TABLE 3 MILLSTONE I LISTING OF LERs BY FUNCTIONAL AREA'

'

Area' A B' C D E X Totals Plant Operations 2 2 4 8 Radiological Controls

.:

Maintenance / Surveillance 2 1 7 10 Emergency Preparedness Security ** 10 1 2 3 16 Engineering / Technical Support 1 6 2 9 Safety Assessment / Quality Veri I 1 Totals: 15 7 1 5 13 3 44 Cause Codes *:

A Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause D - Defective Procedure E - Component Failure X.- Other 1 * Cause~ Codes in this table are based on inspector evaluation and may differ from those specified in the LE ** Security Event Reports are common to the Millstone station and are not specific either to Millstone 1 or Millstone M-1 T3-1

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. REFERENCE INFORMATION TABLE 4 L MILLSTONE 2 ENFORCEMENT SUMMARY / SEVERITY LEVEL DEV Total

'

AREA 1 2 3 4 5 .

Plant Operations 1- 1 Radiological Controls 1 1-Maintenance / Surveillance 2 1 3 Emergency Preparedness Security .

2** 2**

Engineering / Technical Suppor la - 1* 1* 3*

r Safety Assessment / Quality Verification __ __ __ __ __

Totals: 1 6 1 2 10

Combined Millstone 1 and 2 violations

• • Combined Millstone Station violations

, .

l- M-2 T4-1

I l

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i L.- REFERENCE'INFORMATION

'

m TABLE-5 MILLSTONE 2 INSPECTION HOURS SUMMARY i

l Area Hours'  %'of Time ,

Plant Operations- 1621 3 Radiological Controls 245 Maintenance / Surveillance 1061 25.2-Emergency Preparedness 89 Security 158 Engineering / Technical Support 284 ' Safety Assesstent/ Quality Verificatio .1 Totals: 4220, 10 I'

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Wie ** L

,

-, REFERENCE INFORMATION TABLE 6 MILLSTONE 2 LISTINGS OF LERs BY FUNCTIONAL' AREA Area A B D E X Totals Plant Operations 2 1- 3 Radiological Control . Maintenance / Surveillance 4 2 2 8 Emergency Preparedness Security ** 10 1 2 3 16 Engineering / Technical Support 1 2 l' 2 6 Sofety Assessment / Quality Veri I 1

'

Totals: 17 2 1 5 2 7 34 CAUSE CODES *

A - Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause

.D - Defective Procedure-E.- Management / Quality Assurance Deficiency

' X - Other (Equipment Failure)

• Cause Codes in this table are based on inspector evaluation and may differ from those specified in the LE ** Security event reports are common to the Millstone station and are not specific to either Millstone 1 or Millstone I i

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APPENDIX 1 SALP BOARD MEMBERSHIP AND ATTENDANCE

'SALP Board

' Chairyn: .

W. Kane, Director, Division of Reactor Projects (DRP)

Members:

M. Boyle, Millstone I Project Manager, PD I-4, NRR

• S. Collins, Deputy Director, DRP

*R. Gallo, Chief, Operations Branch, Division of. Reactor Safety (DRS)

P. Habighorst, Millstone 2 Resident Inspector

'

• J. Joyner, Division Project Manager, Divisicn of Radiation. Safety and Safeguards (DRSS)

L. Kolonauski, Reactor Eregineer, DRP

'*M. Knapp, Director, DRSS E. McCabe, Cl.ief, Reactor Projects Section 3B, DRP W. Raymond, Senior Resident Inspector, Millstone J. Stolz, Director, Project Directorate I-4,.NRR

• J.'Strosnider, Chief, Materials Processes Section, DRS G. Vissing, Millstone 2 Project Manager, PD I-4, NRR E. Wenzinger, Chief, Projects Branch No. 4, DRP Other Attendees:

• D. Haverkamp', Chief, Reactor. Projects Section 4A, DRP D. Jaffe, Millstone 3 Project Manager, PD I-4, NRR

' *R. Keimig, Chief, Safeguards Section, DRSS

• J. Kottan, Laboratory Specialist, DRSS

• Lazarus, Chief, Emergency Preparedness Section, DRSS

• R. Nimitz, Senior Radiation Specialist, DRSS

• W. Thomas, Radiation Specialist, DRSS A. Perez Rodriguez, Spanish Consejo de Seguridad Nuclear

• Part-time attendees

.

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