IR 05000245/1988200
| ML20154P313 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/23/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20154P316 | List: |
| References | |
| NUDOCS 8810030020 | |
| Download: ML20154P313 (8) | |
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UNITED STATES
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NUCLE AR REGULATORY COMMISSION g
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WA4HINGTON, D. C. 20555
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September 23, 1988
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Docket No. 50-245 Mr. Edward Senior Vice I resicent - Nucitar Enginu; ring a 4 Operations Croup
Northeast Nucle..
Energy Company P. O. Box 270 Hartford, Connecticut 06101-0270
Dear Mr. Mroczka:
SUBJECT:
EMERGENCY OPERATING PROCEDURES INSPECTION (INSPECTION REPORT 50-245/88200)
Re:
Millstone Nuclear Power Station, Unit No. 1 This letter forwards the results and conclusions of the special safety team inspection conducted by the NRC's Office of Nuclear Reactor Regulation of activities authorized by NRC Operating License No. DPR-21 for the Millstone huclear Power Station Unit 1.
The inspection was conducted on June 13 through June 30, !.EE At the conclusion of the inspection, the findings were discussed wid. Mr. Scace and other members of your staff identified in the enclosed inspection report.
The purpose of the inspection was to verify that your Emergency Operating Procedures (EOPs) are technically correct; that their specified actions can be meaningfully accomplished using existing equipment, controls, and instrumen-tation; and that the available procedures have the useability necessary to provide the operator with an effective accident mitigation tool. Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of proceouros and r'epresentative records, siniated emergency exercises using a plant specific simulator, plant walkdowns and interviews with personnel and observations of activities in progress.
Several weaknesses were identified in the development and implementation of the E0Ps. The inspection team identified significant deficiencies in the Primary l
Containment Control guicelines involving the incorrect calculation of pressure j
limits and nonconservative assumptions involving the use of plant specific
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equ'? ment, in addition, the team concluded that the E0P hard copy procedures had a very poor useability ano presented a significant potential fer operator confusion.
Pron.pt action appears warranted to upgradf. the E0Ps to correct the
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t+chnical inadequacies and provide the operators with an effective accident
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eitigation tool. However, the inspection team was impressed with t.be knowleoge inel of the plant staff relating to accomplishrru.t of the E0Ps and concluded
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that the operators could adequately perform the procedures in spite of the
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procecural inadequacies. A sumary of the inspection team's significant obser-vations are identified in the attached Executive Sumary. The attached inspec-tion report details the specific observations relating to the technical and human tactors issues identified in your E0Ps.
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8810030020 OGO923 PDR ADOCK 05000245 g!
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s Mr. Edward September 23, 1988 We have received your July 29, 1988 letter which provides preliminary responses to the issues raised during the inspection team exit meeting on June 30, 1988.
We have discussed with your staff our concerns regarding portions of ycur preliminary responses. Accordingly, we request that you formally transmit to the NRC your plans for corrective actions related to the enclosed inspection findings within 30 days of the receipt of this letter.
These corrective actions should specifically address each of the items identified in the attached Executive Sumary and reflect the significance of the human engineer-ing deficiencies identified in the E0Ps.
Some of the items identified by the team may be potential enforcement findings. Any enforcement actions will be identified by Region I in separate correspondence.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room.
The responses requested by this letter and its enclosures are not subject to
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the clearance procedures of the Office of Management and Budget as required by
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the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this inspection, please contact me or Mr. G A. VanDenburgh (301-492-0965).
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Sincerely,
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Gl Y
i Steven A. Varga, Director Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Enclosures:
1.. Executive Sumary
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2.
NRC Inspection Report 50-245/88200
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cc w/ enclosures: See next page i
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Mr. Edward September 23. 1988 cc w/ enclosures:
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Gerald Garfield, Esquire R. M. Kacich, Manager Day, Berry and Howard Generation Facilities Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President D. O. Nordquist Nuclear Operations Manager of Quality Assurance North?ast Utilities Service Company Northeast Nuclear Energy Company Post Difice Box 270 Post Office Box 270 Hartf9rd, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator, Region 1 Radiation Control Unit U. S. Nuclear Regulatory Commission Department of Environmental Protection 475 Allendale Road State Office Building King of Prussia, Pennsylvania 19406 Hartford, Connecticut 06106
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Bradford S. Chase, Under Secretary First Selectmen Energy Division Town of Waterford Office of Policy and Management Hall of Records 80 Washington Street 200 Boston Post Road Hartford, Connecticut 06106 Waterford, Connecticut 06385 i
S. E. Scace Station Superintendent W. J. Raymond, Resident Inspector Millstone Nuclear Power Station Millstone Nuclear Power Station Northeast Nuclear Energy Company c/o U. S. Nuclear Regulatory Commission Post Office Box 128 Post Office Box 811 Waterford, Connecticut 06385 Niantic, Connecticut 06357 J. P. Stetz, Unit Superintendent Institute of Nuclear Power Operations Millstone Unit No. 1 1100 Circle 75 Parkway
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Northeast Nuclear Energy Company Atlanta, Georgia 30339 i
Post Office Box 128 Waterford, Connecticut 06385 l
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Mr. Edward September 23, 1988 Distribution:
(w/ encl)
Docket File 50-245 DRIS R/F RSIB R/F PDR 1.PDR BEGritnes, NRR CJHaugney, NRR JEKonklin, NRR CVanDenburgh, NRR Inspection Team TMurley, NRR JSniezek, NRR BBoger, NRR JStolz, NRR RCapra, NRR CVogan, NRR MBoyle, NRR JCraig, NRR WRegan, NRR JPersinski, NRR BClayton, E00 EWeinzinger, RI PSwetland, RI WKane, RI EMcCabe, RI DFlorek, RI SRI. Millstone, RI ACRS (3)
OGC (3)
Regional Administrators Regional Div. Directors
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DATE
- 09/tt/88
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- 09/I/88
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t EXECUTIVE SUMMARY INSPECTION REPORT 50-245/88200
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MIt.LSTONE NUCLEAR ENERGY COMPANY Based on a review of the Emergency Operating Procedures (EOPs), the inspection team concluded that the E0Ps are essentially a technically accurate incorpor-ation of the BWR Owners' Group (BWROG) Emergency Procedure Guidelines (EPGs)
with the exception of the Primary Containment Control guidelines.
Several significant deviations involving the calculations and pin.nt specific equipment related to the Containment Control guidalines were identified which will require further licensee action to resolve.
Based on the deficiencies ider.tified during a review of the E0Ps and the plant walkdowns, the inadequacies in the Writer's Guide and the failure to implement the Writer's Guide following revision, inadequate validation and verific.ation i
of the E0Ps and associated operating procedures (ops), and missed action steps during the E0P simulation, the team concluded that the E0Ps and associated
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procedures had poor useability. The inspection team concluded that the opera-tors could implement the required actions of the E0Ps based upon the excellent operator training on the accident mitigation strategy of the EPGs and extensive operator experience. However, the hard copy E0Ps were considered to be an ineffective operating tool,
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i Although a specific Primary Containment vent path was identified, the inspec-tion team determined that engineering calculations were not aerformed to support this path and that errors in the calculation of the Primary Containment Pressure Limit allowed containment venting at a pressure lower than required.
Several significant concerns were identified which will require further licen-see action to resolve. The most significant concerns were:
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(1) The revised verification and validati)n procedures were not utilized to perform a complete review of the E0Ps and the operating procedures refer-
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enced by the E0Ps were never verified or validated.
In addition, the
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revised verification and validation prxedures were not submitted to the NRC by July 31, 1985, as committed.
(fection 3.1.1).
(2) The maintenance of the E0Ps and the Plan'. Specific Technical Guidelines (PSTGs) was not adequate in that:
a.
The licensee did not appropriately control and maintain the PSTGs up-to-date as a design basis document.
(Section 3.1.2).
b.
The licensee ha) not implemented a formal program for on-going review
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and upgrade of the E0Ps and the Quality Assurance organization was
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not involved in the development and maintenance of the PSTG, (Sec.tions 3.1.5 and 3.1.6).
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c.
The number of interim changes to the E0Ps and the methodology of these changes increased the complexity of the E0Ps.
Interim changes
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engineering guidance of the Writer's Guide.
(Section 3.1.3),
d.
Insufficient copies of the E0Ps wtre provided in the Contra) Room.
(Section3.1.4),
(3) The basis of the Primary Containment Control Guidelines of the E0Ps was deficient in that:
,a.
The licensee did not calculate the Primary Containment Pressure Limit in accordance with the guidance of Revision 2 of the EPGs. This significant deviation was not adequately evaluated and the E0Ps were
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not correctly revised to incorporate this deviation.
(Section 3.2.1.(1)).
b.
The licensee revised the original calculational assumptions of the Pressure Suppression Pressure Limit and the Primary Containment Design Pressure Limit without an appropriate evaluation of the effect on the limits.
In addition, the itcensee changed the calculation of the Minimum Number of SRVs Required for Emergency Depressurization without an evaluation.
(Section 3.2.3).
c.
The licensee did not effectively utilize plant specific instrumen-tation to implement the correct Primary Containment Water Level Limit. As a result, the licensee implemented an unrealistic limit for the maximum primary containment water level and modified the accident mitigation strategy of the EPGs without an adequate justiff-cation.
(Section3.2.1.(2)).
d.
Insufficient justification existed for the deletion of EPG Caution No. 23 concerning the operation of the suppression chamber vacuum breakers.
(Section 3.2.1 (3)).
(4) The human factors engineering of the E0Ps was deficient in that:
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a.
The inspection team identified numerous examples of inadequate implementation of the Writer's Guide because the licensee had cot implemented verification and validation procedures for E0P actions in operational procedures and had not fully implemented the procedures following revision.
(Section3.2.5),
b.
The Writer's Guide provided inadequate guidance concerning the use of operator information, step highlighting. E0P entry conditions, the fortnat of operator action steps and E0P identifying information.
(Section3.2.4).
(5) The procedural adequacy of the E0Ps was deficient in that:
a.
The inspection team identified three examples in which special tools or equipment were not provided to support the accomplishment of E0P actions. These examples included:
(1) missing safety equipment and inadequate hoses for venting of the Hydraulic Control Units as a methcd of alternate rod insertion. (2) missing special adapters for the conhection of the fire main as en alternate water injection
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method, and M) insufficient electrical jumpers for use in bypassing the MS!Y isolation logic.
(Section 3.3.2).
b.
The licensee had not administratively controlled operator tids to ensure that the aids were available, remained up-to-date and were not incorrectly revised or superseded.
(Section 3.3.3),
c.
Manually operated valves in the Essential Service Water System were potentially(not accessible because their access covers were corroded in place.
Section 3.3.4).
d.
Procedures were not provided for complex operator tasks such as jumpering of contacts and bypassing interlocks and isolation signals.
(Section3.3.1(1)).
e.
The operational procedures referenced by the E0Ps provided insuffi-cient information concerning the correct methodology for alternate boron injection.
(Section3.3.1.(2)).
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f.
The licensee had not evaluated the accessibility of the secondary
containment following a LOCA in the process of developing the E0Ps contingency actions.
(Section3.3.1.(3)).
g.
The inspection team identified numerous referencing errors between the E0Ps and supporting procedures and several examples of incorrect
or inadequate labeling.
(Sections 3.3.1(4)and3.3.1.(5)).
h.
The inspection team identified discrepancies with respect to the adequacy of control room instrumentation because a Detailed Control Room Design Review had not been compitted.
(Section 3.3.1.(6)).
I (6) Several deficiencies were noted during the E0P accident scenarios. These
included:
.f a.
The E0P simulation demonstrated that the shift manning described by the Technical Specifications was adequate to accomplish the required
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actions of the E0Ps, however the inspection team concluded that insufficient personnel were available to accomplish all the actions required in an emergency.
Specifically, effective implementation of the Emergency Plan or activation of the Fire Brigade coincidertil
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with implementation of the E0Ps could not be perfomed if only the
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minimum shift crew cescribed by Technical Specifications were available in the control room. The duties of the Shift Supervisor's Staff Assistant (SSSA) were essential to the satisfactory performance
of the E0Ps, however the SSSA was not included in all administrative procedures or in the Technical Specifications as a required member of
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the Minimum Shift Crew.
(Section 3.4.2.(5)).
b.
The control room responsibilities assumed by the operators for E0P
implementation differed from the method identified in the
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j administrative procedures.
(Section 3.4.2.(2)).
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The licensee failed to effectively train and implement a method for i
placekeeping during the performance of the E0Ps.
(Section 3.4.2.(1)).
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d.
The immediate operator actions required by the abnormal procedures in response to the loss of feedwater were more conservative than specified in the E0Ps because alternate high pressure feedwater systems were not available. This difference in the plant specific equipment was not addressed as a significant deviation from the EPGs.
(Section 3.4.2 (3)).
e.
The licensee incorporated the Secondary Containment Guidelines concerning depressurization of the reactor pressure vessel upon high secondary temperatures and radiition levels as an abnormal operating procedure differently than specified in Revision 3 of the EPGs without justification as a significant deviation.
(Section3.4.2.(4).
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