IR 05000245/1992099
| ML20059A202 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/18/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059A188 | List: |
| References | |
| 50-245-92-99-01, 50-245-92-99-1, 50-336-92-99, 50-423-92-99, NUDOCS 9310260254 | |
| Download: ML20059A202 (54) | |
Text
{{#Wiki_filter:- -. . . - . . . ENCLOSURE 1 FINAL SALP REPORT = U.S. NUCLEAR REGULATORY COMMISSION
REGION I
= SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE , REPORT NOS. 50-245/92-99 50-336/92-99 50-423/92-99 NORTIIEAST NUCLEAR ENERGY COMPANY MILLSTONE N'UCLEA'R POWER STATION UNITS 1,2, AND 3 ASSESSMENT PERIOD: , FEBRUARY 16,1992 - APRIL 3,1993 BOARD MEETING DATE: MAY 18,1993 l ! i
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. . TABLE OF CONTENTS Page I.
I NTR O D U CTIO N....................................... 1 II.
S UMM ARY OF RESULTS................................. 2 II. A O v ervie w........................................ 2 II.B Facility Performance Analysis Summary.................... 3 III.
PERFORMANCE ANA LYSIS............................... 4 III.A Plant Operations................................... 4 III.B Radiological Controls...............................
III.C Maintenance / Surveillance
............................ III.D Emergency Preparedness............................. 20 III.E Security and Safeguards
............................. III.F Engineering and Technical Support......................
Ill.G Safety Assessment / Quality Verification
........................ IV.
S ITE A CTI VITI ES..................................... 36 IV.A Licensee Activities .................................-36 IV.B Signincant NRC Activities............................
Attachment: SALP Evaluation Criteria, Performance Categories and Trends t .
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INTRODUCTION "le Systematic Assessment of' Licensee Performance (SALP) program is an integrated NRC .ff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facilities' performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on May 18, 1993, to review the observations and data on performance, and to assess licensee performance in accordance with the guidelines in NRC Manual Chapter NRC-0516, " Systematic Assessment of Licensee Performance," dated September 28,1990. The SALP Evaluation Criteria utilized by the Board are attached.
This report is a combined assessment for Millstone Units 1,2, and 3 for the 14 month period of February 16, 1992, through April 3,1993.
The Millstone SALP Board members were: CHAIRMAN: J. Wiggins, Acting Director, Division of Reactor Projects (DRP) MEMBERS: W. Hodges, Director, Division of Reactor Safety (DRS) S. Shankman, Deputy Director, Division of Radiation Safety and Safeguards (DRSS) A. Blough, Chief, Projects Branch No. 4, DRP P. Swetland, Senior Resident Inspector, Millstone
J. Stolz, Director, Project Directorate (PD) I-4, NRR D. Jaffe, Senior Project Manager, PD I-4, NRR (Combined Areas) J. Andersen, Project Manager, PD I-4, NRR (Millstone 1 Areas) G. Vissing, Senior Project Manager, PD I-4, NRR (Millstone 2 Areas) V. Rooney, Senior Project Manager, PD I-4, NRR (Millstone 3 Areas) OTHERS IN ATTENDANCE: D. Dempsey, Resident Inspector, Millstone Unit 2 R. Arrighi, Resident Inspector, Millstone Unit 3 R. Barkley, Project Engineer, Projects Branch 4, DRP C. Holden, NRR SALP Program Manager t
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II.
SUMMARY OF RESULTS II.A Overview During this SALP period, overall performance at Millstone Station improved only marginally from that achieved during the previous period. Each unit was operated soundly with appropriate attention to operational and outage safety principles.
Performance in the majority of SALP functional areas remained about the same during this period. The most noteworthy improvement was in the area of radiological controls which l was rated as a SALP Category 1. Excellent management support and involvement, , ' aggressive supervisory oversight and plarming, and strong training and qualification programs were effective in maintaining low overall exposures and very good control of contamination.
In response to the overall performance decline at Millstone during the 1990 - 1991 time frame, the licensee implemented a broad self assessment effort which later became the, Northeast Utilities Performance Enhancement Program (PEP). The PEP represents a substantial commitment by the licensee to address the observed decline in performance. The NRC determined that the PEP addresses the areas of concern identified to date. However, the current low degree of completion of PEP action plans has not yet yielded a significant performance improvement overall. The NRC did note a number of positive results in the areas of employee concerns and shutdown risk management, as well as, increases in resources and staffing to key departments. The comprehensive nature of and management commitment to the PEP leaves the licensee poised for overall performance improvement.
t Notwithstanding the PEP, continuing performance concerns remain at Millstone station. The licensed operator requalification training (LORT) program was found to be unsatisfactory at , Unit I for the second consecutive year. Some of the identified causal factors were also applicable to other training departments. This failure was indicative ofinadequate root cause analysis.and ineffective corrective action, as well as, a lack of corporate and site senior management attention to an identified performance problem. While the NRC noted that significant changes are ongoing in this area, the effectiveness of these measures remains to be determined.
in addition to the LORT program deficiencies, other long-standing performance problems remain, particularly in the areas of procedural adherence, event classification and reporting and corrective action effectiveness at all three units. As a result, the Self Assessment / Quality Verification functional area was rated a SALP Category 3. An improving trend in this area indicates the significant licensee effort devoted to the PEP initiative, and its significant potential to improve overall performance during the next SALP cycle.
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II.B Facility Performance Analysis Summary Rating, Trend Rating, Trend Functional Artu
- Last Period This Period **
1.
Plant Operations 2,2,2 2,2,2 2.
Radiological Controls 2, Improving
3.
Maintenance / Surveillance 2,2,2 2,2,2 , 4.
Emergency Preparedness
2 5.
Security
2 6.
Engineering / Technical Support
2 7.
Safety Assessment / Quality Verification
3, Improving
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- Previous Assessment Period: December 16,1990 - February 15, 1992
- Present Assessment Period: February 16,1992 - April 3,1993
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PERFORMANCE ANALYSIS Ill.A Plant Operations 'I III. A.1 Millstone Unit 1
III. A. I.a Analysis in the previous SALP, Unit 1 operation was rated category 2. Improvements were noted in
operator communications and response to off-normal plant conditions. Poor procedure adherence during routine evolutions early in the period contributed to several events. Self-
assessment activities failed to identify and prevent operator performance deficiencies which resulted in the NRC declaring the operator requalification program unsatisfactory.
Operator response to non-routine events continued to be good during this SALP cycle as evidenced by the following examples. The first example occurred when control board operators quickly restored the main condenser as a heat sink following a reactor trip caused by the inadvertent closure of a main steam isolation valve. A second example was when control room operators rapidly terminated an isolation condenser initiation following the inadvertent opening of the isolation condenser return valve during a surveillance test.
Routine plant activities were also conducted safely. For exampic, during a service water forced outage, thorough contingency plans were developed to ensure adequate core cooling i would be achieved if shutdown cooling were lost. Administrative controls that were more - stringent than plant technical specifications were used to ensure a diverse means of core cooling was available. Operators were knowledgeable of the contingency plans and the-l administrative requirements.
) Operator shift briefings and turnovers were good during this assessment period. Prior to assuming watch responsibilities, good walkdowns of control room panels and discussions concerning the status of on-going or planned activities between off-going and on-coming shift personnel occurred. Briefings conducted by the shift supervisor consistently communicated an accurate status of plant equipment and planned work activities to shift personnel. The staffing of the operations department was increased during this SALP cycle through the addition of numerous plant equipment operators. The arrival of the new personnel has reduced the workload on shift personnel.
The maintenance of system availability for safety-related equipment had not been well coordinated between Operations and other supporting organizations. Equipment taken out of service did not always have all scheduled maintenance performed prior to its return to service and retesting of equipment after completion of the maintenance activity was sometimes delayed. This unnecessarily atended the unavailability of safety-related equipment. To . . .-
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address this weakness, weekly work scheduling meetings were conducted. Following each meeting, weekly work schedules were published. Operators routinely utilized the work schedule list to determine the timing, scope, and plant conditions to be establirhed for efficient performance of all the work activities. Inspector observations indicate that, overall, this initiative has been successful.
The quality of procedures continued to improve as procedure format and content were revised. However, problems persisted especially with procedures not yet improved, as evidenced by a poorly formatted surveillance procedure which contributed to an inadvertent Engineered Safety Features (ESF) actuation during testing of the isolation condenser.
Additionally, the NRC noted during another surveillance test that an operator was unsure of what action should be taken when the prerequisites for equipment startup could not be met, because the procedure lacked adequate guidance.
Rigorous procedural adherence was not always evident in the performance of routine activities. Procedure adherence was an area of concern noted in the previous SALP.
Weaknesses in procedural adherence caused a reactor trip and inadvertent ESF actuation during surveillance testing. Additionally, during an NRC examination, the isolation condenser was not operated in accordance with the Emergency Operating Procedures. Also, poor overall performance on Job Performance Measures during the requalification examination was caused by operators not following procedures. A licensee-identified problem was noted with Plant Equipment Operators (PEO) not completing inspections and monitoring required by procedure. These problems indicated that management has not assured strong adherence to procedures at the unit.
During the last SALP period, to improve the performance of operators during routine station activities, the licensee committed to the development of an operator self-checking program.
However, this corrective action was not implemented in a timely manner and performance errors continued. Similar performance errors continued this SALP period. At the close of the assessment period, a self-verification program still had not been formally implemented.
Housekeeping continued to improve during this SALP cycle. Few transient items left over from work activitic were noted in plant areas, and designated storage areas were routinely used. Few fire protectica deficiencies requiring compensatory fire watches existed for extended periods. This indicated that the licensee maintains appropriate attention to the fire protection program and the control / storage of transient combustible material. Painting of reactor building areas has noticeably improved the appearance of plant structures and components.
A licensed operator requalification examination conducted in September 1992, resulted in a determination that the training program was unsatisfactory for the second straight year. Ten of fifteen operators passed all portions of the examination. NRC identified three > programmatic weaknesses: (1) the licensee failed to substantially correct or enhance the overall level of operator proficiency since the 1991 NRC requalification examinations; (2) individual operator performance on all parts of the examination was poor; and (3) the Unit 1 written examination banks were weak evaluation tools. Substantial NRC comment ,
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and review were needed for the examination materials to be brought up to an acceptable level. In addition, NRC review of the operator requalification programs failures found weaknesses in the management attention to, and corrective action effectiveness for these programs. These issues are further detailed in section III.G of this assessment.
NRC requalification retake examinations were given March, November, and December of 1992, and in February and March of 1993. A total of 19 licensed operators were reexamined. Operator performance on these examinations was satisfactory. One individual.
failed, but was subsequently remediated and retested satisfactorily. Corrective actions to address the current program failure were developed and included the development of a special project management team and the use of advanced teaching and evaluation techniques to improve operator knowledge levels and capabilities. The effectiveness of those corrective actions will be assessed in the future.
The requalification examination results indicated that some licensed operators did not maintain acceptable knowledge of systems and integrated operations. A lack of operator proficiency was also evident during day-to-day plant operations. For example, on two occasions, operators did not recognize that equipment which was required by plant technical specifica' ions to be operable was out of service.
In summary, routine operations were conducted safely and actual plant transients were handled properly. Equipment availability was improved by better control of equipment out of service time. There were continuing weaknesses observed in adherence to procedures and operator proficiency evidenced by the second consecutive unsatisfactory operator requalification program evaluation. However, the training program weaknesses have not yet been manifested in degraded plant operations.
, I. A. I.b Performance Rating: Category 2 . III. A. l.c Board Recommendation: None III.A.2 Millstone Unit 2 III. A.2.a Analysis f The previous SALP rated operations as Category 2. With some exceptions, performance in the conduct of operations was strong due to an experienced and knowledgeable staff and' good management involvement in operations activities. Some improvement was noted in communications and reduction of personnel errors, but the need for continued management attention to these issues was identified.
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Experienced and knowledgeable operators contributed to safe operation of Unit 2 during power operations and the extended steam generator replacement outage. Operator performance during normal and special operations was good. Alert watchstanding resulted in early identification and correction of erroneous reactor vessel level indication during reactor vessel drain down, prompt restoration of shutdown cooling and spent fuel pool cooling when a reactor building closed cooling water pump tripped on low suction pressure, and recovery of feedwater regulating system control when a feedwater regulating valve was shut inadvertently. However, certain events occurred which indicate opportunities for further improvement exist. Two automatic reactor trips occurred during minor plant transients when operators were unable to maintain steam generator level with the feedwater regulating system
in manual, indicating a need for more effective training in the area of manual steam generator water level control. Configuration control weaknesses and an unnecessary sense of urgency to restore spent fuel pool cooling during a partial loss of normal power event contributed to the inadvertent partial drain down of the spent fuel pool to the containment refuel cavity. Also, not aggressively addressing questionable local position indication for a high pressure coolant injection system throttle valve resulted ultimately in rendering both , safety trains inoperable for a short period of time. This indicated a need for more critical assessment of component operability during routine operations.
A professional environment was maintained in the control room. Turnover brienngs by the shift supervisor and work control center supervisor effectively communicated information regarding plant conditions and current and planned evolutions to all shift crew members.
Pre-evolution briefings also were conducted routinely with good interaction among shift personnel. The briefings contributed to successful completion of complicated evolutions such as post-modi 6 cation testing of the engineered safety features actuation system and testing of the new steam genemtors. An additional senior control operator was assigned to each shift to provide experienced supervision of field activities. During the refueling outage, written guidelines for shutdown risk reduction were used. Safety function assessments were performed every shift and reviewed by management. Also, management involvement in reduced inventory operations was good. These initiatives made a positive contribution to safety during the steam generator replacement outage.
A licensee investigation of inaccurate plant equipment operator rounds logs revealed that Unit 2 had the greatest number of operators at Millstone Station who missed inspection rounds and was the only unit in which licensed operators were involved. Management expectations regarding integrity in signing for logged rounds were neither communicated effectively in guidance documents and procedures nor monitored and reinforced in the field by first line supervisors and managers. The licensee's corrective actions to improve the communication of management expectations regarding watchstanding have been effective.
, The work control center supported operations through participation in daily planning meetings and by reducing the administrative burden on the operating shift crew. In addition, operations personnel made a significant contribution to reduction of risk during daily outage planning meetings. However, lapses in adherence to administrative procedure requirements by work control center personnel contributed to a partial loss of normal power event and Gooding of a feedwater heater while maintenance personnel were working inside.
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Procedure adherence was adequate, but lapses attributable to inattention to detail or lack of self-verification continued to occur such as: an unplanned reactor coolant system cooldown occurred when operators missed a procedure caution concerning feed regulating bypass valve response to a turbine trip; the technical specification limit on reactor coolant system cold leg temperature was exceeded twice due to inadvertent boron dilution when purging hydrogen gas from the volume control tank; and, technical specification action statements were not entered for inoperable main steam line radiation monitors and accident monitoring system instrumentation. Also, there were instances noted of insufficient sensitivity to operability requirements for support systems not directly identified in technical specifications and for ' reactor protection system requirements in Mode 3.
Ongoing efforts to improve procedure quality were evident, but several operational occurrences indicated a need for better procedure reviews and more critical self-assessment of the conduct of operations. For example, lack of specific restoration guidance following depressurization of safety injection tanks resulted in starting a reactor vessel drain down to reduced inventory with two of four level indicators inoperable.
Successful completion of licensed operator requalification examinations administered by the NRC was attributed to a generally effective training program. Strengths were noted in crew teamwork and communications, use of emergency operating procedures, and knowledge of integrated systems. However, weaknesses were identified regarding the practice of differentiating training for active versus inactive personnel and regarding attendance at requalification training.
Housekeeping was acceptable; however, examples of defective lighting, inadequate storage of transient material, and poor equipment preservation persisted indicating that management involvement in this area was not wholly effective. At the end of the SALP period, a new program to upgrade material conditions in the unit was being developed, indicating that housekeeping would be receiving additional emphasis. Combustible materials were adequately controlled during normal operations. Fire protection structures and equipment were generally well maintained. During the outage, however, repeated incidents of contractor failure to follow procedures resulted in a number of small fires in the containment.
These incidents indicated a weakness in management oversight of contractor activities.
. In summary, an experienced and knowledgeable staff maintained a professional environment in the control room and generally showed good adherence to procedures. However, several
' events occurred during the SALP period, indicating a need for more critical self-assessment of operating practices and procedure content. A need for more training on plant transients that could perturb the feedwater regulating system was identified. Occasional lapses in configuration control were observed, in part, as a result ofinadequate control of work . activities. The operator requalification program performance was good.
III. A.2.b Performance Rating: 2 Ill.A.2.c Board Recommendation: None
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III. A.3 Millstone Unit 3 III. A.3.a Analysis Plant operations was rated a Category 2 in the previous SALP period. Strengths were noted in operator performance during routine plant activities and transient events, and in the cperator requalification program. The failure to use procedures appropriately continued to detract from good overall performance. A limited discussion of events during daily management meetings inhibited the self-recognition of degrading performance trends.
. f During this period, reactor operator professionalism, their conduct of control room operations, and their response to off-normal plant conditions and transients were very good.
Operators averted an unnecessary plant trip by promptly and effectively acting to mitigate the effects of the loss of a feedwater pump. They also successfully met the challenges presented during a loss of steam generator level event complicated by a stuck open steam generator safety valve and failure of the auxiliary boilers to start. Strengths included maintaining proper plant systems configuration, good communications within the department, and thorough shift turnovers. A good approach to safety was displayed by the shift supervisors , in their response to plant equipment problems and in the application of technical specification , ' requirements. A notable exception involved the inadequate response to the initial identification of an open ventilation duct access door on the auxiliary building filtration system (ABFS). Further, operators displayed a lack of questioning attitude with respect to ABFS system surveillance alignment, which was different from the normal system line-up.
Housekeeping was improved during this SALP period and noted to be very good. The fire protection program was generally well implemented and determined to be consistent with the conditions described in the fire hazards analysis. Improvement was also noted in the control of transient combustible materials.
The operations work control center was effective and lessened distractions to the operating - crew. A shift supervisor and a senior licensed operator were taken off shift to lead a dedicated team performing work control and coordination. Daily management meetings were-l effective in planning operating activities. The status of out-of-service equipment, ) unnecessarily illuminated annunciators, fire watch issues, and plant incident reports were i discussed at these meetings. Notwithstanding this management attention, some of these backlogged corrective actions were not resolved promptly. Several administrative controls-j designed to assure timely followup in these areas were also not properly implemented.
. Good planning was evident and inter-department activities were well-coordinated, However, one notable exception occurred when a hydrogen recombiner was rendered inoperable for approximately 90 days due to inadequate communications of actual work performed or proper - retest verification. Operations personnel demonstrated a sensitivity to shutdown risk management issues which included imposing safety system operability requirements more - stringent than technical specifications during maintenance outages.
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Generally, operating procedures were of good quality. One exception involved the procedure changes made in response to modifications of the auxiliary building filtration (ABF) system.
Several technical, administrative, and human factors deficiencies were noted in the operating - procedure following changes implemented when the ABF system was modified. Weaknesses were noted in configuration control and inattention to detail during the earlier part of the assessment period. However, increased management emphasis toward attention to detail resulted in a decrease in the number of operator errors and an improvement in operator performance and morale. Further, an operating self-checking program was developed during the latter part of the assessment period as part of a continuing effort to improve operations department performance.
Licensed operators demonstrated a high level of proficiency during NRC-administered requalification examinations and the operator requalification program was rated satisfactory during this assessment period. Procedural adherence was good. Operator team skills during , the simulator examinations were excellent. Training department and operations management involvement contributed to the operators' high level of proficiency and also ensured the evaluations were conducted thoroughly. Plant management involvement in the training process contributed to generally effective administration of the licensed operator initial and requalification programs, although the failure to conduct audits of the licensed operator requalification training program (as well as at Units 1 and 2) indicated a weakness in upper management's attention and oversight. In addition, some licensee checks of the quality of the written requalification exams were not made adequately.
In summary, good performance was observed as operators successfully met the challenges presented by routine operations, transients, and forced outages. Weaknesses were noted in configuration control and attention to detail, although improved performance in these areas was noted later in the assessment period. The operator requalification program was rated satisfactory with procedure adherence and team skills during the simulator examinations noted to be very good. Plant management's involvement in the requalification program and commitment to operator attention to detail was excellent. However, that same level of involvement was not seen with regard to the timely completion of backlogged corrective actions.
III. A.3.b Performance Rating: 2 III. A.3.c Board Recommendation: None P i , , , ..,.. ...
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, III.B Radiological Controls III.B.1 Analysis The previous SALP provided a combined rating of Category 2, Improving, for Radiological Controls at Millstone Units 1, 2, and 3 and noted that overall, a good radiological controls , program was implemented. The previous SALP also noted that there was a very good level of management involvement, control, and support of the program, and resolution of technical matters was good, but repetitive weaknesses in the control of contamination resulted in the unplanned exposure of personnel to airborne radioactivity and the release of contaminated , material from the radiologically controlled area. Strengths noted during the previous SALP were performance of the radiological environmental monitoring program (REMP) and monitoring and control of effluents, including efforts to maintain the process / effluent radiation monitoring systems. An effective radwaste packaging and transportation program w r, implemented.
Dunng the current period, management continued to maintain a very good level of , involvement and control of the radiological controls program. All vacant positions within the , radiological controls organization were filled in a timely manner; the radiation protection staff was augmented, as appropriate, with trained personnel to support work activities; new technical support organizations were established and staffed within the on-site radiological , controls group; and the licensee continued to phase out contractors by creating and filling permanent radiation protection technician positions. The enhanced organization was
appropriately defined, including identification of personnel responsibilities. Technical expertise was good. Overall supervisory oversight of on-going activities was considered - improved and generally very good throughout the assessment period.
During the current period, the licensee replaced the steam generators at Unit 2. The replacement effort was a significant challenge to the licensee. Planning, preparation, and execution of the replacement effort were excellent overall from a radiological controls standpoint. All appropriate involved individuals received training, including mock-up training; ALARA goals for the task. were appropriate; appropriate radiological controls (both external and internal) were provided for the activities; aggressive monitoring of on-going activities from an.ALARA and radiation protection standpoint was provided; and very good reviews of emergent work associated with the replacement efforts were noted. Similar good performance in work planning, preparation and execution continued at U' nits 1 and 3.
There were no external or internal exposures in excess of applicable limits at Millstone station during the assessment period. The overall exposure controls program was considered , strong, consistent at each of the units, and ofimproved quality. A comprehensive procedure rewrite effort was implemented to improve the quality of station radiation protection procedures. In addition, procedures to support implementation of the revised 10 CFR Part 20 (effective January 1,1994), were being aggressively developed, -- , . - . _. . - _ _ - . -, -,
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There were several NRC identified proble.ms and weaknesses at Unit 2. Evaluation of the. items separately, indicated they were of minor safety significance; however, when examined i in the aggregate, they indicated some need for enhanced attention to detail, relative to procedure adherence, by the radiation protection organization. Examples included a problem
involving lack of an adequate evaluation of radiological conditions prior to traversing the partially flooded Unit 2 reactor cavity, lack of completion of sign-offs of audits of High Radiatien Area access point key inventories, and lack of collection of a radiation work permit specified air sample when working in the Unit 2 cask wash pit.
The control of radioactive material and contamination, a previous concern, was considered , very good during the period. The contamination control enhancement program was effectively implemented. For example, all outside RCA areas were fenced in and the station policies were finalized regarding selection of lower limits of detection (L'.Ds) for analysis of various waste material to be released. One problem regarding the licensee's identification of ' a contaminated gauge located within a warehouse situated within the protected area was aggressively addressed. The licensee's evaluation concluded that the gauge was old and had been in the warehouse for an extended period of time, well before enhancement of the ' contamination control program.
I The overall radiation protection training programs were excellent and contributed to a good understanding of procedures, with few personnel errors noted. The licensee's training group was considered innovative and provided very good training to support activities. A Training Program Control Committee provided consistent overview of training activities. A problem involving distribution for use by personnel of a new type of respirator (powered air purifier)
without providing appropriate personnel training was NRC identified, but quickly corrected.
The licensee developed and implemented an improved training program for personnel who used survey meters, a previous problem. Very good communications between the training > group and the radiation protection group on training needs continued this period.
The audit and assessment program was considered ofimproved quality relative to the previous period. Two previous weaknesses, lack of a detailed plan to provide for audits of i radiation protection program sub-elements and audits of radiation protection supervisory and management personnel, were well addressed. Audits and assessments by corporate audit personnel were of improved quality. In addition, radiation protection performance summary j documents continued to be provided to management on a frequent basis. Overall, management had in place a very good self-identification program. Supplemental audits were requested by radiation protection management of areas indicating an apparent need for ] enhanced review. 12stly, the licensee was aggressively coordinating efforts to ensure proper j implementation of the program audit requirements outlined in the revised 10 CFR Part 20.
The corporate radiological controls organization as well as the on site QA and radiation i protection groups were effectively coordinating audit plans.
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The ALARA program continuea to be a strength at Millstone station. Three-year average (1990,1991,1992) accumulated radiation exposure values at Units 1 and 3 continued to be among the lowest in the industry. Exposure reduction initiatives continued to be implemented at each of the three units. For example, use of flange shields, water shields, and implementation of the use of depleted zine injection (Unit 1) reflected very good licensee efforts to reduce exposure to ALARA values. Although aggregate personnel radiation exposure at Unit 2 was above industry averages, this was attributed to frequent steam generator maintenance activities. The licensee's replacement generators were designed with innovative features to reduce exposure during maintenance activities; radiation exposure incurred during the replacement of the steam generators was only slightly above the ambitious goal established and was attributable to emergent work.
. A very good radioactive waste packaging and transportation program was implemented with a generally very good level of quality assurance of the radwaste packaging and transportation , activities evident. The training program for personnel involved with these activities was a notable strength. Radioactive waste was properly stored and labeled at the station with ALARA dose reduction principles in mind. The overall program for handling, storage, ' posting and labeling, and transportation of radioactive material was very good. An isolated problem involving determination of curie loading of Unit 2 resin shipments was NRC-identified and being evaluated by the licensee at the end of the period.
The licensee continued to maintain and implement a highly effective program for radioactive , liquid and gaseous effluent controls. A noted strength in the effluent control area was the knowledge of the responsible individuals involved with 1) effluent controls, 2) radiation monitoring systems, 3) effluent release quantification,4) protection of the public health and safety, and 5) the offsite dose calculation manual. Air cleaning systems were tested and maintained. Quality Assurance (QA) audits of the effluent control programs were thorough and of excellent technical depth. Overall, the programs exceeded regulatory requirements.
The licensee continued to maintain an effective Radiological Environmental Monitoring Program (REMP) and had a good QA/QC program to validate tne analytical measurement results of the contractor laboratory for various REMP sample media. The licensee had an excellent meteorological monitoring program in place and had performed a thorough audit of this program. The licensee uses the Nuclear Review Board (NRB) to perform audits of the REMP. The NRB Audit of the REMP only assessed the implementation of the Quality Control portion of the REMP during this assessment period and that audit lacked technical j depth and scope to fully assess the REMP. Overall the licensee implemented a very good REMP ed exceeded regulatory requirements.
b ssp, the licensee implemented overall a very good radiological controls program at all three units, with particularly commendable efforts during the Unit 2 steam generator replacement project; however, some need for enhanced attention to detail, regarding , procedure compliance, was noted. There was a very good level of management involvement and control of the program. Management was supportive of new initiatives, and identified problems were properly evaluated and resolved in timely manner. The overall resolution of technical matters was very good. The training and qualification programs were very good I .
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overall, staffing levels provided good support of program activities, and efforts to enhance - on-site organization's technical capabilities were very good initiatives. The licensee continued to implement a very good radwaste packaging and transportation program.
Excellent performance in the REMP and effluent areas also continued as did the efforts to maintain the process / effluent radiation monitoring systems.
Ill.B.2 Performance Rating: 1 III.B.3 Board Recommendation: None III.C Maintenance / Surveillance III.C.1 Millstone Unit 1 ' Ill.C.1 a Analysis The previous rating for this functional area was category 2. The skill, experience and tnining of licensee personnel was considered to be a licensee strength. Maintenance and surveillance programs generally were effective in assuring safe and reliable plant operation; however, a decline in performance was evident. Management was not sufficiently aggressive in identifying and correcting deficiencies before problems developed. Program and procedure weaknesses contributed to the degradation of safety-related equipment.
Overall, the performance of the maintenance department was good. No reactor trips or significant events were caused by personnel error in the maintenance or instrumentation and controls department. This good performance could be attributed to a well trained and experienced staff. The backlog of open work items and equipment rework was low. Staffing of the maintenance and instrumentation and controls departments appeared adequate to meet station requirements. Installation and testing of the modification to the reactor vessel wide range level indicating system was very good. The appearance of the plant continues to be upgraded through an aggressive painting program. Troubleshooting activities were well conducted which reduced equipment out of service time on technical specification required equipment. During troubleshooting operations, activities were properly controlled and personnel were knowledgeable of the systems that they were examining.
The lack of comprehensive preventive maintenance programs continued to cause equipment problems during this SALP period. Examples included the failures of auxiliary contacts in 480 volt motor control centers and 4.16 kV circuit breakers during surveillance testing.
Equipment environmental enclosure barriers were also noted to have deteriorated over time.
Additionally, degradation in the service water and emergency service water system tee -
connections was not detected until the piping in those systems was thinned below acceptable Code limits. These deficiencies indicate that the licensee has not effectively self-assessed whether present maintenance practices assure component operability based upon prior maintenance history.
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Planning of significant work activities improved. Examples included the coordination of work activities in the feedwater heater bay during planned down-power evolutions and the timely _ repair of a degraded service water pipe and exhaust manifold on the diesel generator.
However, weaknesses remained in assessing overall work scope prior to commencement of work activities. For example, complete inspection of a gas turbine coupling was not possible during another maintenance activity since the appropriate procedures had not been written to allow gas turbine rotation when the coupling was in a disassembled condition.
Procedural adherence improved but weaknesses still remamed during surveillance testing.
' For example, valves in the Low Pressure Coolant Injection system were cycled during a surveillance test before operators weie at the desired station. In another surveillance, instrumentation and control technicians commenced testing the isolation condenser before all work order prerequisites were satisfied. Surveillance tests were routinely performed on schedule which indicated good management oversight. The visibility of surveillance ' programs such as inservice testing (IST) increased by listing the status of components in the IST program in the daily plant status log.
Procedural detail and format changes that were conducted under the first phase of the procedure upgrade process improved the quality of mamtenance/ surveillance procedures; however, weaknesses remain. For example, the gas turbine surveillance test procedure specified a desired band for parameters with no guidance to follow if a parameter was , outside the band. Also, a deficient maintenance procedure allowed an Emergency Service Water strainer to be installed and later declared operable without having an adequate amount of oil in the rotating element assembly.
The licensee showed initiative in upgrading its inservice inspection (ISI) program data management system. The new system will enhance the licensee's control over its ISI vendor's activities and should strengthen the program by providing a means of assuring that correct procedures and equipment are used by properly qualified examiners during the performance of inservice inspection activities. Licenser actions in response to concems associated with non destructive examination (NDE) training, data, and procedures were decisive and extensive. Training of vendor personnel was revamped as were NDE procedures and associated data sheets.
In summary, procedural adherence improved in the maintenance / surveillance areas but further improvement was still required. The licensee's preventive maintenance programs for some safety-related equipment did not adequately detect / prevent the degradation which caused failures in this equipment. The licensee continued to improve the ISI program. No reactor trips or plant transients were caused by personnel in the maintenance or instrumentation and controls departments during the performance of maintenance / surveillance activities.
Ill.C. I.b Performance Rating: Category 2 III.C. I.c Board Recommendation: None ,
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i III.C.2 Millstone Unit 2 l III.C.2.a Analysis Unit 2 performance was rated previously as Category 2. Program strengths were noted in planning and work prioritization as evidenced by a low maintenance backlog, and in coordination of preventive maintenance and surveillance testing. An improving trend in procedure content was identified. Weaknesses were noted in adherence to administrative , requirements and procedures, and in attention to detail in the performance of maintenance and surveillance activities. Corrective action programs were not entirely effective in preventing repetition of performance errors.
Maintenance and surveillance programs were staffed with motivated and skilled personnel and training continued to be a licensee strength. Staffing levels were adequate to meet challenges posed by planned and forced outages. Plant staff significantly contributed to the successful replacement of the steam generators during the refueling outage. A generally well-managed program maintained a !ow maintenance backlog.
Effective planning and preparation for routine maintenance and surveillance activities were facilitated by twice-daily planning meetings attended by department managers and supervis~ rs. In the meetings, management emphasized coordination of corrective and o preventive maintenance, and surveillance to maximize the availability of safety-related equipment. Two instances of late performance of surveillance tests occurred, but were attributed to administrative error rather than to programmatic weakness. Administrative controls for tracking allowed outage times for equipment undergoing surveillance testing were applied inconsistently.
Unit 2 completed an extended steam generator replacement / refueling outage during the SALP period. The replacement project was well-controlled and organized with strong management involvement. Plant staff representatives facilitated coordination with other outage activities.
Extensive use of mockup training and automated welding techniques effectively reduced rework. Daily plant planning and status meetings fostered good interdepartmental communication. Management reacted well to emergent problems. The outage organization generally maintained positive control of maintenance and surveillance activities and effectively used an enhanced heatup check list as a configuration control tool to assure proper scheduling and performance of technical specification and special testing evolutions.
However, coordination during planning meetings was informal and an integrated schedule to coordinate maintenance, retest, system valve lineups, and surveillance testing was lacking, ' and successful performance relied heavily on the skill and experience of individuals rather ' than on ' programmatic strength. A notable lapse in work control performance resulted in a partial loss of normal power during the outage. The partial loss of normal power was attributed to failure to correctly implement a vital inverter replacement plan and to a design weakness.
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, A decrease in plant incidents attributed to procedure quality indicated that licensee personnel ' were more attentive to the need to change procedures before use. However, technical errors and lack of detail in procedures continued to be a factor in maintenance and surveillance performance deficiencies. Examples included failure of a hydrogen purge system valve local leak rate test and failure to verify ventilation system boundary integrity after maintenance. A plant transient which ultimately resulted in an automatic reactor trip occurred when a steam generator atmospheric dump valve failed open. The failure was attributed to misalignment of the valv'e positioner feedback mechanism during installation.
Two automatic reactor protection system actuations which occurred late in the SALP period were caused by inattention to detail and failure to follow surveillance procedures. Instances ' persisted of failure to comply with administrative procedures involving safety tagouts, ! component retest requirements, and documentation of changes in work scope. Increasing performance deficiencies caused by failure to follow procedures and lack of self-verification and self-checking were identified by licensee programs and NRC inspections. These adverse findings continued despite a significant management emphasis and work observation initiative. This indicated that corrective action programs for these concerns were not entirely effective.
Inservice inspection and testing programs were well-organized and completed on schedule.
Baseline eddy current testing of all new steam generator tubes was accomplished prior to installation, and an additional 20% of the tubes were inspected after steam generator
installation to verify that no damage had occurred. With one exception involving post-maintenance testing of power-operated relief valves, coordination of inservice testing program requirements with the operations staff was very good. The safety-related snubber reduction program received adequate management support. The maintenance organization made a significant contribution to the licensee's motor-operated valve program. Successful completion of an integrated containment leak rate test indicated good isolation valve maintenance practices.
Several initiatives contributed to safe operation of Unit 2, including a good emergency diesel , generator reliability program and a surveillance program for molded case circuit breakers.
Replacement of the "A" diesel generator governor system addressed a load oscillation , concern identified in the last SALP report. Extensive replacement of carbon steel service water and turbine-to-feedwater heater piping significantly contributed to plant safety.
Increased surveillance testing of safety injection system check valves and DC switchgear ventilation systems resulted in a 50% reduction in estimated core damage risk for Unit 2.
Management exhibited a safety-conscious approach to technical and safety issues by - scheduling high risk activities to minimize shutdown risk. Response to engineered safety feature actuation system deficiencies identified after a partial loss of normal power event was comprehensive. Root cause evaluations were good, as indicated by self-identification and correction of maintenance program deficiencies involving safety-related ventilation system components. However, the need for management to focus attention more fully on incidents caused by personnel error was identified.
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In summary, maintenance and surveillance programs adequately staffed with skilled and well-trained personnel continued to be a strength. Good coordination of routine activities was facilitated through frequent staff meetings. Control of maintenance and surveillance activities ' during the steam generator replacement / refueling outage was good, but relied heavily on the quality and experience of personnel rather than on a formal integrated program. A reduction in the number of incidents caused by procedure quality indicated a more questioning attitude
by personnel, but inadequate procedures continued to cause problems. Instances of inattention to detail and failure to follow procedures indicated that corrective action programs were not entirely effective. Plant management supported several initiatives which contributed to plant safety.
, III.C.2.b Performance Rating: Category 2 l III.C.2.c Board Recommendation: None Ill.C.3 Millstone Unit 3 III.C.3.a Analysis The Unit 3 maintenance and surveillance area was rated a Category 2 during the previous assessment period. Strengths were noted in the quality of maintenance activities and management supervision. There were noted improvements in procedure quality and , adherence. Weaknesses were identified in the corrective action program as evidenced by ) repetitive equipment failures.
j ' The quality of routine maintenance and surveillance during this assessment period was good.
Personnel were knowledgeable of their job tasks and worked within the job scope. However, exceptions to generally good procedure adherence were noted; one resulted in damage to the motor driven feedwater pump. To improve procedure adherence, the licensee implemented a work observation program to evaluate and reinforce work practice expectations. The increased oversight indicated that the licensee was attempting to improve performance in the . area of procedural adherence and, while initially successful, some procedure adherence problems persisted. Maintenance procedures were effective in preventing repetitive equipment problems. In an attempt to ininimize the time that components were out of service, work orders which affect technical specification components were conspicuously marked to indicate the need for increased awareness.
i Notwithstanding the efforts of the procedure upgrade program, there were a number of examples of inadequate maintenance and surveillance procedures, one of which resulted in a feedwater injection signal. These procedural deficiencies resulted from either technical errors or lack of detail. In addition, surveillance testing of the supplemental leak collection and release system (SLCRS) was inadequate in that it did not detect system degradation. A good questioning attitude by the departments was evident by the number of required procedural changes identified during performance of surveillance activities. There was a .- ,
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noted in' crease in the number of personnel errors and procedure deficiencies reported in licensee event reports. There continued to be numerous overlap testing deficiencies for the testing of protection system components which demonstrated a narrowly focused corrective action program for previously identified problems in this area.
Maintenance and instrumentation and control department management and supervisory oversight and involvement were evident and strong. The work control process was generally well implemented and communications between personnel and departments were effective.
Notwithstanding the good performance, the hydrogen recombiner was rendered inoperable for approximately 90 days due to inadequate work control. Poor work control also resulted , in a SLCRS boundary breach due to inadequate work planning and the installation of the wrong gasket material in the pressurizer power operated relief valves.
The backlog of open work items was low and the amount of maintenance rework was small.
There were no reactor trips caused by inadequately performed maintenance or surveillance procedures; this demonstrated continued good performance in this area. Surveillances during this period were generally performed on schedule; however, there were numerous requests for technical specification relief from the scheduled 18 month surveillance due to the failure of licensee personnel to identify all the implications of the extended operating cycle.
The licensee began an initiative to upgrade its ISI program data management system. The new system is intended to enhance the plant's control over its ISI vendor activities and to assure that correct procedures and equipment are used by properly qualified examiners during the performance of ISI activities. The training of ISI vendor personnel was entirely revamped as were NDE procedures and associated data sheets. Also, the unit has an adequate snubber reduction program and is using a unique approach, based on the physical characteristics and methodology used in the pipe stress analyses. This program was tested under a pilot program and is getting good support from management. The visual examination procedures for snubbers were good.
In summary, the conduct of maintenance and surveillance activities was good with appropriate emphasis on improving procedural adherence. There were several examples of insdequate surveillances procedures identified by a good questioning attitude on the part of the departments. Notwithstanding the good initiatives in the work control area, several equipment problems resulted from inadequate work control and planning. Management oversight and involvement were evident and were a strength.
III.C.3.b Performance Rating: Category 2 III.C.3.c Board Recommendation: None
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III.D Emergency Preparedness Ill.D.1 Analysis
In the last SALP assessment of emergency preparedness (EP), strengths were noted in staffing, drill performance and extensive management involvement in the program. A Category 2 rating was assigned. Weaknesses were noted in operator training on classifying j fast-breaking general emergency scenarios and in meteorological data reliability. Also, during an actual loss of annunciator event, review by the Technical Support Center (TSC) was hampered by a lack of detailed schematics for the annunciator power supply.
During this SALP period, the technical information available to the TSC was significantly improved although some vendor manuals have not yet been obtained. Further, a 10-meter, back-up meteorological mast was installed to provide additional wind speed and direction to compensate for equipment damage and/or Doppler Acoustic Sounder inaccuracy during high winds or heavy precipitation (e.g., Hurricane Bob). To address the weakness in operator training on the more severe emergency scenarios, the licensee increased the number of Site Area Emergency and General Emergency scenarios available in each unit's simulator scenario files. The effectiveness of the use of these additional scenarios has not yet been evaluated. However, one of five operators examined had difficulty classifying emergency events during NRC requalification examinations.
The five Unusual Events declared during this SALP period were promptly recognized and properly classified, but one of the five was reported 15 mir utes late. As corrective action, ' the licensee issued a memo to the operators restating the need for timely implementation of offsite notifications. Effectiveness of that action has not yet been reviewed by the NRC, but
one post-SALP period event notification was slightly late (about three minutes), indicating that event reporting timeliness was still not assured.
The licensee began staffing a 24-hour, On-Site Director of Site Emergency Operations (ODSEO) position for each unit during this period. That relieved the shift supervisor of - DSEO responsibilities earlier in an event. NRC observations during events and licensee drills concluded that their response had been enhanced as a result. However, the NRC found that the licensee occasionally listed the same person as the ODSEO (a Comrol Room / Emergency Operations Facility position) and as on-call Duty Officer (the pre-designated Technical Support Center Manager), but took action to resolve this coiifli':t after identification by the NRC. This indicated a lack of careful coordination of the ODSEO ' initiative.
Other flaws in emergency preparedness program and facility maintenance were evident. For example, NRC review found that the " Duty Officer" procedure was out-of-date and not being used. It did not reflect the ODSEO program implementation. It was also noted that replacement of missing items in emergency equipment lockers was very slow (e.g., six to-
nine months). No associated response inadequacy or facility degradation was evident. These were instances of inattention to detail in keeping emergency procedures and equipment current. Otherwise, the EP program was satisfactorily maintained.
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During the annual emergency exercise, computer-based call-out system effectiveness we strength. Two exercise weaknesses were identified in relation to: (1) maintaining containment pressure above the value specified by Emergency Operating Procedure < p (2) declaration of the event as a General Emergency (Connecticut State posture c' BRAVO) when radiological conditions did not support that high of a classificav exercise performance was good.
The Millstone Emergency Plan Implementing Procedures (EPIPs) were F combine the 77 EPIPs into about 33 procedures, including EPIPs, ope'
(EPOPs) and departmental procedures (EPDPs). That project inclur' .ew Writer's Guide, and procedure validation and verification, and we m May 1993. This was assessed as a good initiative but could no+ tor effectiveness.
t In an effort to enhance emergency planning, the licensee ased the number of emergency drills conducted. During this SALP peri .tlls were conducted (versus a goal of six) including the annual exercise a-
- ise. Twelve call-in drills and seven security interface drills were also '
provided excellent training. Other EP training was accomplished tF , except for some training sedures, when issued. Delays delayed late in 1992, in order to permit traini[r in the implementation of the new procedure . this training being rescheduled I and conducted using the old procedures tc , ,n expiration. Nonetheless, all training was accomplished within the re ,' emergency response organization (ERO) qualifications were maintained f the training was assessed as good.
EP specialist staffing was sufficir . Emergency Plan and EPIPs, conduct drills and exercises, maintain e f p facilities, and assure the maintenance of ERO qualification. The EP ' ' f gorganized with increased staffing to support i the Millstone and Haddam piew Emergency Preparedness staff was headed by a Corporate (NUSCC , included the EP Technical Programs staff, the Off-Site Program staf' EP staffs for Millstone and Haddam Neck.- A major purpose of the reorr ed staffing was to improve off-site EP support to the State and local m* .corganization was a positive initiative showing management in- .,upport of EP; its effectiveness will require additional time and review tr Manager .n EP was excellent. Senior licensee staff and management
mainti ations. The on-site lead Senior Nuclear Emergency Preparedness t Coo-with plant management daily. A close and effective relationship be' dP staff, plant managers, the corporate office EP staff, and corporate .cated by the high quality of the EP procedure upgrades that_were
- EP staff also held meetings with State and local officials to discuss the ERO
.sponse. The licensee also assisted State and kwal officials with updates to their ' .et new Federal Emergency Management Agency (FEMA) directives.
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, . . 21a During the annual emergency exercise, computer-based call-out system effectiveness was a strength. Two exercise weaknesses were identified in relation to: (1) maintaining containment pressure above the value specified by Emergency Operating Procedures, and (2) declaration of the event as a General Emergency (Connecticut State posture code BRAVO) when radiological conditions did not support that high of a classification. Overall, , ' exercise performance was good.
The Millstone Emergency Plan Implementing Procedures (EPIPs) were being revised to combine the 77 EPIPs into about 33 procedures, including EPIPs, operating procedures (EPOPs) and departmental procedures (EPDPs). That project included completing a new Writer's Guide, and procedure validation and verification, and was to be completed in May 1993. This was assessed as a good initiative but could not yet be evaluated for effectiveness.
In an effort to enhance emergency planning, the licensee significantly increased the number , of emergency drills conducted. During this SALP period, eight major drills were conducted ' (versus a goal of six) including the annual exercise and a practice exercise. Twelve call-in . drills and seven security interface drills were also held. These drills provided excellent training. Other EP training was accomplished throughout the year, except for some training delayed late in 1992, in order to permit training on new EP procedures, when issued.
Delays in the implementation of the new procedure project resulted in this training being rescheduled and conducted using the old procedures to avoid qualification expiration.
i Nonetheless, all training was accomplished within the required time period, emergency response organization (ERO) qualifications were maintained, and the quality of the training j was assessed as good.
i EP specialist staffing was sufficient to maintain the Emergency Plan and EPIPs, conduct drills and exercises, maintain emergency response facilities, and assure the maintenance of ERO qualification. The EP Department was reorganized with increased staffing to support the Millstone and Haddam Neck sites. The new Emergency Preparedness staff was headed by a Corporate (NUSCO) EP Director and included the EP Technical Programs staff, the Off-Site Program staff, and the On-Site EP staffs for Millstone and Haddam Neck. The { major purposes for the reorganization and added staffing were to enhance the on-site EP program as well as improve off-site EP support to the State and local municipalities. The reorganization was a positive initiative showing management involvement in and support of EP; its effectiveness will require additional time and review to assess.
Management involvement in EP was excellenc. Senior licensee staff and management , maintained ERO qualifications. The on-site Lead Senior Nuclear Emergency Preparedness Coordinator interacted with plant management daily. A close and effective relationship between the on-site EP staff, plant managers, the corporate office EP staff, and corporate , managers was indicated by the high quality of the EP procedure upgrades that were completed. The EP staff also held meetings with State and local officials to discuss the ERO and off-site response. The licensee also assisted State and local officials with updates io their plans to meet new Federal Emergency Management Agency (FEMA) directives.
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Two annual licensee EP audits were conducted. The first was performed by auditors who did not have direct responsibility for the EP program, but who reported to the Radiological Assessment Branch Manager, who had that responsibility. The second audit was conducted j by the NUSCO Quality Services Department, providing auditor independence. These EP ' audits were generally sufficient in scope and depth, but the required 12-month audit of off-site interfaces was not included in the second audit. The licensee then interviewed officials from 12 towns and found them generally satisfied with their relationship with the licensee.
) Overall, EP auditing was assessed as adequate.
In summary, there was a generally sound EP program. Staffing, exercise performance, and-licensee drills were program strengths. Management was extensively involved in EP.
Meteorological data support was substantively improved and there were several other good initiatives, the results of which were not yet evident in performance. Program audits were adequate. Emergency classification and reporting discrepancies continued indicating this weakness has not been fully resolved. Also, there were multiple instances of flaws in program and facility maintenance.
III.D.2 Performance Rating: Category 2 Ill.D.3 Board Recommendation: None.
Ill.E Security nnd Safeguards III.E.1 Analysis During the previous assessment period, the licensee's performance was rated as a Category 2. That rating was based on implementation of a generally effective program.
Improvements were made during that period and resources were committed for other security initiatives. Audits and self-assessments were generally effective in improving program implementation; however, weaknesses were identified by the NRC in corrective action implementation. Equipment maintenance and training were considered strengths.
! During this SALP period, management attention to the security program remained evident.
Upgrading of systems to enhance their operation and reliability was continued (e.g., the assessment system upgrade was completed and the intrusion detection system upgrade was very nearly completed). An aggressive preventive and corrective maintenance program, carried out by Instrument & Controls personnel within the licensee's security department, produced an excellent on-line availability for security equipment and a significant reduction in staff-hours for compensatory measures. These initiatives were indicative ofinterest in an effective program.
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Corporate security management continued to be actively involved in all plant security program matters. This involvement included corporate staff support for monitoring program implementation and planning program modifications and upgrades. Security personnel were also active in industry groups engaged in nuclear plant security matters. This demonstrated program support from upper level management.
During removal of the first steam generator from the Unit 2 containment, a significant weakness was identified by the NRC. This evolution was not routine; plans had been developed by security to maintain the required protection for the plant. However, for about 50 hours, a vital area boundary was degraded and was not noticed by a number of security supervisors, both licensee and contractor. In addition, no special post orders were developed for the security force members who were involved in this evolution. Further, when the steam generator was moved outside the protected area, the NRC identified a problem with control of personnel that were accompanying the steam generator. The security organization did not adapt to that non-routine activity. When these weaknesses were identified by the NRC, the licensee took prompt corrective actions, which included measures to upgrade the performance of the supervisors. The effectiveness of these measures has not yet been assessed by the NRC.
Effective communications and interface with other plant groups were maintained by a security representative attending daily plant staff and outage planning meetings. A ) potentially significant security problem was avoided by an alert member of the security force after, through a personnel error, a revision to a work order had been made without review by security. The NRC review of the matter confirmed that the problem was not programmatic.
During a special inspection of the licensee's access authorization program, the NRC found the program to be generally effective; however, several weaknesses were identified. Those weaknesses included problems with personnel identification practices, contractor audits, the lack of definitive acceptance criteria for derogatory information, limited review of credit report information and a concern with the program used to update information following ) interrupted access authorization. The effectiveness of the licensee's corrective actions for these weaknesses has not yet been assessed.
'i Only one prompt reportable security event occurred during the assessment period. It resulted' from severe weather which caused some security equipment to fail. Appropriate compensatory measures were implemented. The licensee's event reporting procedures were j clear and consistent with the NRC's reporting requirements. However, late in the period a weakness was identified in the amount of detail contained in the logs of recordable events.
Review of these iogs disclosed that the records were very brief and lacked sufficient j specificity to classify and trend similar events. The weaknesses did not appear to have adverse programmatic effects, but the licensee committed to review the matter and take corrective actions as required. The NRC has not yet evaluated the effectiveness of licensee actions in this matter.
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The annual audit of the security program was performance-based. A few minor findings were effectively corrected in a timely fashion. The audit of the Fitness-for-Duty Program was very comprehensive and in-depth and utilized a consultant on the team. A few programmatic findings were identified and effectively corrected. The licensee conducts self-assessments to augment the audit program. These were effective in providing increased oversight of program implementation and personnel performance on a day-to-day basis. The self-assessment program was effective in minimizing problems; however, it did not identify _ the weaknesses in supervisory performance, post orders, loggable events or access control practices.
In the previous period, the NRC found a weakness in the licensee's tracking identified ' corrective actions. To correct the weakness, the licensee assigned a member of the security department to that task. That action was found to be effective during this period.
The licensee's security department was staffed with experienced and dedicated personnel.
, Staffing in the contract security force was consistent with program needs, with a manageable . overtime rate. The security training and qualification program continued to be a strength.
Development of a tactical training program continued and the training facilities continued to be upgraded, further evidence of management support for the security program. The effectiveness of the security training program was evidenced by the small number of errors by security personnel.
During the assessment period, the licensee submitted three revisions to the security program , plans. The revisions were technically sound and demonstrated a thorough knowledge and understanding of NRC requirements and security objectives.
j In summary, the licensee continued to implement a generally effective security program.
System and equipment upgrades were continued during the period. While the audit and self-assessment programs were effective in improving some aspects of program implementation, some weaknesses went undetected. In particular, not recognizing problems that could and did develop during a non routine evolution and the lack of specific post orders to monitor the evaluation effectively, reflected poorly on supervisory performance. The training and qualification program for security force members and the security I&C support for equipment remained strengths.
III.E.2 Performance Rating: Category 2 III.E.3 Board Recommendation: Management oversight of non-routine operations should be improved l
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III.F Engineering and Technical Support III.F.1 Analysis During the previous SALP period, Engineering and Technical Support for all three Millstone Units received a combined rating of Category 2. Problems with timely reportability determinations appeared to have been corrected. Significant changes to the corporate and site engineering organization had been made to enhance individual unit support. A good plant modification program was founded upon good coordination between corporate and site engineering groups.
During the previous SALP period, licensee engineering initiatives resulted in identifying a number of pre-existent design basis problems at Unit 1. Handling of these issues reflected a good questioning attitude, good perspective, and good corrective actions.
Unit 2 management oversight of the engineering organization was generally good for a number of activities; however, weak management oversight of the erosion / corrosion program was observed and weaknesses were noted in the in-service test program. Unit 3 had several long-standing equipment problems that led to inoperable equipment. These problems appeared to be the result of inadequate monitoring of equipment performance by engineering.
During this SALP period, a corporate reorganization formed the Project Services Department ' (PSD) within the Nuclear Engineering & Operations (NE&O) Group to better focus corporate engineering support to unit operation and to consolidate design authority within the engineering organization. The licensee had historically provided engineering and technical , support for plant operations via engineering groups that reported to the individual Unit Director. During this SALP period, the PSD project engineers performed major plant , modifications and engineering backlog reduction tasks. Major design changes were processed with the PSD group having the lead for overall design, design review, and discipline specialty support, with the plant in a support role for procedure changes, testing, and turnover. Materials and equipment selected for the modifications were found to be suitable for the application. Design inputs were incorporated and installed equipment complied with the QA procurement requirements and engineering specifications. Design changes were of good quality, technically accurate, and used sound engineering bases. Pre-operational tests conducted for the design changes were thorough and detailed.
The licensee demonstrated a good safety ethic, critical self-assessment, and comprehensive corrective actions for some identified discrepancies. Several major program areas were targeted'for improvement including such activities as engineering backlog reduction, procedures upgrading, system engineering implementation and reliability-centered maintenance. Examples of the licensee's corrective actions included the Unit 2 spent fuel pool criticality analysis, mitigation of potential grid stability problems and modification of the Unit I reactor vessel water level instrumentation. But, there were also instances of inadequate resolution of engineering issues at all three Millstone Units. These included Unit I replacement of the service water (SW) strainer without proper dedication of a commercial grade component and restarting in March 1992 with a known flaw involving below minimum wall thickness on the SW piping. Initial review and engineering control of Unit 2 reactor .
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coolant system (RCS) pipe movement was weak. The licensee was slow to fully investigate deficiencies in leftover fasteners from Unit 3 construction that were subsequently used in other units. Also, the licensee was slow to respond to degraded Unit 3 auxiliary building filter system and its effect on the operability of the supplemental leak collection and release system.
The licensee was sensitive to potential vulnerabilities during shutdown operation and the engineering department consequently developed a comprehensive shutdown risk management strategy. The strategy was first employed on a limited basis during the Unit 1 service water outage and was successful in ensuring diverse means were available to the operators to remove decay heat from the reactor and sensitizing the operators to the decay heat load.
Similar shutdown risk program initiatives were implemented during the Unit 2 refueling outage and the Unit 3 forced outage for ventilation system modification.
Management attention provided to the erosion / corrosion program development and implementation was effective. The erosion / corrosion program implementing instructions were controlled, explicit and implemented with high quality.
Northeast Utilities' effort to formalize training guidelines provided the basis for enhancing existing training for engineering support personnel. Appropriate training tailored to work assignments was available using varied techniques and was comparable to industry practices.
Millstone Unit 1 Good erigineering support was provided to the plant to correct deficiencies in plant systems and components during this SALP cycle. Examples included the design, installation and testing of the wide-range reactor vessel level backfill system and the development of a detailed inspection plan for the service water system during the unplanned mid-summer service water maintenance outage. However, inadequate resolution of engineering issues was noted in the replacement of the service water strainer with an improperly dedicated component and the March 1992, unit startup with a known area of service water piping thinning below minimum wall thickness.
Administrative closcout of completed work packages and Plant Incident Reports were not timely and complete. The slow administrative closeout of these items resulted in inaccurate design basis documents, wiring diagrams, and slow investigation of events. To improve performance, appropriate additional management attention has been placed on these areas.
The effectiveness of these actions has yet to be determined by the NRC.
There was an improved understanding of the Unit I design basis by the site and corporate engineering staffs. This was recognized by the discovery of numerous plant design deficiencies that have existed since the start of commercial operation. Examples included a discovery of the potential for inadequate service water flow during a design basis accident . .
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following an assumed single failure of a valve in the service water system and the discovery of degradations in environmental qualification protective barriers in the turbine building.
The improved understanding of Unit I design basis has helped improve the assessment and understanding of design issues.
A weakness was noted in the procurement area. Nonsafety-related equipment was installed in safety-related applications and material from nonapproved vendor sources was used in plant equipment. This weakness suggests a lack of thoroughness by personnel during receipt and inspection of these components. Improved procedures were put in place to correct this problem but have not yet been assessed 'for effectiveness.
Millston'e Unit 2 , Generally good management oversight of the engineering organization, both on-site and off-site, was evident. This was particularly evident in the plant modifications relating to the vulnerabilities to the July 1992, loss of normal power event and a postulated main steam line - break accident. However, there were some examples of incomplete action to resolve issues.
The failure to implement a plan for properly removing two inverters from service resulted in . unexpected loss of actuation logic power and failure of emergency equipment to operate properly. Once the design problem with the emergency safeguards actuation system was discovered, extensive resources were applied to the resolution. There were several - opportunities to identify the problem before the event, which suggested that an interdisciplinary review of the issue might have identified the problem sooner. In another case, the licensee failed to focus on an industry-recognized emergency diesel generator vulnerability until the NRC questioned their practice.
In general, the engineering staff was technically competent in those areas associated'with the l electrical distribution system. Responses to NRC requests were timely. However, there was a noticeable lack of communications between the electrical and systems groups in development of the diesel generator loading calculations. There were, however, noticeable instances of lack of attention to detail, such as in the use of inappropriate mathematical relationships to determine starting loads for Motor Operated Valves; the use of nonconservative assumptions (e.g., motor power factors), and in the efficiencies assumed in the voltage regulation study.
, i The overall management of the steam generator replacement was strong. The technical reviews and calculations used to support this modification were detailed and well documented. Personnel controlling the change were highly qualified. The safety evaluation and supporting reviews and analyses were thorough and of high quality. However, the NRC , considered that the initial evaluation of the reactor coolant system piping movement and its effect on the analysis and engineering calculations performed by the licensee to assure conformance to the original design basis to be technically deficient. The preparation for and conduct of the actual steam generator replacement and the final studies made to support the unexpcx:ted problems encountered were thorough, well organized, technically sound and in accordance with applicable industry codes and standards.
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The NRC identified deficiencies in the way the licensee was handling the administrative aspects of plant design changes: systems were declared operational prior to procedures being changed, drawings were not always upgraded, administrative procedure requirements were being side-tracked without formal Plant Operating Review Committee (PORC) review and approval, short-term Plant Design Change Requests (PDCRs) and purchase orders were used ' to control engineering activities, and design change notices for major changes to PDCRs were not receiving the safety evaluations and PORC reviews required by administrative procedures. Management administration of PDCRs appeared weak. The informal process for tracking and closing PDCRs did not meet Administrative Control Procedures (ACP) i requirements; however, serious problems were prevented by good internal, but informal, communications.
Millstone Unit 3 Thorough follow-up, prompt corrective actions, and good safety perspective were demonstrated to resolve most identified design issues. Examples included adjustments to the Veritrack reactor protection system differential pressure transmitters by Unit 3 (although corporate engineering support of the Unit 3 technical evaluation was delayed), resolution of Potter-Brumfield rotary relay concerns, and resolution of discrepant power-operated relief valve gasket materials. However, administrative closeout of completed work packages and Plant Incident Reports were not timely and complete. In addition, poor engineering judgement and weak management oversight were noted in the initial resolution of the auxiliary building filter system (ABFS) design issues. Also, the licensee's investigation of construction fastener receipt inspection discrepancies was not prompt and comprehensive.
The ABFS design issue significantly challenged the site and corporate engineering groups.
The licensee devoted substantial resources and time to determine the root cause, and to establish conditions to assure that the system would perform its design function. Initial corrective actions were inadequate in that the system was further degraded by the positioning of the variable inlet vanes. However, once the full scope of the problem was identified and understood, the licensee implemented well-developed corrective action to ensure temporary system operability. The time required for completion of this effort was prolonged and needed improvement in several areas: clearer communications of design requirements and limitations for incorporation into operating procedure, more accurate and complete preparation for PORC discussions, and better coordination between the organizations involved in problem resolution.
A number of new engineers were hired and reported on-station during this period in an attempt to reduce the number of backlog open items. An improvement was noted in the backlog at the end of the period; however, the remaining open items continued to be of concern because of the continuing effort needed to manage this backlog to the detriment of addressing emergent problems.
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Summary
In general, there was good engineering support for the plants to correct identiDed de6ciencies. The effectiveness of the new engineering organization has yet to be f-
demonstrated. Deficiencies were identified in the administratior of plant design requests. The shutdown risk initiatives showed management attention to this s- , Completion of the erosion / corrosion program station-wide was thorough and , Corporate and site engineering understanding of the Unit I design basis '
discovery of numerous design deficiencies that existed since the start c ' operation. Weaknesses were noted in Unit 1 area of procurement rr xy-related equipment being installed in safety-related applications.
Overall, management of the Unit 2 steam operator replaceme-supported by ' generally excellent technical work. Upon recognition, Uni' ok extensive actions to resolve a number of complex issues. A lack o' a was evident .i t - ing calculations, and through inappropriate mathematical relationships used i the handling of PDCRs.
/ At Unit 3, examples of thorough engineering an f pective were offset by examples of poor engineering judgement and v p f . oversight. Progress was made in reducing the backlog of engineerinc 9 I-mcrease in corporate
engineering participation in routine operat lil.F.2 Performance Rating:
III.F.3 Board Recommen J.
+ III.G Safety Assessme' .ation ' Ill.G.1 Anal' The previous S/ .ssessment of Safety. Assessment / Quality Verification that resulted in a r The SALP Report noted that there were weaknesses in the licensee's s-aer in the review period carried over from the previous SALP period. management and the independent assessment functions of the
Nuclea-4RB) and Quality Assurance (QA) audits to effectively review site activ apt action on resolving some deficiencies resulted in the decline in pe* i the majority of functional areas during the SALP period. Licensee r ~ their Nuclear Safety Concerns program appeared responsive to the s for improvement made by their self-assessments. Problems associated with .erence were carried over from the previous SALP period.
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Summary In general, there was good engineering support for the plants to correct identified deficiencies. The effectiveness of the new engineering organization has yet to be fully demonstrated. Deficiencies were identified in the administration of plant design change ' requests. The shutdown risk initiatives showed management attention to this safety issue.
Completion of the erosion / corrosion program station-wide was thorough and effective.
A Corporate and site engineering understanding of the Unit 1 design basis has led to the discovery of numerous design deficiencies that existed since the start of commercial operation. Weaknesses were noted in Unit 1 area of procurement resulting in nonsafety-related equipment being installed in safety-related applications.
Overall, management of the Unit 2 steam generator replacement was strong and supported by generally excellent technical work. Upon recognition, Unit 2 took extensive actions to resolve a number of complex issues related to the steam senerator replacement project.
However, for other issues, a lack of attention to detail was evident through inappropriate. mathematical relationships used in certain engineering calculations, and the handling of PDCRs.
? At Unit 3, examples of thorough engineering and good safety perspective were offset by examples of poor engineering judgement and weak management oversight. Progress was made in reducing the backlog of engineering open items. An increase in corporate ' engineering participation in routine operation was noted.
III.F.2 Performance Rating: Category 2 III.F.3 Board Recommendation: None - III.G Safety Assessment / Quality Verification III.G.1 Analysis The previous SALP provided an assessment of Safety Assessment / Quality Verification that . ' resulted in a Category 3 rating. The SALP ' Report noted that there were weaknesses in the licensee's self-assessment earlier in the review period carried over from the previous SALP period. The failure ofline management and the independent assessment functions of the Nuclear Review Board (NRB) and Quality Assurance (QA) audits to effectively review site activities and take prompt action on resolving some deficiencies resulted in the decline in ! performance noted in the majority of functional areas during the SALP period. Licensee actions to enhance their Nuclear Safety Concerns program appeared responsive to the recommendations for improvement made by their self-assessments. Problems associated with procedural adherence were carried over from the previous SALP period.
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i Millstone Station and Corocrate Programs , During this SALP period, the licensee exhibited strength in some of their self assessment efforts, in particular, the efforts in development of the Performance Enhancement Program (PEP). However, other areas of quality verification exhibited significant weaknesses such as continuing problems with the Unit 1 operator requalification program and the decision to startup Units 1 and 2 with known deficient conditions and incomplete work in the service water header and the service water supply line to the vital switchgear areas coolers, respectively. In addition, the licensee's efforts to correct longstanding problems with procedural adherence were ineffective.
in response to declines in performance identified by NU and NRC during the previous two SALP periods, NU had initiated a number of evaluation efforts to assess their performance.
These efforts resulted in the preparation of task group reports, during the previous SALP period, in the following areas: Performance, Procedural Compliance, Allegations Root Cause, and Operability, Reportability, and Communications. In response to the observed decline in overall performance at the Millstone facility and the Corporate Offices, the licensee developed the PEP during this SALP period. The PEP represented the vehicle by which the licensee took positive steps to address the recommendations of their internal task groups and other evaluation processes and represented a substantial investment by the licensee to reverse the identified decline in performance. Notwithstanding the comprehensive scope of the PEP action plans, current progress on PEP initiatives had not yet achieved a discernible overall performance improvement. However, improvements in oversight and handling of employees concerns and shutdown risk assessment, and increases in staff and resources for key areas were evident.
During this SALP period, licensee management was prompt, effective, and showed good initiative in investigating concerns of inaccurate records on operator round sheets. The
licensee's corrective actions to improve the communication of management expectations i regarding watchstanding were effective. Also, as a result of these investigations, a number. of differences among the units were noted. The need for improved consistency among the units was identified in the PEP.
In contrast to the improved self-assessment efforts reflected in the PEP, the NRC noted a distinct lack of management attention to, or critical self-assessment and effective corrective
actions for, the problems with the licensed operator requalification training (LORT) program at Unit 1. As a result, for the second consecutive year, the Unit I requalification program was determined to be unsatisfactory. Reviews c,f the LORT programs at all thice units indicated that divergent LORT program / procedural implementation existed for common j corporate policies and principles. A training team inspection, completed just after the end of the SALP period, indicated training program weaknesses common to all three units. In addition, the failure to conduct required audits of the training program further indicated the lack of management attention to and critical self-assessment of thi:: performance area. While substantial licensee effort has been devoted to this area recently to correct these performance j deficiencies, the effectiveness of these corrective actions remains to be evaluated.
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During this SALP period, the Quality Services Department (QSD) critically assessed plant and corporate performance through surveillance and audit activities which, in addition to planned audit areas, focused on previous problem areas for Millstone. Audit activities effectively assessed technical and administrative programs. Chronic weaknesses in corrective action programs and adherence to administrative procedures were identified frequently and highlighted in quarterly trend reports to corporate management. Station responses to audit findings generally required extensions and were often late. To improve procedural adherence, frequent oversight of surveillance activities by Quality Services Department and first line department supervision was noted. The increased oversight indicated that the licensee was attempting to improve performance in the area of procedural adherence and while initially successful, performance improvement in this area reached a plateau.
Procedural errors during this SALP period caused a reactor trip on MSIV closure at Unit 1, several inadvertent safety system actuations at Unit 2, and an inoperable hydrogen recombiner at Unit 3. In the last quarter of this assessment period, QSD initiated action to elicit further management action in the area of corrective actions.
> During this SALP period, the NRC noted a tendency by the licensee to defer prompt comprehensive corrective actions for identified program area deficiencies pending the implementation of long-term comprehensive corrective actions (i.e., via the PEP). As a result, initial corrective actions for identified problems tended to be narrow in scope and some problems such as Unit 3 overlap testing concerns have recurred. In particular, identified procedure discrepancies are corrected, but efforts to determine why the procedure review process did not find the problem and whether similar procedures are effected are often deferred to the procedure upgrade program.
The NRBs/SNRBs generally fulfilled their charters, although with the primary focus on technical rather than programmatic issues. With varying degrees of effectiveness, the boards performed good technical safety reviews of plant operations. However, improvements were warranted in assessment of program effectiveness (e.g., Quality Assurance Program, Operator Requalification Program) and communication of these assessments to site and corporate management.
During the last SALP period, the Plant Incident Report (PIR) corrective action program was found weak in that personnel failed to review previous events to determine if adverse trends were occurring. The licensee revised the PIR reporting process, but station management had not assured the new procedures were effectively carried out.
While inconsistency in safety evaluation quality was noted in the 10 CFR 50.59 evaluations during the previous SALP period, more recent evaluations reviewed during this SALP period showed an increase in quality and technical content.' The 10 CFR 50.59 cvaluation prepared in support of the Millstone Unit 2 steam generator replacement was particularly noteworthy ) in its scope and completeness.
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l During this SALP period, the licensee requested, and received, short turn-around, expedited, or emergency action on seven license amendment requests among Units 1,2, and 3. In at least one case, involving Millstone Unit 3 snubbers, the emergency action was brought about by poor planning on the part of the licensee. In general, the requested issuance date was known well in advance, but the requests were not submitted until approximately 3 months before the requested issuance date. Licensee management attention and involvement were evident in their continued attention to reducing the licensing backlog of old issues.
i The licensee devoted significant resources to the Nuclear Safety Concerns Program (NSCP) and revised it along the lines recommended by the Allegation Root Cause Task Group's recommendations, particularly with the introduction of the Peer Evaluator Program.
Millstone Unit 1 Weaknesses in the administrative processing and dissemination of industry information - contained in NRC Information Notices and vendor letters were apparent during this SALP period. These weaknesses prevented timely correction of a deficiency in a secondary containment surveillance procedure and may have prevented the development of an effective preventive maintenance schedule for 4.16 kv circuit breakers.
A noteworthy initiative involved conducting a periodic review of the outstanding Unit 1 engineering / design issues with the corporate NUSCO staff during a combined Plant Operations Review Committee (PORC)/NRB meeting. During this meeting, all outstanding ' design issues were examined by the PORC/NRB members and assessed in the aggregate to ensure their cumulative effect did not result in an unacceptable decrease in plant safety.
Following the meeting, engineering resources and schedules were varied based upon plant priorities. By holding these meetings, the licensee demonstrated an appropriate sensitivity to resolve longstanding design issues and an awareness that several outstanding design issues may have a deleterious cumulative effect on plant safety.
PORC meetings were well focused during this report period. Significant issues were J " thoroughly examined. An example includes the assessment and evaluation of the modification to the reactor vessel wide range level indicating system.
During this assessment period, the licensee completed and submitted several licecsing packages related to the operation of Millstone Unit 1. In most cases, the licensee provided the appropriate analysis and information to substantiate their positions. An excep. ion to the above was noted in the technical review of the revised drywell temperature profi'.e. The staff > noted that the licensee was slow in submitting information concerning the operator intervention times for manually initiating drywell sprays.
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P Millstone Unit 2 The PORC was active during this SALP period, due to emerging events and issues and a long refueling outage which involved many modifications including the steam generator replacement effort. Generally the PORC deliberations were thorough and probing; however, following the outage, procedure deficiencies were identified due to the failure of the PORC to perform adequate reviews of procedures associated with modifications to systems and , components. Also, the PORC on two occasions accepted non-rigorous interpretation of ' Technical Specifications and procedural requirements. These examples involved the performance of the Control Room Tightness Tests and entry into the spent fuel pool area during the movement of fuel.
Procedure adherence was an issue in the last two SALP periods and was a recurring theme in NRC and the licensee's QSD findings. PIRs continued to show a large percentage of personnel performance problems. Corrective actions for procedural or technical deficiencies often tended to be narrowly focused, thereby missing potential programmatic issues. For example, a technical basis justifying compensatory measures for a loss of cooling in a vital switchgear room did not exist, despite the fact that a similar concern had arisen previously for another switchgear room. Also, specific procedural deficiencies were often corrected without reviewing other procedures for similar problems. This approach to corrective action
represented missed opportunities to prevent recurrence of problems.
The licensee's license amendments, approvals and relief request submittals were normally comprehensive and complete. These included TS changes for Cycle 12 operation, the
addition of two containment isolation valves, TS changes to support a Main Steam Line
Break (MSLB) reanalysis, TS changes to support modifications necessary to correct design deficiencies that caused a partial loss of normal power, TS changes necessary to correct an error in the spent fuel pool criticality analysis and TS changes related to containment tendon surveillance. Although the licensee's Plant Design Change Records concerning the MSLB reanalysis and the Loss of Normal Power (LNP) event on July 6,1992, were thorough and technically sound, the proposed license amendment's initial submittals for such complex issues did not reflect the complete scope of the PDCR.
Millstone Unit 3 During this SALP period, the PORC performed generally sound technical reviews and safety assessments. Station management and safety committee assessment of safety issues and routine plant performance issues were good. Notable examples of safe and conservative operational decisions were demonstrated in the adjustment to the Veritrack reactor protection system differential pressure transmitters (although corporate engineering support of the Unit ' 3 technical evaluation was delayed) and response to service water system degradation.
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The Independent Safety Engineering Group (ISEG) audit evaluations were of good quality and valid recommendations for improving performance were proposed. Examples of good evaluations included the assessment of the high pressure safety injection system availability and dispositioning of NRC information notices. Management action to resolve ISEG a recommendations was not timely in several cases, in part due to the lack of formal tracking of open issues. An improved tracking program for ISEG recommendations was developed, I but the effectiveness has yet to be assessed.
Licensee staff support for licensing action submittals, in meetings, and in telephone - conferences was technically sound and professionally presented (for example, the licensee's , September 10, 1992, relief request from ASME Section XI requirements was cited by ' reviewers as exemplary for completeness of information and a well-thought out format).
A weakness in the identification, evaluation, and timely correction of safety issues was evidenced by the inoperability of the auxiliary building filter (ABF) system and the testing of the ABF and SLC.RS system. Once the safety issue was identified; however, the licensee conducted a thorough investigation, and initiated acceptable corrective actions.
Summary The licensee's self assessment activities were acceptable with strong initiative being shown in the development of the PEP. Progress to date on PEP action plans had not yet resulted in a significant overall performance improvement. There was a distinct lack of management attention to, critical self-assessment of, and effective corrective actions for the problems with the LORT program at Unit 1, resulting in the second consecutive program failure. The activities of QSD, NRBs and SNRB were effective; however, improvements were warranted in corrective action programs and in the assessment of QA program effectiveness. The licensee was ineffective in resolving station-wide procedural adherence problems, and a tendency toward narrowly focused corrective actions was observed. The licensee's submittals were generally good, but tended to be submitted without recognition of the time needed for NRC staff review. Although the PEP and other initiatives have poised the , licensee for significant improvement in this area; the Jack of overall performance improvement, the inability to resolve long-standing procedural adherence problems, ineffective corrective actions, and the significant management oversight contribution to the unit LORT program problems have dominated this assessment.
III.G.2 Perfonnance Rating: Category 3, Improving ! III.G.3 Board Recommendations: 1.
Perform an integrated, in-depth assessment of the licensed operator training programs for the site to identify and ensure comprehensive corrective actions in this area.
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Improve the timeliness of comprehensive corrective actions for identified program area deficiencies by improving priorities and being more judicious in deferring action until completion of long-term programs (e.g., PEP).
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IV.
SITE ACTIVITIES
IV.A Licensee Activities IV.A.1 Millstone Unit 1 Millstone Unit 1 began the assessment period in cold shutdown while erosion / corrosion inspections of the secondary plant were performed. Once the inspections were completed, a plant startup was commenced on March 2,1992. However, full reactor power could not be obtained since the "A" condensate pump was out of service which reduced condensate / feedwater flow. On March 22, the plant was shut down when a 3/4 inch drain line from the "A" main steam line ruptured. Following replacement / redesign of the drain line and similar components, the plant was restarted and full power was reached on April 6,1992.
On July 4,1992, the plant was shut down when an unisolable portion of piping on the service water system had thinned to code allowable limits because of corrosion. When , additional inspections of the service and emergency service water systems revealed further degradation, an extended outage was commenced as the licensee performed extensive repairs and piping upgrades to those systems.
- During the July shutdown, level oscillations on both channels of the reactor vessel wide . ' range level indicating system occurred. The licensee attributed the oscillations to a buildup of non-condensable gasses in the reference leg of the level indicating system. Following further investigation of the oscillations, the level indicating system was declared inoperable when it,was postulated that the buildup of the gases could render the level indicating system i ' inoperable during a design basis event. To remove the non-condensable gases, a ' modification was developed which would theoretically purge the gases from the reference legs of the level indicating system with water from the control rod drive system. The licensee subsequently installed the system, declared the level indicating system operable and commenced a startup on August 13, 1993. The NRC reviewed the modification and determined that the installation did not adversely affect installed plant equipment.
Following the startup, the plant remained at 100% power except for power reductions due to routine maintenance and testing until December 3,1993. On that date, the reactor tripped when an operator inadvertently closed two main steam isolation valves during the performance of a surveillance test. Following the completion of minor maintenance and testing, the plant was restarted later that day.
The plant remained at full power until March 14, 1993, when during a severe winter storm an Unusual Event was declared and plant shutdown commenced when the licensee discovered that high winds had dislodged dampers that are located on the roof of the reactor building.
Before the plant shutdown could be completed, the dampers were repaired and the plant shutdown was stopped with the plant at 65% of rated thermal power. The plant returned to full power later that day and remained at full power for the remainder of the SALP period.
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IV. A.2 Millstone Unit 2 ! This assessment period began on February 16, 1992, with the plant operating at full power.
Full power operations continued until the end-of-cycle shutdown on May 30,1992. The plant was cooled down to Mode 5 on June 1.
, Reactor disassembly and core off-load was complete on July 2. Major outage activities included: replacement of the steam generators; replacement of vital and non-vital 120 volt AC static inverters; refurbishment and testing of safety related motor-operated valves pursuant to NRC Generic letter 89-10; safety-related ventilation system upgrades; and service water system pipe replacement.
The refueling outage originally was scheduled to be completed by mid-October. The outage tvas extended in part due to equipment set-up and contractor problems, engineered safeguards , ! actuation system problems discovered in response to a partial loss of normal power event on ' July 6, and unexpected reactor coolant system pipe movement which occurred during steam generator replacement.
Reactor reassembly was completed and Mode 5 was reached on December 9. Plant heatup started on January 5,1993, and the reactor was taken critical on January 10. Power ascension and core physics testing took place until January 24 when rated power was attained.
Full power operation continued until February 1, when power was reduced to 65% to repair a leaking main feed pump casing vent plug. Rated power operation resumed on February 3 and continued until the reactor tripped on low steam generator level on February 22 when a steam generator atmospheric dump valve failed open. During plant restan on February 23, at approximately 14% power, the plant again tripped on low steam generator level after the main turbine was tripped manually for high vibration. The plant was restarted on February 24 and full power was reached on February 26. The SALP period ended on April 3,1993, with the plant operating at rated power.
IV. A.3 Millstone Unit 3 This assessment period began on February 16,1992, with Unit 3 at full power. Power operations continued with power reductions to 60% on March 11 and March 26 due to storm condition impact on the circulating water intake bays. The unit was manually tripped on April 5 when both condensate pumps tripped due to low condenser hotwell level during condenser backwashing.
The unit restarted on April 10 and power operations continued until May 15 when the unit was shutdown for power-operated relief valve and safety valve repairs. The unit restarted and resumed power operation on June 4. On July 2 the power was reduced and the turbine was taken offline due to hot high side bushings on the main transformer. Power operations resumed on July 3.
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, On September 29, the plant was shutdown due to both trains of the supplementary leak collection and release system being declared inoperable. During the unit restart on November 5, the reactor tripped from a spurious signal in the offsite electric distribution system. The unit restarted and resumed power operation on November 9. Operations continued with a power reduction to 30% power on November 13-14, due to storm condition impact. The unit resumed full power until November 20 when the unit experienced a turbine runback caused by a failure in the electro-hydraulic control (EHC) system, resulting in a plant trip.
The unit restarted on November 21 with a subsequent 131 day on-line run. Power was reduced on December 10 and December 18 due to foul weather and feedwater pump testing, respectively. On March 31, 1993, the unit tripped from 100% power when a failure in the EHC system resulted in a severe load reject transient following which a main steam safety valve failed to rescat. The unit was shutdown at the end of the SALP period.
, ' IV.B Significant NRC Activities Five NRC resident inspectors were assigned to the site during the assessment period. NRC
team inspections were conducted in the following areas: Between May 26, and July 24,1992, the NRC conducted an inspection of the
activities related to the replacement of the steam generators at Millstone Unit 2. The NRC team determined that the preparations for the replacement of the steam generators were well organized and thorough.
A review of the July 6,1992, Unit 2 partial loss of normal power and
subsequent fuel pool draindown event was performed over an extended time period from July 6, to November 17, 1992. Overall, the team concluded that t the safety significance of the actual event was low. However, escalated enforcement action was under consideration by the NRC staff at the end of the SALP cycle concerning the failure of the licensee to identify and correct significant single failure design discrepancies earlier.
A modification that the licensee installed to the Unit I reactor ves21 wide range level
indicating system was reviewed by an NRC team from July 26 through September 7,1992. The team concluded that the modification was installed and tested in a safe and controlled manner and would not introduce previously unanalyzed , system failures.
Following a determination that the Unit I licensed operator requalification program
was unsatisfactory in September 1992, the NRC monitored the subsequent performance of the Unit 1 program by conducting several additional inspections of the operator licensing program throughout the remainder of the SALP cycle.
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During September-December 1992, a team of NRC employees from Region I and
NRR conducted a review of the PEP. That review involved the evaluation of elements of the program as well as a series of interviews to determine the level of management and employee support for the program. Overall, the PEP was viewed as a positive step toward addressing NU's performance deficiencies and represented a s'ubstantial investment on the part of NU. However, because of the early stage of the program, as well as the incomplete development of the verification and validation (V&V) part of the program, the ultimate effectiveness of the PEP could not be evaluated at that time.
An operational safety team inspectien was conducted at Unit 2 from
December 28,1992 - January 14, 1993. This team verified the completion and satisfactory testing of significant plant modifications, resolved specific technical concerns, and monitored plant restart.
- A team inspection of the Millstone Station requalification training prograir for
licensed operators was conducted in April 1993. While the team found substantial efforts at remediating the Unit I requalification training deficiencies, the team identified only one programmatic strength (i.e., the use of the Advanced Training Classroom). Three common program weaknesses across the units were identified: (1) control measures do not address the amount of previously used questions during LORT from being used on the facility; (2) control measures do not address how training for important or significant procedure changes is given when an immediate need occurs; and (3) control measures do not address when a root cause analysis for major de&iencies in the training area is to be conducted and the extent of that analysis. Although outside the SALP period, these results were included in this SALP, since the inspection reviewed and assessed licensee activities that occurred.
within the period.
. The training team inspection also reviewed the root cause(s) of the repetitive unsatisfactory results in 1991 and 1992, at Unit 1. The probable cause for the 1991 failure was a combination oflow training time and training to low standards. For 1992, the adverse result for ROs on the facility administered written examination was due to low training standaids (i.e., the low training time issue improved).
Management control system breakdowns reduced operator proficiency, resulting in these adverse results.
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_.. _ _ - P . I ~ A'ITACHMENT 1 SALP EVALUATION CRITERIA. PERFORMANCE CATEGORIES AND TRENDS The following evaluation criterion were used, as applicable, to assess each functional area: 1.
Assurance cf quality, including management involvement and control.
2.
Approach to the identification and resolution of technical issues from a safety standpoint.
3.
Enforcement history.
4.
Operational and construction events (including response to, analyses of, reporting of, , and corrective actions for).
5.
Staffing (including management).
6.
Effectiveness of training and qualifications program.
The performance categories used when rating licensee performance are defined as follows: + Catenorv 1. Licensee management attention to and involvement in nuclear safety or ' safeguards activities resulted in a superior level of performance. NRC will consider reduced levels of inspection effort.
Category 2. Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a good level of performance. NRC will consider maintaining normal levels of inspection effort.
Category 3. Licensee management attention to or involvement in nuclear safety or
safeguards activities resulted in an acceptable level of performance; however, because of the NRC's concern that a decrease in performance may approach or reach an unacceptable level, NRC will consider increased levels of inspection efforts.
Category N. Insufficient information exists to support an assessment oflicensee performance. These cases would include instances in which a rating could not be developed
because of insufficient licensee activity or insufficient NRC inspection.
, The SALP Board may assess a performance trend, if appropriate. The trends are: Imoroving: Licensee performance was determined to be improving during the assessment -; period.
~ Dsclining: Licensee performance was determined to be declining during the assessment ' period and the licensee had not taken meaningful steps to address this pattern.
Trends are normally assigned when one is deOnitely discernable and a continuation of the -! trend is expected to result in a change in performance during the next assessment period.
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NUCLEAR REGULATORY COMMISSION
475 ALLEt ALE ROAD %, ,e KING OF PRUSSIA. PENNSYLVANIA 19406-1415 W
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JUL 20 G03 Docket Nos. 50-245 50-336 50-423 Mr. John Executive Vice President - Nuclear Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT: INITIAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT NOS. 50-245/92-99,50-336/92-99 AND 50-423/92-99 On May 18,1993, an NRC SALP Board assessed the performance of activities at the Millstone Nuclear Power Station, for the period February 16, 1992, through April 3,1993.
The results are documented in the enclosed SALP Board Report. We plan to meet with you and your staff at the Millstone site in the near future to discuss the findings of this evaluation.
During this SALP period, performance at Millstone Station improved marginally from that achieved during the previous period. All three units have been operated cafely, with the most , noteworthy performance improvement in the Radiological Controls area which was rated a SALP Category 1.
We found the self-assessment initiatives and task action plans reflected in the Northeast Utilities Performance Enhancement Program (PEP) to be positive steps toward improving performance. However, your progress in implementing PEP has not yet produced significant overall performance improvement.
Continuing training program weaknesses were observed at Millstone, particularly in the area of Licensed Operator Requalification Training (LORT) at Unit 1. As a result, the Unit 1 L. ORT program was rated as unsatisfactory for the second consecutive year. This failure was indicative of inadequate root cause analysis and ineffective corrective actions, as well as, a noteworthy lack of corporate and site management attention to an identified performance problem.
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_ . Northeast Nuclear
J1 20IE3 Energy Company In addition to the LORT program deficiencies at Unit 1, long-standing performance problems remain in the areas of procedural adherence and corrective action effectiveness across the station. Additional management attention to these areas is warranted. Consequently, the area of Safety Assessment / Quality Verification was rated a SALP Category 3. An improving trend in this functional area recognizes the significant effort devoted to PEP initiatives during this SALP period.
In April 1993, a team inspection of the Millstone Station LORT was conducted. Although , ' the inspection was conducted outside this SALP period, the inspection findings were included in this SALP since the inspection reviewed and assessed activities that occurred within the period. While the team found substantial efforts at remediating the Unit I requalification training deficiencies and a programmatic strength involving the use of the advanced training classroom, program weaknesses adversely affecting all three units were identified. Of particular note was the fact that policies and procedures for program elements common to all three units were implemented differently or inconsistently among the units. The variances among the units suggested further weaknesses in corporate and site senior management oversight and direction to the program.
At the SALP management meeting you should be prepared to discuss our assessment, and your plans to improve performance. The meeting is intended to be a candid dialogue wherein any comments you have, regarding our report, are discussed. Additionally, you may provide written comments within 20 days after the meeting. In accordance with NRC policy, this meeting will be open for public observation.
We appreciate your cooperation.
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Sincerely, Thomas T. Martin Regional Administrator ] Enclosure: Initial Systematic Assessment of Licensee Performance (SALP) Report Nos.
50-245/92-99, 50-336/92-99 and 50-423/92-99 ~. -
, ' , .4 R 20 E Nonherst Nuclear
Energy Company cc w/ encl: W. D. Romberg, Vice President, Nuclear Operations Services E. DeBarba, Vice President, Nuclear Engineering Services S. E. Scace, Nuclear Station Director , H. F. Haynes, Nuclear Unit Director J. S. Keenan, Nuclear Unit Director F. R. Dacimo, Nuclear Unit Director R. M. Kacich, Director, Nuclear Licensing G. H. Bouchard, Director of Quality Services Gerald Garfield, Esquire Nicholas Reynolds, Esquire The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque , Institute of Nuclear Power Operations (INPO) K. Abraham, PAO (33) Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of Connecticut SLO Designee i i i .
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.. Northeast Nuclear
l Energy Company bec w/ encl: Region I Docket Room (with concurrences) , bec via E-mail: r J. Taylor, EDO V. McCree, OEDO ,_ J. Lieberman, OE L. Wharton, NRR J. Stolz, PDI-4, NRR D. Jaffe, SPM, NRR G. Vissing, PM, NRR - V. Rooney, PM, NRR _ ' J. Andersen, PM, NRR - Region I Staff (Refer to SALP Drive) Region I Docket Room (with concurrences) . I P $ . f P k !. . .
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. Enclosure 3 ' 'a , NORTHEAST UTILtTIES cenera Omen seiden street. Bernn. connecucut
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HARTFORD. CONNECTICUT 06141-0270 i k L IJ [[CN.7, [", (?03) 665-5000 i l September 10, 1993
Docket Nos. 50-245 50-336 50-423
B14603 i Re: SALP
Mr. Thomas T. Martin Regional Administrator, Region I ' U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Gentlemen:
Millstone Nuclear Power Station, Unit Nos.1, 2, and 3 Systematic Assessment of Licensee Performance . Report Nos. 50-245/92-99, 50-336/92-99, and 50-423/92-99 Response and Comments to Initial SALP Report , . I The NRC Staff forwarded the initial Systematic Assessment of Licensee , Performance (SALP)"' report documenting the results of the NRC SALP Board i assessment conducted on May 18, 1993.
The SALP Board evaluated.the: -j performance of activities associated with Millstone Unit Nos.1, 2, 'and 3 for ~ the period between ' February 16, 1992, and April 3, 1993.
Additionally, a management meeting was held on August 24, 1993, between the NRC Staff and , Northeast Nuclear Energy Company (NNECO) personnel to discuss the SALP Board assessment and initial report.
The purpose of this letter is to respond to and comment on the-initial SALP report and the SALP Board recommendations on individual functional areas.
Attachment 1 to this. -letter contains NNECO's response to each of the Board's ! recommendations for Millstone Unit Nos.1, 2, and 3.
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NNEC0 recognizes the importance of s' iving to improve corrective action
effectiveness and compliance with pro,.adures.
NNECO has taken and: will continue to take more aggressive actions-to improve in these areas.
These.
actions are detailed in Attachment I to this letter. Also, NNECO's corrective actions to the continuing operator training program weaknesses observed at Millstone Unit No. 1 are discussed in the attachment to this letter, f (1) T. T. Martin letter to J.
F. Opeka, " Initial Systematic Assessment of Licensee Performance (SALP) Report Nos. 30-245/92-99, 50-336/92-99, and 50-423/92-99, dated July 20, 1993.
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. .- - _ _ , - c - e , . U.S. Nuclear Regulatory Commission ' B14603/Page 2-September 10, 1993 NNECO acknowledges the obvious substantial effort and ' dedication of NRC ~ We resources that were expended in the preparation of the initial report.
appreciate and take seriously your assessment of. our performance and the
insights offered in the narrative of the report.
We are available to answer any questions you may have.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY hk & . J. F.% pdka () Executive Vice President J. W. Andersen, NRC Acting Project Manager, Millstone Unit No. I cc: G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 V. L. Rooney, NRC Project Manager, Millstone Unit No. 3 D. H. Jaffe, NRC Project Manager, Millstone Station P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 L. T. Doerflein, Reactor Project Section 4A, Region I U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
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. 1 l Docket Nos. 50-245 i 50-336 . 50-423 ' B14603 .. ! ? Attachment 1 - ; Millstone Nuclear Power Station, Unit Nos.1, 2, and 3 ' . Systematic Assessment of Licensee Performance P
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__ _ . . c . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 1 September 10, 1993 Hillstone Nuclear Power Station Unit Nos. 1, 2,.and 3 Response to SALP Report functional Area: Plant Operations Board Recommendation: None Response: Nuclear Energy Company (NNECO) recognizes the need for Northeast improvement in the areas of procedure adherence, attention to detail, self-verification, and configuration control at Millstone Unit Nos.1, 2, and 3.
In this regard, NNECO has taken and will continue to take actions to improve performance in this area.
A summary of key initiatives underway is provided below.
The vice president - Millstone Station issued two memoranda on April 30, 1993, to address the procedure compliance issue.
The first memorandum was issued to NNEC0 department heads.
It discussed causes and actions to preclude recurrence.
The recurring nature of deficiencies identified by Nuclear Quality' and Assessment Services (formerly Nuclear Quality Services) indicated that the identification of causal factors was not sufficiently accurate to allow the appropriate corrective actions to be implemented.
Therefore, if the causal factors were not accurate, then the corrective actions to preclude recurrence could not be successful.
The underlying cause of recurring procedure noncompliance was an inadequate determination of the causal factors for the deficiencies-listed in the Nuclear Quality and Assessment Services surveillance reports.
One of the causal factors which was appropriate was the existence of ambiguities or errors in some procedures, especially the Administrative Control Procedures (ACPs).
The existing ACP ' rewrite , I effort will continue to implement corrective measures.
" , To address the recurring deficiencies, station personnel were instructed to improve their determination of the causal factors.
Following the identification of causal factors and corrective / preventive measures, follow-through is required to assure timely and effective completion of corrective / preventive measures.
The second memorandum was sent to all Millstone Station personnel to The emphasize the vice president's expectation for procedure compliance.
memo expressed that everyone should understand that the issue is performance of personnel to standards and expectations.
All personnel must understand what is expected of them, examine their own performance, and recognize the need for improvement.
It was emphasized that these expectations must be met.
Each individual is accountable for his/her own __ __- ____-__- - __ - -
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September 10, 1993 performance, and supervisors are also accountable for the performance of their subordinates.
The Work Observation Program (WOP) has been an important tool in providing feedback to management with respect to corrective action effectiveness.
The WOP was initiated in September 1992 and was identified as a strength by INP0.
It functions not only as a management tool, but also as a worker tool that: , (1) reinforces work practice expectations; (2) evaluates work practices; (3) directs supervisory involvement; (4) provides a process to promptly correct deficiencies.
These observations are conducted by department heads and first-line supervisors.
Stop, Think, Act, Review (STAR) is a self-checking program which is being applied to all working groups at Millstone.
The STAR program booklets have been distributed to Millstone personnel, and this effort is expected to improve our performance in the area of procedure adherence and-attention to detail.
These issues will remain prominent on management's agenda during the current SALP interval.
With respect to the NRC's request for information concerning use and value of the Independent Safety Engineering Group (ISEG) at Millstone Unit Nos. I and 2, we offer the following: The current use of ISEG activities on Millstone Unit Nos.1 and 2 is primarily the evaluation of stationwide generic issues or programs.
These may be identified by the ISEG group or be initiated by management-request.
Examples include an evaluation of the. Plant Information Report (PIR) program conducted in 1992 and an evaluation of surveillance scheduling conducted in 1993.
Specific activities at Millstone Unit Nos. I and 2 generally take the form of independent reviews of unit events.
These r generally are the result of management requests.
Station management values both the technical capabilities and independent point of view that the ISEG function brings to issues.
Management is mindful, however, of the resource limitations that are imposed by the obligation to , comply with Millstone Unit No. 3 Technical Specifications.
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. . ' ., . . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 3 September 10, 1993 The ISEG group was augmented with an additional staffing position in 1992 which allows some flexibility in evaluating Milltone Unit Nos. I and 2 without adversely impacting Millstone Unit No. 3.
This flexibility is being.
used currently to support additional ISEG activities at Millstone Unit No. 2.
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' ,., . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 4 September 10, 1993 Functional Area: Radiological Controls Board Recommendation: None Besponse: NNECO is pleased that the Board recognizes our continued improvements in the area of radiological controls during the last SALP period.
NNECO will continue to emphasize improvements in all aspects of the Radiation Protection Program.
Enhancements to the Radiological Observation Programs are ongoing and include: Formalized assessment matrix designed to ensure continual review of . the entire health physics (HP) program.
Increased participation in site assessment programs, such as the - . WOP.
Continued emphasis by management for quality work.
. i Other improvements include reformatting / revising all HP procedures with human factors in mind.
A memo has been issued to prescribe additional training to facilitate awareness of changes to 10CFR20, which will be implemented at Millstone Station January 1, 1994.
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. . . .. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . ' , .l U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 5 September 10, 1993 Functional Area: Maintenance / Surveillance Board Recommendation: None Response: NNECO agrees with the Board's assessment of our performance in this functional area.
NNECO acknowledges the need to continue with the management initiatives associated with procedure quality and adherence, and work control and planning activities at Millstone Station.
The actions taken regarding procedure adherence are summarized in our response to the plant operations functional area.
Clearly, there exist opportunities for improved efficiency and coordination of our work control processes.
Establishment of the Integrated Team will help address the identified weaknesses in the areas of work control and pl anning.
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. . ' f ', . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 6 September 10, 1993 Eunctional Area: Emergency Preparedness Board Recomendation: None Response: We acknowledge the need to continue to improve.
One important area concerns emergency classification and reporting requirements.
As noted by the Board, management continues to focus attention to this area.
We appreciate NRC's recognition of the enhancements to the Emergency Preparedness Program such_ as more drills, new procedures, and' increased staffing.
We are encouraged that the NRC will consider the results of these enhancements in the next SALP period.
On page 21, paragraph 4 of the initial SALP report, the Board noted that the major purpose of the staffing increase was to improve offsite support to the state and local communities.
As mentioned during our. August 24, 1993, meeting, NNECO wishes to offer some clarification regarding the motives behind the staffing increases.
Staffing to support major enhancements to the on-site program was the single most important reason.
On-site staffing at Millstone was doubled to six personnel, and the Haddam Neck on-site staff was increased by one.
The Technical Programs section was formed to coordinate the increased number of drills and various other short-term and long-term on-site technical projects.
The staff in this area was increased from three Staff members to a supervisor . and seven staff members. The off-site programs staffing was also doubled l to a supervisor and eight staff members to meet increased FEMA requirements.
We suggest that you consider revising the SALP narrative to reflect the above.
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e Q ' . . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 7 September 10, 1993 Functional Area: Security and Safeguards Board Recommendation: Management oversight of nonroutine operations should be improved.
, R_esponse: Several initiatives have been taken to improve the management oversight of nonroutine operations at Millstone Station.
The number of licensee supervisors has been increased by one.
Administrative security shift assistance has been provided to support operations, freeing supervision for review and planning of nonroutine activities.
coordinators (nonsupervisory personnel) have been added to each Shift shift to free assistant shift commanders from routine tasks and allcw them to better focus on activities in the field.
Post-check standards were modified to ensure that sufficient time and Additionally, one supervisor on each scrutiny were given to each post.
shift is identified as the lead for all post inspections and maintains this responsibility for the duration of the' shift to provide continuity.
The Security Department Work Observation Program pairs supervisors and officers for observation of actual work in progress, and allows for Each immediate feedback on the quality of the officers' performance.
supervisor is obligated to perform a certain number of observations weekly.
for creating and changing post orders has been modified.
The process Requirements have been established for committee review and evaluation of ' changes to ensure adequate detail is provided and that there is no conflict with procedures, plans, etc.
In exigent circumstances, new post be effected with review and . orders or changes to existing ones can concurrence by the shift commanding officer and the licensee shift supervisor.
In addition, corrective actions for the NRC identified weaknesses in the ' access authorization program have been implemented for all items (e.g., identification used for temporary clearances, audits of approved coutractor programs to include Continuous Behavior Observation Program, and the lack of definitive acceptance criteria for derogatory information) except for the concern involving infrequent access.
Resolution of this issue is continuing to be developed.
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.. . e * ,, ' U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 8 September 10, 1993 Functional Area: Engineering and Technical Support Board Recommendation: None Response: In response to a question that arose during our August 24, 1993, meeting, please be advised that our currently committed schedule for completing our response to Generic Letter 89-10 is: Millstone Unit No. I the 1996 Refueling outage") Millstone Unit No. 2 the 1994 Refueling outage") Millstone Unit No. 3 the 1995 Refueling outage") As discussed during the meeting, if we believe that extensions to this schedule are appropriate and justified, we will be contacting you to discuss this option.
NNECO provides the following comments regarding the Millstone Unit No. 2 discussion and summary portion of this functional area: The initial SALP report (on page 29, paragraph 3) states: "Overall, . management of the Unit 2 steam operator replacement was strong and supported by generally excellent technical work."
We believe the underlined word should be " generator."
Also in the same paragraph, the second statement and third statement taken together may give a misleading impression since both items are separate.
We - suggest changing the second and third statements as follows: "Upon recognition, Unit 2 management took extensive actions to resolve a number of steam aenerator complex issues.
ligwever, for other issues, a lack of attention to detail and the handling of ... PDCRs."
We request that you consider the above comments in preparink the final SALP report.
, l I i , (1) In a letter dated December 15, 1989, NNEC0 provided our schedular commitment for completing the initial MOV Testing Program as prescribed in Generic Letter 89-10.
The above schedule is consistent with the commitments made in our response dated December 15, 1989.
- . . I . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 9 September 10, 1993 Functional Area: Safety Assessment / Quality Verification Board Recommendations: 1.
Perform an integrated, in-depth assessment of the Licensed Operation Training Programs for the site to identify and ensure comprehensive corrective actions in this area.
2.
Improve the timeliness of comprehensive corrective actions for identified program area deficiencies by improving priorities and ensure comprehensive corrective actions in this area.
!Lesponse: 1.
NNEC0 recognizes the need to maintain the quality and effectiveness of the Licensed Operator Training Programs at a high level. We believe that periodic internal and external assessments of these programs are key to identifying emerging weaknesses where attention should be directed.
To that end, NNEC0 has put in place measures to ensure that these assessments take place.
These measures were described at the July 1, 1993, Enforcement Conference relating to Licensed Operator Requalification Training (LORT) and include both self-assessment and independent Nuclear Quality and Assessment Services assessments.
Specifically, the procedure which governs the conduct of audits has been revised to require that audits of the operator training and requalification programs be conducted at least once every two years by the Nuclear Quality and Assessment Services.
Also, consistent with the implementation of the Performance Enhancement Program (PEP), Procedure NE0 2.38, Nuclear Assessment Program, has been developed which establishes the nuclear assessment program philosophy, structure, and process expectations.
This procedure establishes self-assessment as the cornerstone of the assessment program, and will require a documented self-assessment to be conducted at least annually.
To implement this requirement, Nuclear Training Department Directive-26, Sel f-Assessment, issued.
This directive provides the schedule and instructions to was ensure the depth and breadth necessary to determine how well each program fulfills its requirements.
A selected operator training program will be audited quarterly.
In response to the NRC Staff identification of inadequate audit frequency, audits were conducted of the Millstone Station and Haddam Neck Plant LORT programs as follows: i Millstone Unit No. 1 - March 1993 . Millstone Unit No. 2 - May 1993 .
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o U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 10 September 10, 1993 Millstone Unit No. 3 - February 1993 . Haddam Neck Plant - August 1993 . The NRC Staff noted in an Inspection Reportm that, "the team further noted that the audits completed (after the violation was identified for Unit 1) were thorough and in-depth.
The findings from the recent audits and assessments indicate that meaningful audits can be performed by the licensee."
We believe that the audits which recently have been completed in response to Staff concerns, coupled with the revisions to procedural requirements which govern the conduct of audits, are fully responsive to the Board recommendation in this area.
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We are pleased that the Board recognizes NNECO's sel f-assessment initiatives and various Action Plans that comprise the PEP.
We acknowledge and understand your comment about deferring comprehensive corrective actions to the PEP (see page 31 of the initial SALP report), and reTer you to our September 10, 1993, letter * for a summary of plans in this regard.
The SALP report also notes that improvements in oversight and handling of employee concerns and shutdown risk assessment, and increases in staff and resources for key areas were evident.
In order to achieve excellence in this functional area, we recognize that a strong and proactive management philosophy and commitment to support the discovery and prompt resolution of problems is essential. The approach being taken to address our performance in the application of self-assessment techniques is intended to improve various dimensions of this functional area and and lasting resul ts. While not all inclusive, the produce complete following actions are indicative of our commitment and accomplishments in this functional area during this SALP period, as well as areas of focus for the future.
As of May 1993, a vice president chairs the Nuclear Review Board . (NRB) for Millstone Unit Nos. 1, 2, and 3 and the Haddam Neck Plant.
The previous NRB chairman now serves as a vice chairman and one of his main responsibilities is to explore various ways to make the NRB more effective.
In addition, an INPO staff member serves as an advisor to the NRB.
(2) M. W. Hodges letter to J. F. Opeka, " Combined Team Inspection Report Nos. 50-245/93-80, 50-33/93-80, 50-423/90-80," dated June 7. 1993.
(3) J. to the U.S.
Nuclear Regul atory Commission, " Performance Enhancement Program-Engineering Integration," dated September 10, 1993.
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. . .. . U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 11 September 10, 1993 INPO has loaned an employee, Mr. G. Bregg to serve as the Site . Service Director for a one-to two-year period.
His experience and knowledge will help to maintain a broader view of industry perspective.
On September 12, 1993, Mr. J. M. Solymossy, an INP0 Reverse Loanee, . will be assuming the position of Director, Nuclear Quality and Assessment Services (formerly Nuclear Quality Services).
Mr. Solymossy will be reporting directly to Mr. J. F. Opeka.
NNEC0 empowered department managers to send their personnel to . various industry meetings and participate and serve on industry committees to broaden knowledge and awareness.
Inattention to detail and failure to follow procedures are also . being addressed by the Millstone STAR Program and the Millstone WOP.
NE0 Procedure 2.38, " Nuclear Assessment Program" has been developed . and establishes the nuclear assessment program philosophy, structure, and process expectation.
This procedure will require a documented self-assessment to be conducted at least annually.
NNECO has been involved in a number of programmatic assessments, such as a recently completed self-assessment audit of' the MOV . dated August 6,1993,(}) testing program at Mi lstone Unit No In a letter NNECO transmitted the results of the self-assessment.
A meeting with the NRC Staff has been scheduled for In September 28, to discuss the results of this self-assessment.
addition, we have recently completed another self-assessment in the NU.
Our area of reportability/ operability evaluation process at dialogue on that topic with the NRC will continue.
We continue to use the Combined Utility Assessment Team to verify the effectiveness of our QA program.
_ . ., As a part of our independent assessment efforts, we requested INPO , . to review our programs in the following areas i Training . - - Human Error Chemical Consumable Control ) - Outage Activities - System Engineering ) - - Work Control - Emergency Preparedness (4) J. letter to T. T. Martin, GL 89-10, "MOV Testing Program Audit Report," dated August 6, 1993.
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U.S. Nuclear Regulatory Commission B14603/ Attachment 1/Page 12 September 10, 1993 We have also made several enhancements to our PIR process.
We . expect that these enhancements will help to: reduce backlog - improve root cause assessment - - facilitate trending - improve review for similar prior occurrences One of the more recent and more important initi.atives under way that relates to the second Board recommendation stems from our ongoing reviews relating to operational performance of Millstone Unit No. 2.
While some initial actions have been taken, more will follow, and we will be communicating separately with you on this matter.
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. e ENCLOSURE 4
SALP BOARD REPORT REVISION SHEET e Revision #1: , e Page/Line: 21/28-30 Now Reads: A major purpose of the reorganization and added staffing was to improve off-site EP support to the State and local municipalities.
Should Read: The major purposes for the reorganization and added staffing were to enhance the on-site EP program as well as improve off-site EP support ' to the State and local municipalities.
Basis: The revised wording more clearly reflects the motives behind the substantial staff increases in the emergency preparedness staff.
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Revision #2: Page/Line: 29/10-12 Now Reads: Overall, management of the Unit 2 steam operator replacement was , strong and supported by generally excellent technical work. Upon recognition, Unit 2 took extensive actions to resolve a number of complex issues. A lack of attention to detail was evident... Should Read: Overall, management of the Unit 2 steam generator replacement was - strong and supported by generally excellent technical work. Upon l recognition, Unit 2 took extensive actions to resolve a number of complex issues related to the steam generator replacement project.
However, for other issues, a lack of attention to detail was evident... j
Basis: The revised wording corrects a typographical error as well as clarifies a , subsequent statement in the paragraph which could be misinterpreted.
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