IR 05000336/1985098
| ML20214X191 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/04/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207B611 | List: |
| References | |
| 50-336-85-98, NUDOCS 8612110006 | |
| Download: ML20214X191 (50) | |
Text
g- o U.S. NUCLEAR REGULATORY COPMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-336/85-98 NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 ASSESSMENT PERIOD: MARCH 1, 1985 - MAY 31, 1986 BOARD MEETING DATE: JULY 28, 1986
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SUMMARY OF RESULTS
. Facility Performance CATEGORY CATEGORY LAST PERIOD THIS PERIOD RECENT ()fUNCTIONALAREA (9/83-2/85) (3/85-5/86) TREND nt tions 1 1 Consistent Radi ogic Controls 2 3 Consistent Mainten & Modifications 1 1 Consistent Surveillan 1 1 Consistent Emergency Pre ess 1 1 Consistent Security & Safegu 1 1 Consistent Refueling / Outage Man ment 2 1 Consistent Assurance of Quality # 2 Consistent Training and Qualification 2 Consistent Effectiveness 1 Licensing Activities 1 1 Consistent
- - Not previously addressed as a separate are Overall Facility Evaluation _
With the exception of the Radiological Controls ea, facility perform-ance during this SALP period was consistently goo Safe and conserva-
tive plant operation has been evident. The operato and their manage-l ment performed well in response to the unplanned even such as the one
! trip and Hurricane Gloria. In general, the more diffi lt activities were handled proficiently. Among these were high radiat n exposure work planning and supervision, and minimizing the downtime invo ved in cor-recting security computer problem This licensee has implemented several important initiative Unit 2 example is the plant specific simulator which is now in operatio t
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6a III. SUMMARY OF RESULTS Facility Performance CATEGORY CATEGORY LAST PERIOD THIS PERIOD RECENT FUNCTIONAL AREA (9/83-2/85) (3/85-5/86) TREND Plant Operations 1 1 Consistent Radiological Controls 2 3 Consistent Maintenance & Modifications 1 1 Consistent Surveillance 1 1 Consistent Emergency Preparedness 1 1 Consistent Security.& Safeguards 1 1 Consistent Refueling /0utage Management 1 1 Consistent Assurance of Quality # 2 Consistent Training and Qualification # 2 Consistent Effectiveness l
1 Licensing Activities 1 1 Consistent
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! Overall Facility Evaluation With the exception of the Radiological Controls area, facility perform-ance during this SALP period was consistently good. Safe and conserva-tive plant operation has been evident. The operators and their manage-ment performed well in response to the unplanned events such as the one trip and Hurricane Gloria. In general, the more difficult activities <
were handled proficiently. Among these were high radiation exposure work planning and supervision, and minimizing the downtime involved in cor-i recting security computer problem This licensee has implemented several important initiatives. A Unit 2 3 example is the plant specific simulator which is now in operatio .
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Problems in the performance and management of the more routine activities led to a slip in performance in the Radiological Controls area. In that area, the slip generally resulted from the licensee's inability to cor-rect previously identified problem areas cc weaknesses such as radwaste shipping and radiation area access contro Overall, the problems identified were outweighed by the general strength and conservatism of the licensee's approach to nuclear sofety. Nonethe-less, significant improvement is needed to achieve across the board ex-cellenc .
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PERFORMANCE ANALYSIS l
' Plant Operations (655 hours0.00758 days <br />0.182 hours <br />0.00108 weeks <br />2.492275e-4 months <br />, 38%) Analysis This functional area encompasses operations, housekeeping, fire protection, staff performance, review committee activities, event reporting, and corrective actions. During the previous SALP, the unit was rated as Category 1. Strengths noted Mcluded professional operator performance and effective review committee performanc During this SALP period, one unplanned reactor trip from power oc-curred. That trip was due to a stuck open pressurizer spray valve, not attributable to operator erro In general, operator alertness reduced the challenges to safety grade equipmen Overall, operator performance was evaluated as professional and effective. Pre-evolution briefings of operators were evaluated as complete and well presented. Operators were found to be responsive to changing plant conditions. Routine control room transactions (including the approval of Radiation Work Permits, minor maintenance, and surveillance) were conducted carefully and smoothly. Procedures were observed to be readily available and in use. Extraneous read-ing material was not present. Controls were instituted to limit the number of personnel in the control roo Control room logs were up-to-date and sufficiently detailed to permit reconstruction of plant conditions and event Further, strong management emphasis on procedure adherence was indicated during PORC meetings and in-spector observations in the fiel Prior to Hurricane Gloria, management put the Emergency Response Organization into operation. The pl1nt operating staff performed well in placing the plant on natural circulation, loss of the switchyard, and the placement of TS required " Flood Level" protec-tions on service water pump "B". Challenges to operations during the hurricane included the loss of service water pumps and the loss of two off-site power lines. These were handled successfully. The unit was shut down prior to salt spray causing the loss of the switchyar Recovery actions were carefully accomplishe Plant management was observed to be in the plant frequently, and to be discussing activities with the operating staf Thorough knowledge of plant conditions was routinely exhibited by plant man-agement during daily management meetings and during discussions with the resident inspectors.
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The resident inspectors observed numerous meetings of the Plant Operations Review Committee (PORC). Questioning attitudes by PORC members were consistently evident. Inputs, both positive and nega-tive, were sought from all participants. Further analyses and re-submittals to PORC were required when questions were not resolved to the satisfaction of the PORC. Overall, the PORC meetings were evaluated as thorough and professional review sessions.
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The total number of licensed personnel at the end of the SALP period -
was 37. Operators are on a 6-shift schedule with an abundance of backup licensed individuals. Plant staff turnover for the SALP period was very low (less than 2%). At any time, three shifts are
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' on shift rotation, one is a relief shift, one shift is in training, and one shift is off. 'The training emphasis provided by this rota-tion is considered a licensee strengt No Unit 2 operator license examinations were conducted during this SALP perio The control room was generally clean and inspection of the interiors of control boards found only a very light layer of dust with no excessive buildup. Housekeeping was evaluated as generally good ~
in the plan An effective pipe and valve leakage control program
> was evident by a general lack of leakag During the SALP period, a fire occurred in a degreasing unit in the tool decontamination facility. The on-site fire brigade and local fire department responded and the fire was extinguished promptl No safety equipment was involved. To prevent recurrence, the de-
- greasing unit was permanently remove Management involvement and control of assuring quality in fire pro-
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tection was evident. The administrative control procedure contains well-defined provisions. Fire brigade training was assessed as aggressive and well defined. Fire protection audits were generally complete and audit findings were resolved in a timely and satisfac-tury manner. Fire protection staffing was considered adequate. Fire protection activities were well documented. The responsibility for implementing the fire protection program is shared by various de- ~
partments. No dedicated individual (fire protection engineer or coordinator) is assigned to coordinate the different fire protection activities in the plant. While, with three units operating on site, it may be appropriate to consider assigning a full time onsite fire l protection coordinator, the lack of one was not found to result in any fire protection inadequacies.
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LERs are routinely reviewed by Region I. In addition, a sample of LERs was evaluated by the NRC Office for Analysis and Evaluation of Operational Data (AEOD) and was found satisfactory. A strong point noted by AE0D is that information was provided on operator
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actions that affected the course of the event and on automatic and safety system responses. Weaknesses identified included a lack of assessment of the potential safety consequences under other condi-tions and a lack of identification of failed components. The former relates to the thoroughness of assessment of potential consequences; the latter to the ability of other facilities to readily correct similar problem In summary, the licensee's operations functions were generally well performe Operator response to changing plant conditions were con-sidered appropriate, and operator performance was considered pro-fessional and competen . Conclusion Rating: Category Trend: Consisten . Board Recommendation:
Licensee: Non NRC: Non .
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11 Radiological Controls (227 hours0.00263 days <br />0.0631 hours <br />3.753307e-4 weeks <br />8.63735e-5 months <br />, 15%) Analysis
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The previous SALP rating in this area was Category 2. Although the licensee's radiation protection program was defined by generally good policies and procedures, there were deficiencies noted in the implementation of procedure changes and in the shipment of radio-active materials to Barnwell, South Carolin During this SALP period, radiation protection was considered to be defined by adequate procedures and policies. Contamination was well-controlle The extent of contaminated areas was kept to a minimum, reflecting a station commitment towards that en The licensee's program for surveying and posting radiological areas was generally well implemented. Surveys were performed as required to evaluate radiological condition Survey information was avail-able at the control point and status boards were frequently' update However, NRC inspections of Unit 1 in June 1985 and January 1986 identified instances where doors posted "High Radiation Area - This ,
Door Must Be Locked At All Times," were left open or where the lock had been defeated. The licensee's implementation of routine sur-l veillance of High Radiation Area control failed to identify these instance Corrective actions were shown to be inadequate by the January 1986 identification of recurrent instance Labeling of radioactive material was generally adequate. In one isolated instance, however, a problem did develop from a failure to remove radioactive material labeling from clean structural steel used during the Unit 2 outage before it left the site. Although the material was not radioactive, it was noted by members of the
general public at a scrapyard and created unnecessary concer Several high-exposure jobs were completed and effectively controlled during this assessment period. During the Unit 1 outage, the work included NDE and weld overlay work on the recirculation piping and .
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jet pump instrument nozzles. The ALARA group ongoing review of jobs in progress included review of exposure status reports and the per-
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formance of periodic worksite audits to insure specified controls were being implemented. A potential weakness was noted in the Unit
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1 ALARA staff's reliance on the HELPORE exposure tracking computer system. Due to computer problems, the Unit 1 ALARA group was not aware of actual versus goal exposure overruns on two separate jobs until ten days into the outage. Alternate exposure tracking meas-ures should be considered when computer support is not timely for relatively high exposure activitie Several deficiencies were noted in the Unit 1 outage control of routine radiological activities. Examples were identified in which the radiological controls required by the Radiation Work Permit (RWP)
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were modified by a HP technician in the field, without supervisory i review or documentation of the change on the RWP. This contributed l to worker confusion and an excessive reliance on HP verbal instruc- '
tion. In one instance, the requirement for respiratory protection was dropped by an in-the-field, unreviewed change; this resulted ,
in the unplanned uptake of radioactive material by a worker. An !
unrelated unplanned uptake by two workers performing valve repacking resulted from a failure to adequately assess the work conditions in the RWP. Neither the RWP nor the pre-job briefing recognized !
the increased potential for personnel contamination resulting from the worker's position directly underneath the contaminated valve Additional lapses in control occurred when contractor workers vio-lated station procedures by decontaminating themselves and leaving the site without notifying the licensee's HP organization. This prevented HP from promptly locating the source and cause of con-tamination and taking corrective measures. Action was taken, later, to reinstruct the workers and improve the posting of contaminated area The Unit 2 outage work included significant steam generator tube inspection and sleeving / plugging activities. The ALARA group
, planned and implemented numerous dose reduction methods, including mockup training, temporary shielding, use of remotely-operated NDE equipment, and steam generator decontamination. Of particular note was the dose expenditure savings in the steam generator nozzle dam installation. Licensee development of specialized training and modifications to the nozzle dams made in response to " lessons learned" during the previous outage resulted in a dose expenditure of less than 25% of the previous outage expenditure. Despite these efforts, the collective occupational radiation exposure during the 1985 Unit 2 outages exceeded 1650 man-rem. This indicates a need to reduce the collective radiation exposur The licensee was suc-cessful in promulgating ALARA concepts and philosophy within the radiological controls group. Further reduction in the collective occupational exposure may require more active participation of other licensee organizations and expanding new ALARA initiatives to plant chemistry, maintenance, and operation The preceding analysis notes strong control over high exposure jobs but multiple lapses in routine radiation controls. The latter con-dition is considered to have occurred enough to warrant specific corrective action. In this regard, the assurance of individual worker endorsement of and adherence to radiation protection controls is at least as important as assuring that health physics specialists do not allow improper deviation from previously established controls or good practice '
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A generally ineffective corrective action program in radwaste pre-Daration, packaging and shipping activities was evident. During the previous assessment period, 10 discrepant shipments had been identified and the previous SALP noted that the licensee had not effected adequate corrective action. During this assessment period, the special NRC appraisal brought specific programmatic weaknesses to the licensee's attention. Reviews of radwaste preparation, packaging and shipping by NRC specialists and Agreement State Rep-resentatives identified multiple violations indicative of program-matic breakdow In March 1985, external radiation levels on a licensee shipment exceeded 200 millires/ hour on a package shipped ,
on an open, flatbed tractor trailer. This resulted in a Severity Level 3 violation. In March 1986, a licensee radioactive shipping package was mislabeled and the vehicle carrying the shipment was not placarded. The licensee did not have copies of drawings and other documents referenced in Certificates of Compliance for two shipment Procedures for solidification of radwaste did not pro-vide specific detailed information to assure that the radwastes were properly solidified. The licensee's Quality Control program did not assure compliance with 10 CFR 61.56. Receipt inspections of soli-dification equipment were not performed as required by the licen-see's Quality Assurance procedure Radwaste shipping personnel were not adequately traine Sufficient management involvement in and control over assuring quality in packaging and shipping activities was not evident. Pro-cedures for preparing and packaging radioactive materials for ship-ment lacked step-by-step instructions in the degree of detail necessary to perform the activity. Acceptance criteria against which success or failure of the activity could be judged were lack-in Lack of management oversight of packaging and shipping acti-vities was made evident by inadequate supervision of activities during the absence of the Radioactive Material Supervisor, by an inactive Radwaste Review Committee, and by failure of the Radiolo-gical Services Supervisor to examine the radwaste shipping records and logs as required by licensee procedures. In addition, radwaste shipment records were no' readily available for revie The application of the licensee's QA program to radwaste packaging and shipping was found to be ineffective. QA audits lacked techni-
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l cal expertise in shipping-related areas. Corporate QA implementing procedures did not reflect transport packages as a Category I item as established in the licensee's QA Topical Report. The QC program
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was limited in scope with regard to 10 CFR 61.55 and 61.56. QA monitoring of radwaste packaging / shipping activities was infrequen No effluent release limits were exceeded. Nonetheless, occasional lack of licensee attention to detail was noted during reviews of the effluent control program. QA audits of the readiness to imple-ment Technical Specification changes concerning effluent monitoring
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were not performed prior to the effective date of those change Administrative control procedures identifying periodic surveillance tests were not updated to reflect the changes. Station personnel were unable to discuss the scope of effluent monitor calibratio A review of the licensee's environmental monitoring progrem immedi-ately prior to the assessment period indicated the program was generally satisfactor This analysis addresses items which resulted in the issuance of a total of eight NRC violations. One of these was a Severity Level 3 vi'olation, but no civil penalty was issued by the NR In conclusion, the licensee's system for the identification and correction of radiological deficiencies has shown a decline since the previous assessment period. Several licensee initiatives were taken in the ALARA program; however, the collective occupational radiation exposure remains high in comparison to similar power reactors. A recurrent problem with High Radiation Area access con-trol and continuing repetitive violations indicative of programmatic breakdown in the radioactive waste packaging and shipping areas were noted. Licensee corrective actions in the transportation area have been ineffective. A lack of appropriate management involvement is indicate . Conclusion:
Rating: Category Trend: Consisten . Board Recommendation:
Licensee: Improve radiation worker training to stress worker aware-ness of and compliance with Health Physics procedure Improve the effectiveness of the ALARA progra Strengthen assurance of quality in the transportation are NRC: Increased inspection effort to assess adequacy of program improvements.
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C. Maintenance and Modifications (138 hours0.0016 days <br />0.0383 hours <br />2.281746e-4 weeks <br />5.2509e-5 months <br />, 8%) Analysis The previous SALP rated maintenance as Category 1. Positive find-ings were made on machinery history, working knowledge of techni-cians, supervisors and QA inspectors, post-maintenance and post-modification testing, programs to extend the life of the steam generators and improve charging pump performance, the corporate-wide maintenance management system, procedural compliance, safety, work practices, and documentation. The equipment classification program, vendor interfaces and QA involvement in post-maintenance testing were assessed as goo The licensee performed some difficult maintenance work during this SALP period. Steam Generator (SG) head lancing and tube sleeving (also addressed in the Outage Management functional area) along with changeout of the letdown prefilter needed and received considerable preplanning by the plant staff. Other maintenance work, such as the repair of the transfer tube gate valve and minor oil leaks on the "A" diesel generator, revealed a high level of system knowledge on the part of the maintenance staff. These repairs were supported by engineering, purchasing, and other support groups, and all levels of management. Detailed involvement of quality control personnel was note Examples of thorough QC overview were the careful checking on material introduced into the SGs and meticulous step-by-step identification of completion of tube sleeving step Licensee review of design changes was generally sound, with thorough approaches used during management revie An exception was failure to properly review and test a design change that replaced the pres-surizer spray valve controllers and cross-wired the valves to the new controllers. On July 15, 1985, when normal pressure control was restored during initial operation after this change, a stuck open spray valve caused an unplanned scram on low pressure (the only unplanned scram during the SALP period). This trip was evaluated as not being due to the design change, however.
l Late in the SALP period, the fuel pool rack expansion modification l
I occurred. The changeover was well coordinated with the operations department in regard to moving fuel. To support this modification, j
a separate team was formed. Procedures, drawings, and scheduling t were carefully detailed. Scheduling was appropriate. Procedures used for fuel verification and movement were conservative and tech-nically sound. The new high density racks were in place at the end of the SALP period. The management of this project while maintain-ing the unit on-line showed effective planning and assignment of priorities.
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Inspector discussions with maintenance personnel revealed a high level of knowledge about current maintenance activities. Special-ized t' raining utilizing mock-ups and providing hands-on orientation were very effective. An example was the steam generator head
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lancing and sleeving evolution A special team inspection was performed to assess the environmental qualification (EQ) of electric equipment. The team noted evidence of prior licensee planning and assignment of priorities; and well stated, controlled, and explicit procedures for EQ activitie Policies were also well stated, disseminated, and understandabl Licensee Udits were complete, timely, and thorough. EQ records
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were complete, generally very well maintained, and available. Cor-porate management was involved in and knowledgeable of the progra The licensee exhibited conservatism and reached decisions which were thorough, technically sound, and timely. They established a 24-hour beeper system for calling EQ personnel to resolve maintenance prob-lem The licensee was somewhat slow in dealing with IE Information No-tices on implementation of the EQ program. Tney did, however, make commitments for positive resolution of the associated concern Deadlines were then met with technically sound and thorough resolu-tions. Staff positions were identified and authorities and re-sponsibilities for EQ were well defined from the Senior Vice Presi-dent level dow Staffing was considered ample. Consultants specializing in EQ were used, but only under licensee directio The training program was well defined and implemented for all in-t volved personnel. Site personnel training was extensive: all per-sonnel interviewed had an excellent awareness of their role in the EQ program, and displayed a positive attitude. The inspection team
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concluded that this was a well-implemented EQ program.
! No violations were identified in this functional area during this SALP perio In summary, maintenance programs are effective overall. Outstanding i work was performed, and the EQ program was well-implemente . Conclusion Rating: Category 1.
Trend: Consisten . Recommendations:
Licensee: None.
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D. Surveillance (196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br />, 11.4%) Analysis Surveillance was rated Category 1 during the last SALP. Failure to perform surveillance of fire detection instruments (a violation)
and the low level of QA oversight over key activities such as con-tainment leak rate testing and post-refueling start-up testing were the only concerns identifie Surveillance activities were observed by the resident inspectors throughout this SALP period. In addition, specialist inspectors observed the Inservice Inspection (ISI) Program, the containment leak rate program, and other surveillance The licensee's overall surveillance program continues to be compre-hensive. During the outage, management, engineering, and QA in-volvement in the eddy current testing (ECT) of the steam generators was evaluated as excellent. QA and the Plant Operating Review Com-mittee were actively involved in the examination of tube In ad-dition, appropriate control of the inservice inspection program was noted, including ultrasonic examinations of piping welds, completion of the 10 year containment tendon surveillance, evaluation and re-placement of reactor vessel irradiation specimens, and pump and valve testin Surveillance tests during operation, such as calibration of nuclear instruments, power range safety channel and delta-temperature power
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channel calibration, were routinely performed in an acceptable man-ner. Four licensee event reports (LERs) were submitted involving partial actuation of emergency safety features during the refueling outage. Three of these events involved procedural inadequacie Appropriate procedure changes were mad The licensee implemented comprehensive and technically sound local leak rate test (LLRT) and containment integrated leak rate test (CILRT) program But there was a lapse in calibration, resulting in a violation, for the LLRT portion. There was also a failure to follow the test procedure for leak test of the containment purge exhaust valves (improper use of flow test box). This resulted in a second violation. QA personnel were very knowledgeable of the test However, there was a lack of QA/QC coverage of the end of test flow verification during depressurization of containmen This is a minor ite Operational surveillance training consists primarily of checkouts on specific surveillances. That training has been noted by the resident inspectors to be thorough and rigorou _. . _ .
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Overall, the relatively few problems noted with the many surveil-lances conducted shows that the licensee has a sound and successful surveillance progra . Conclusion Rating: Category Trend: Consisten ' Board Recommendation Licensee: Non NRC Non .
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i Emergency Preparedness (84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />, 5%) Analysis During the previous SALP, the licensee was rated as Category 2 (Improving) in Emergency Preparedness (EP). This rating was based upon the progress that had been made in correcting previously iden-tified weaknesses, including replacement of the small temporary TSC with a new permanent facility and improving the EP Training Progra This progress was readdressed during the Unit 3 licensing process and subsequent evaluation of the adequacy and effectiveness of the site EP progra As the Emergency Plan, procedures, facilities, and key response personnel are common for the site, this SALP reflects relevant per-formance at Millstone 2 and 3 as representative of performance on Unit 1. During this assessment period, the NRC review effort in-cluded one inspection at Unit 2 to observe the Annual EP exercis The other major EP inspection effort involved conducting the EP Im-plementation Appraisal for Unit 3 (and the follow-up of issues identified during that appraisal) in preparation for licensin The appraisal covered the areas of facilities and equipment, or-ganization, procedures, and training. The emergency organization which includes corporate response personnel is acceptable. The Site Plan provides for augmentation of key staff personnel within 30 minutes as recommended in the staffing goal The training program has shown improvement over the past two years; however, some draft procedures on testing requirements (identified during inspection in February 1984) were still in draft form during the EP follow-up inspection. These procedures implement the stand-ards for hands-on/ practical training for emergency response. (The associated apparent lack of management attention was also identified in the current SALP for Unit 3.)
In general, the licensee has been responsive to NRC initiative In addition to the " official" November 1985 exercise, two drills were observed demonstrating Unit 3 specific features as part of the EP Implementation. Licensee performance in the exercise and the drills reflected a high level of training and preparation, reflect-ing the recent a.anagement attention to this are The licensee's preparation for the appraisal was generally excellent, but not all
of the currently accepted guidance concerning Emergency Plans had i been incorporated. A meeting to discuss the issues in Region I resulted in implementation of appropriate changes or incorporation I of better descriptions of Plan features in the Emergency Plan.
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The emergency response capability was also observed during the pass-age of Hurricane Gloria in September 1985. An Unusual Event was conservatively declared at the sit High winds caused damage to some system The meteorological monitoring capability became com-pletely inoperable. No onsite backup was available. The licensee plans to install a system to provide backup / supplemental meteorolo-gical monitoring capability on site. Licensee personnel partially staffed emergency response facilities, maintained a ready posture, and tracked the storm system. Afterwards, the licensee addressed the problems and prepared appropriate corrective action Northeast Utilities maintains an excellent relationship with the State of Connecticut and local municipalities, as evidenced by the cooperation demonstrated during exercise Overall, the licensee has a sound emergency preparedness progra . Conclusion Rating: Category Trend: Consistent Board Recommendation Licensee: Reassess effectiveness of commitment tracking syste NRC: None.
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s F. Security and Safeguards (68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br />, 4%)
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, Analysis
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The previous SALP rating was a Category 1. Strengths were manage-ment attention to the security program, a comprehensive corporate security audit program, security staffing, and event reporting.
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Minor problems were report content (insufficient details in a few reports) and a potential training weaknes Since security is a site program, this SALP addressed relevant findings at all three Millstone plants. Two routine, unannounced physical security inspections and one routine, unannounced material
control and accounting inspection were performed by region-based inspectors during this assessment period. Routine resident inspec-l tions continued throughout the period.
One Severity Level III violation, with no civil penalty assessed, was' cited for the unauthorized introduction of a firearm onsit This resulted from an oversight by a member of the security forc The violation was detected by another member of the security force
and was promptly and factually reported to the NRC. The short term corrective actions were prompt and effective and the long term ac-tions were comprehensive and innovativ During this period, the licensee installed and tested equipment and systems at Unit 3 and integrated the Unit 3 program into the program at Units 1 and 2. While that effort consumed considerable resources,
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the licensee was able to continue a highly effective security pro-gram at Units 1 and 2. This was accomplished through comprehensive
planning, effective coordination and appropriate allocation of re-
- sources. That was reflective of close management oversight and in-A volvement, well stated policies and procedures, effective licensee and contractor supervision, and an effective training and qualifi-cation progra Management oversight and involvement was evident in the licensee's decision to restructure its licensee and contractor security organi-zations as it became apparent that modifications were needed to ac-l Program implementation was separated into an
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operational element and a support element. Additional supervisory j and technical positions were incorporated. This resulted largely
- from a comprehensive task analysis, initiated by corporate manage-ment, of both the licensee and contract organizations by a group
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of licensee corporate, management, site management, and contractor ,
management representative That initiative was evidence of the licensee's commitment to a high quality security progra !
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The licensee was prompt and comprehensive in responding to two potential weaknesses pointed out by NRC. In both cases, the licen-see upgraded the commitment in their NRC-approved plan, after de-veloping and applying strengthened criteri Personnel in the security organizations were professional and cour-teous in their dealings with NRC personne The licensee's comprehensive security audit program includes planned audits to meet NRC requirements and a licensee initiative to conduct periodically, without notice, audits of program implementatio Auditors are well qualified and professionally carry out the audit Audit findings and recommendations are clearly documented, appro-priately disseminated, and promptly resolved. The audit program is also complemented by frequent corporate staff assistance visits to discuss potential problems, evaluate proposed program modifica-tions, and exchange information of general interes The licensee submitted a total of 16 Security Event Reports (SERs).
Nine of these identified security computer problems. Due to an ef-fective and dedicated security equipment repair group and a computer services group, the cumulative downtime during the entire assessment period was only about five hours. Three SERs involved defective equipment found during surveillance testing. The licensee has recognized the need for and has initiated planning for replacement of aging equipment to avoid such problems in the future. Three other SERs involved isolated errors by security force member SERs were timely and contained the detailed information essential for NRC assessment. Compensatory actions for all events were found to be prompt and appropriate to the circumstances. In two cases involving personnel errors, however, the NRC had to contact the licensee for more detail. The licensee's program for identifying and reporting security events is considered adequate but could be strengthened by providing greater detail (e.g., time elements and
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root cause). This concern about SERs is mino :
Staffing of all aspects of the licensee's security program is ade-quate and effective. Experience and expertise at both the corporate and onsite levels of management are apparent and are complemented by strong technical support from a security systems project engineer, a computer services group, and a dedicated security instrumentation and calibration (repair) group. Additionally, the licensee's security contractor recently appointed a permanent administrator to oversee the performance of its organization, which substantially increased in size with the inclusion of Unit 3 into the program.
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The allocation of sufficient administrative, technical and logisti-cal resources is further evidence of management's commitment to a quality security progra The effectiveness of training of the security force is adequate and improving, as evidenced by few personnel errors occurring during the period. The licensee was prompt to respond to training weak-nesses identified as a result of performance testing of the security force by NRC. New training program criteria were developed and im-plemented to overcome the shortcomings. In a licensee initiative, significant emphasis is being placed on alarm station operator and response team drill training. This emphasis is targeted towards enhancing communications and professional skills among members of the force and was initiated by the licensee as a result of recog-nizing a possible weakness. The licensee's actions to continuously improve professional performance skills and communications via the use of organized drills enhances the capability of the entire security organizatio Two Security Plan changes were submitted to the NRC during this rating period. Both were indicative of thorough knowledge of NRC program objectives. The changes were adequately summarized, clear, and appropriately marked for clarity during NRC revie With regard to material control and accounting practices, the lic-ensee was in compliance with NRC requirement Procedures and practices were adequate for the control of special nuclear materia Records and reports were complete, well maintained, and availabl Overall program performance was goo In summary, licensee performance in the security and safeguards area, including the controlling programs, management oversight, staffing and training, and reporting, was very goo . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensee: Non NRC: Non _ __ ._
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G. Refueling and Outage Management (196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br />, 12%) Analysis Previous licensee performance in this area was rated Category At the beginning of this assessment period, the licensee was in a refueling / maintenance outage. The outage was extended due to ex-tensive eddy current testing of steam generator "U" tubes and manual sleeving, inspection of the core support barrel removal area, ex-tensive fuel inspection, and main turbine generator rotor rewindin Refueling and outage activities were reviewed by the resident and region-based inspectors, including outage coordination, refueling operations, steam generator "U" tube cleaning (secondary side), and eddy current testing of steam generators (SGs).
The licensee's outage organization included twenty-four hour cover-age by an outage coordinator and senior licensed personnel on all shifts, including shift supervisor staff assistants as Containment Coordinators. Dedicated department coordinators for I&C, operations,
'
maintenance, and Betterment Engineering were assigned. Routine, twice daily management meetings contributed to effective control of the outage schedule and to prompt problem identificatio During the outage, critical activities that were not meeting sched-ules were generally identified early. Corrective actions were ap-plied in the form of either more manpower, additional shifts, or activity changes. The use of the computerized maintenance system to plan boundaries, tag controls, and monitor job completion (in-cluding retest) contributed to effective tracking of major and minor l repairs and change Major outage efforts involved steam generator nozzle dam installa-tion and later removal, secondary side tube lancing, chemical cleaning, ultrasonic testing (UT), sleeving approximately 3000 tubes,
'
and plugging 63 tubes. Effective steam generator tube repairs re-suited in minimum primary to secondary leakage during subsequent plant operatio *
l In response to problems noted during the last SALP, the licensee
! performed extensive training for individuals who placed the steam j generator nozzle dams. The training included a movie on past prob-less and how they were corrected, improvements in nozzle dams, in-stallation and removal procedures, and injured worker rescue. The
,
l
,
use of a new mockup for SG ECT aided in minimizing exposures. NRC observation of nozzle dam installation verified that efforts were well coordinated and demonstrated effective trainin .
.
Post-outage pre-critical, low power physics, and power ascension tests were well coordinated and were performed with active involve-ment of QA/Q Management involvement in all outage phases obviously aided in re-solution of problems encountered and in recognition of areas that require additional attentio After Hurricane Gloria, an additional outage was taken to repair all four reactor coolant pump motors and replace pump seals. The outage received close management supervision. The licensee also conducted a seven-day turbine inspection outage in May 1986 in re-sponse to GE recommendation In response to NRC concern, the licensee initiated extensive PDCR reviews to identify problems'such as the cross-wired pressurizer spray valves during pre-outage meetings for the September 1986 out-ag In addition, because estimating job exposure has been hampered due to lack of detail on automated work orders (AW0s), management has initiated corrective actions by committing to early review of AW0 In summary, outage activities were effectively controlle . Conclusion Rating: Category Trend: Consisten . Board Recommendation:
Licensee: Non NRC: Non .. - - _ -. - _ .. . ...
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26 l
' Assurance of Quality Analysis During this assessment period, Assurance of Quality is being consi-dered as a separate functional area. The various aspects of quality have been considered and discussed as an integral part of each
>
functional area and the respective inspection hours are included
,
in each one. Consequently, this discussion is a synopsis of the assessments relating to quality work conducted in other area Licensee management emphasizes proper performance on the first try and that quality is each individual's jo Therefore, the QA or-ganization is not looked upon as the central control for quality; line managen.ent i Operator performance was assessed as professional and competent, and the pass rate of candidates for Unit 2 operator licenses was good. No Unit 2 reactor scram during this 15-month SALP period was attributed to personnel erro Facility managers actively tour the
'
plant, and management communication with the operators has been evident. Plant Operations Review Committee evaluations were evalu-ated as thorough and professional. Daily licensee management meet-ings and discussions with the resident inspectors showed thorough
! knowledge of plant conditions. These factors are all indicators
- of effective assurance of quality in plant operatio Regular QA/QC department monitoring of the performance of operating procedures and activities was not noted. NRC checks found, however,
! careful adherence to operating procedures and effective line manage-
- ment overview of this aspect.
,
Surveillance procedures were found to be of generally high quality.
! Rigorous checkouts were performed to qualify individuals in specific i surveillances. There is a strong in-service inspection progra QC was observed to be routinely involved in observing maintenance i l
and surveillance on numerous occasions; including Unit I recircula-
'
tion pip: repair work, Unit 2 spent fuel pool rerack modifications, Unit 2 service water pipe weld repairs, and both units main turbine insDeCtion The associated procedures were adhered to and were evaluated as valid and meaningful checks of activity performanc Good performance was noted in addressing the potential applicability of standby liquid control system problems at enother facility. How- .
ever, a need to better assure the quality performance of aging
! equipment was identified. In this regard, the licensee's perform-i ance is considered effective once corrective actions are undertaken, with a need for better preventive upgrading of important components before failures occur. Alto, the licensee needs to improve post-
-. .__ _ _ _ ____.____ _ _ _ _ _ _ _ _ . _ _ . _ _ . . _ _ _ _ _ _
,
maintenance testing to prevent instances such as control rod scrams occurring at power because earlier post-maintenance testing did not assure operabilit Design change control including appropriate post-modification test-ing was the subject of a management meeting during the SALP perio The specific issue in this case was the Unit 2 drawing errors re-sulting in wiring reversal of pressurizer spray controllers and failure to identify this wiring error during subsequent testin This design control and testing inadequacy was an isolated case:
licensee review of all 65 plant design changes implemented during the preceding refueling outage revealed no other problems. In ad-dition, no other cases of post-modification testing inadequacies were found and appropriate corrective actions were taken. Thus, design change control was generally soun Aggressive corrective actions prevented security computer problems from causing significant computer down time. There was a licensee-initiated restructuring of the security program. Security event reports were conservatively generated. There was extensive security drilling and detailed knowledge of security program objective The undetected entry of a firearm onsite was identified by the lic-ensee and properly reporte Sound corrective actions were applie In licensing activities, this performance appraisal found licensee competence and effective resolution of safety issues. Submittals to the NRC were generally timely and of good quality. The Millstone 1 probabilistic safety study was noted as being a valuable decision making tool for assessing operating risk and prioritizing improve-ment High exposure activities were effectively controlled but weaknesses were evident in the application of routine radiation protection -
controls. Radiation worker support of those controls was found lacking. In radwaste shipping, ineffective program performance and management were identified. Because effective corrective actions were not applied after previous identification of significant in-adequacies, radwaste shipping stands out as an example of inadequate assurance of quality.
!
In summary, the licensee's basically sound approach to assuring quality has been effective in most areas. There is a need for bet-ter assurance of proper performance of aging equipment. Better worker adherence to and endorsement of routine radiation protection controls are needed. Further, radwaste shipping has significant deficiencies which were not corrected after being identifie . . . -. - - -- . -- . . . .... -
,
,- .
r Conclusion:
Rating: Category Trend: Consisten . Board Recommendations Licensee: Non NRC: None.
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I. Training and Qualification Effectiveness
. Analysis .
'
During this assessment period, Training and Qualification Effective-ness is being considered as a separate 1 functional area for the first time. The various' aspects,of this functional area have been con-sidered and discussed as an integral part of cther functional areas and the respective inspection hours have been in-luded in each on Consequently,-this discussion is a synopsis of the assessments re-lated to training conducted ill other areas. Training' effectiveness has been measured primarily by the observed. performance of licensee personnel and, to a lesser degree, as'a review of program adequac The discussion below addresses three principle areas: licensed operator training,-non-licensed staff training, and the status of INP0 training accreditatio At the end of this SALP period, no training programs had been.ac-credited by INP0. The licensee has reassessed the program goals and milestones and expects to be accredited in all operator, staff, and technician programs-by the end of 198 The licensee has recently completed installation of the Unit simu-lator Although post-installation testing and upgrading is con-
'tinuing, the training department has declared the machines " ready for training." Requalification training utilizing the simulators had begu The next NRC licensing exams are to be conducted using the simulators. The licensee's commitment to simulator training is one measure of their resolve to keep improving staff performanc During this SALP period, the training center staff was reorganized and increased in size. Training has been increased, and the simu-lators are used.to train managers as well as operator Licensing Group personnel receive training in plant systems, QA, FSAR and Technical Specification changes, the nuclear safety ethic, and unresolved safety issues. They are rotated to the site during outages to provide insight into plant activities. These efforts are cnnsidered a licensea strength.'
During this SALP, fire brigade training and operator emergency re-sponse training were evaluated as very good. Security training was found adequate, with few security personnel errors noted. Security training weaknesses were noted to be aggressively pursued, and ex-tensive use of security drills was noted as a strong point. Emer-gency preparedness and security force training is improving, al-though procedures on testing requirements for emergency response training and security response team drill training were weak at the time of each inspectio .
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Little evidence of appropriate training of radwaste shipping per-sonnel was found, and lack of such training is considered a signi-ficant weakness in radiological control In summary, both licensed and non-licensed staff training was found to be good overal Improvements were noted in operator training capabilities through addition of the simulator There is a general strength in training, except for radwaste shipping trainin . Conclusion Rating: Category '
Trend: Consisten . Board Recommendation Licensee: Non NRC: Non .
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J. Licensing Activities' Analysis This area was rated Category 1 during the last SALP. However, a concern was identified for recurrent response timeliness problem During this SALP period, the licensee's management and staff have demonstrated sound technical understanding of issues involving lic-ensing actions. For the majority of these, the licensee's submit-tals were technically sound, thorough, well referenced, and they generally exhibited safety conservatism. However, additional atten-tion should be focused on the quality of submittals so as to mini-mize time necessary for review. An example of a submittal causing expenditure of excessive staff time is Appendix R. Currently, after many years of deliberation, Appendix R exemptions for Millstone Unit 2 have all been approved, but the licensee intends to modify these and add new ones. These modifications and additions could have been foreseen earlier and incorporated into prior submittals, thus avoid-ing some of the additional f'uture expenditure of staff hours. A contrasting example is the rerack of the Spent Fuel Pool. Here a technically sound and thorough approach was take Conference calls with licensee personnel clearly showed that the licensee'had con-servatively calculated the decay heat loads and provided detailed, technically acceptable, and complete information. Nonetheless, greater emphasis should be added to ensure that submittals are con-sistently of high quality. The technical quality is consistently present but administrative errors in and revisions to the original submittals could be reduce Responsiveness to NRC initiatives has imp.4oved significantl How-ever, further improvements are still possible. An issue that is i
taking excessive time for response is Generic Letter 83-37. The
! licensee, in a July 25, 1984 letter, planned to submit Technical
'
Specifications for items such as Noble Gas Effluent Monitors (II.F.1.1), Containment High Range Radiation Monitor (II.F.1.3),
! and the Containment Pressure Monitor (II.F.1.4). 10 date, these specifications have not been received. Another issue for which an excessive amount of time is being taken for response is our request for additional information on Emergency Response Capability Con-formance to Regulatory Guide 1.97. However, these are exceptions rather than the rule.
! Significant issues were completed during this rating period such l
as the Radiological Effluent Technical Specifications and Appendix l
R exemption requests. The Safety Evaluation for the rerack of the Spent Fuel Pool was accomplished in a very efficient manner due, in part, to the quality of the licensee's submittal and the re-sponsiveness to NRC question The Licensing Staff interfaces with l
_ _ _ _ _ _ _
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32 l l
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the Engineering Department and the Operations Personnel at the plant i in a very efficient manner so that the proper people are available
'
to discuss issue Members of the Licensing Group have received training in the fol-lowing areas:
--
Quality Assuranc Departmental Procedures for processing Technical Specification Changes and FSAR Updates
--
Nuclear Safety Ethics
--
Professional Development Courses and Seminars
--
Unresolved Safety Issues and Seminars
--
Outside Licensing Familiarization Training and Seminars In addition, Licensing Group personnel are rotated to the site during refueling outages to provide additional insight into the operations of the facilit Personnel from both Licensing and Engineering are participating in various industry groups such as Station Blackout, Fire Protection, EQ, and IEEE. All the above are considered to be a positive contribution to the effective performance of the Licens-ing Grou Overall, the licensee's licensing activities are performed by a well-staffed and well-trained group performing an overall efficient oper-ation. The licensee has excellent capability to respond to NRC in-itiatives and has demonstrated this capability for the vast majority of item . Conclusion Rating: Category Trend: Consistent Board Recommendations Licensee: None NRC: None.
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V. SUPPORTING DATA AND SUMMARIES Investigation and Allegation Review There were three allegations during this SALP period. One was that two outage workers were convicted felons, the second that drug screening was selective instead of random, and the third that some Combustion Engi-neering personnel were unqualified. Review identified no unacceptable conditions and the allegations were close Also, an allegation initially attributed to Millstone 1 turned out to be a Millstone 2 item. It involved radioactive material markings on metal in a local junkyard. The metal was not radioactive. Its markings had not been removed as they should have been. The matter was identified to the licensee for corrective action and the allegation was close Escalated Enforcement Actions Civil Penalties There were no civil penalties issued during this assessment perio . Orders There were no orders issued during this assessment perio . Confirmatory Action Letters There were no confirmatory action letters issued during this SALP perio Management Conferences On March 25, 1985, an enforcement conference was held at the NRC Region I office to discuss radioactive waste transportation problem . On July 18, 1985, a Management Meeting was held at the NRC Region l
.
I office to discuss design changes made during the Millstone 2 re-fueling / maintenance outag . On June 18, 1986, after the SALP period, an enforcement conference l was held at the NRC Region I office to discuss repetitive radwaste transportation problems.
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D. Licensee Event Reports Tabular Listing Type of Events: Personnel Errors 7 Design / Man./Const./ Install 6 External Cause 3 Defective Procedure 2 Compeaent Failure 14 Other _1 Total 33 Causal Analysis (Review Period 3/1/85 - 5/31/86)
Unit 2 LERs 85-02, 85-05, 85-06, and 85-07 involved ESF actuations during surveillance testing while shutdow Unit 1 LERs 85-03, 85-04, 85-05, 85-06, 85-10, 85-14, 85-30, 86-04, and 86-07 reported security computer malfunction Unit 1 LERs 85-07, 86-11, and 86-15 reported security personnel error E. Licensing Actions Schedular Extensions Granted Non Reliefs Granted
, On October 31, 1985, relief was granted from inservice inspection ,
requirements of 10 CFR 55a(g) for four Safety Injection Tank outlet check valve e Exemptions Granted On April 15, 1985, an Appendix R Exemption Request was grante . Memorandum and Orders Issued On July 27, 1985, an Order Modifying License was issued confirming .
additional licensee commitments on Emergency Response Capability (Supplement 1 to NUREG-0737).
.
,,-
35 License Amendments Issued Amendment No. 99 issued on June 19, 1985, Revised Technical Speci-fications for the Cycle 7 Reload Analyse Amendment No. 100 issued on June 19, 1985 Control Room Habitability Modification Amendment No. 101, issued on August 2, 1985, Diesel Generator Test Requirements and Other Miscellaneous Change Amendment No. 102 issued on August 6, 1985, Organizational Change involving the Training Superviso Amendment No. 103 issued on August 12, 1985, Deletion of Environ-mental Qualification Section Amendment No. 104 issued on September 16, 1985, Radiological Efflu-ent Amendment No. 105 issued on October 3, 1985, Correction of Typo-graphical Error Amendment No. 106 issued on December 10, 1985, Overtime Polic Amendment No. 107 issued on December 19, 1985, Contingency Guard Forc Amendment No. 108 issued on December 24, 1985, Battery Service Tes Amendment No. 109 issued on January 15, 1986, Reracking the Spent Fuel Poo Amendment No. 110 issued on February 4, 1986, Fire Protectio Amendment No. 111 issued on April 9, 1986, Reportable Events
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MILLSTONE 2 TABLE 1 INSPECTION HOUR SUMMARY AREA HOURS % OF TIME Plant Operations 655 3 Radiological Controls 242 1 Maintenance and Modifications 215 1 Surveillance 196 1 Emergency Preparedness 84 Security and Safeguards 117 Refueling and Outage Management 196 1 Training and Qualification Effectiveness 10 Assurance of Quality -- Licensing Activities -- Other -- TOTALS 1715 100.0 l
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MILLSTONE 2 TABLE 2 ENFORCEMENT SUMMARY SEVERITY LEVEL 1 2 3 4 5 DEV TOTAL AREA
Plant Operations 1 6 1 8 Radiological Controls
Maintenance and Modifications 2 2 Surveillance O
Emergency Preparedness 1 1 Security and Safeguards
'O Refueling and Outage Management
Training and Qualification Effectiveness .
Licensing Activities -r
Assurance of Quality Other __ __ __ __ __
TOTALS 0 0 2 8 1 0 11 i
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- INSPECTION SEVERITY FUNCTIONAL E E REPORT N LEVEL AREA VIOLATION ?
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( 336/85-11 5 RAD CONTROL DOSE RATE AT THE EXTERNAL SURFACE OF if 3/11/85 A PACKAGE ON AN OPEN TRANSPORT VEHICLE ir L EXCEEDED LIMITS g-a 336/85-14 4 RAD CONTROL FAILURE TO IMPLEMENT QA PROCEDURES A 4/15-19/85 FOR RECEIPT OF THE SOLIDIFICATION s E SYSTEM 'l e
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336/85-14 3 RAD CONTROL ABOVE LIMIT RADIATION ON THE OUTSIDE 1 4/15-19/85 SURFACE OF A PACKAGE SHIPMENT TO
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! 336/85-17 4 SURVEILLANCE LEAK TEST OF CONTAINMENT PURGE EX- 5_
i 4/8-11/85 HAUST VALVES WITHOUT PROPER SET UP %
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336/85-22 4 SURVEILLANCE PERFORMANCE OF LLRT WITH NON-CALI- _
[ 6/3-17/85 BRATED INSTRUMENTATION I 336/85-36 3 SEC/ SAFEGUARD UNAUTHORIZED INTRODUCTION OF A FIREARM R
- 11/13-20/85 TO THE SITE PROTECTED AREA i
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-
E 4 RAD CONTROL PACKAGE IMPROPERLY LABELED C
h 3/24-27/86 m 336/86-06 4 RAD CONTROL PERSONNEL IMPROPERLY TRAINED I E 3/24-27/86 b 336/86-06 4 RAD CONTROL FAILED TO HAVE COPIES OF DRAWINGS AND j 3/24-27/86 OTHER DOCUMENTS AS EEQUIRED :
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E 336/86-06 4 RAD CONTROL FAILURE TO CONDUCT PROCESS CONTROL 3/24-27/86 PROGRAM AS REQUIRED he s
r 336/86-06 4 RAD CONTROL QC INADEQUATE TO ASSURE COMPLIANCE g E 3/24-27/86 y
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MILLSTONE 2 TABLE 4 INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 85-07 RESIDENT 87 REFUELING, SG N0ZZLE DAMS, SG PRIMARY HEAD 2/19-3/15/85 HYDROLAZING, IEB 84-03, MAINTENANCE, SUR-VEILLANCE 85-08 SPECIALIST 0 NOT APPLICABLE (OUTSIDE INSPECTION PERIOD)
2/19-3/01/85 59 PLANT OPERATIONS, EQUIPMENT ALIGNMENT &
85-09 RESIDENT READINESS, RADIATION PROTECTION, SECURITY, 2/25-3/24/85 FIRE PROTECTION, PLANT OPERATING RECORDS, MAINTENANCE, SURVEILLANCE, REPORTING SPECIALIST 81 ALARA IMPLEMENTATION, SURVEILLANCE, TRAIN-85-10 3/1-29/85 ING, SG REPAIR, RADIATION AREA AND DOSE CONTROL SPECIALIST 0 REVIEW 0F SHIPPING PAPERS, PLACARDING, 85-11 MARKING & LABELING, RADIATION MEASUREMENTS, 3/11/85 CONTAINMENT SURVEYS, AND PACKAGE & VEHICLE INSPECTION 85-12 SPECIALIST 9 PRESERVATION OF CIVIL STRUCTURES AND 3/26-29/85 STRUCTURAL SUPPORTS 71 PLANT OPERATIONS, EQUIPMEN'i ALIGNMENT &
85-13 RESIDENT READINESS, RADIATION PROTECTION, SECURITY, 3/25-5/13/85 FIRE PROTECTION, OPERATING RECORDS, MODI-FICATIONS, SURVEILLANCE, REPORTING ,
85-14 SPECIALIST 51 RADWASTE TRANSPORTATION 4/15-19/85 85-15 SPECIALIST 15 MEETING ON RADWASTE TRANSPORTATION 3/25/85 SPECIALIST 25 SECURITY ORGANIIATION, PROGRAM AUDIT, 85-16 RECORDS AND REPORTS, TESTING AND MAIN-4/8-11/85 TENANCE, BARRIERS, AND ACCESS CONTROL
- - - -
.
T-4-2 REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 85-17 RESIDENT 27 LOCAL LEAK RATE TESTING OF CONTAINMENT 4/8-11/85 PURGE EXHAUST VALVE, HYDRAULIC SNUBBER TESTING, CONTROL ROOM HABITABILITY MODI-FICATIONS, AUXILIARY FEEDWATER MAINTENANCE 85-18 SPECIALIST 39 IN SERVICE INSPECTION, ULTRASONIC EXAMINA-4/29-5/03/85 TION OF PIPING AND EDDY CURRENT EXAMINATION OF SG TUBES 85-19 SPECIALIST 38 DEGRADED GRID VOLTAGE PROCEDURES 5/13-17/85 85-20 RESIDENT 29 THERMAL SHIELD STORAGE, CASK WASHDOWN PIT 6/3-6/85 FILTER CHANGE 00T, SERVICE WATER HYDROSTATIC TEST, SURVEILLANCE PROCEDURES 85-21 RESIDENT 108 PLANT OPERATIONS, EQUIPMENT OPERABILITY, 5/13-6/29/85 RADIATION PROTECTION, SECURITY, FIRE PRO-TECTION, OPERATING RECORDS 85-22 SPECIALIST 64 CALIBRATION OF LOCAL LEAK RATE TESTING 6/3-17/85 INSTRUMENTATION 85-23 CANCELLED 0 --
6/24-20/85 85-24 SPECIALIST 31 RADIOACTIVE EFFLUENTS, CONTROL INSTRUMEN-6/24-28/85 TATION, PROCEDURES, REACTOR COOLANT CHEMIS-TRY, AND VENTILATION SYSTEMS I 85-25 RESIDENT 53 OPERATIONS, EQUIPNFNT OPERABILITY, RADI-l 6/30-7/22/85 ATION PROTECTION, SECURITY, FIRE PROTECTION, DESIGN CHANGES, AND SURVEILLANCE 85-26 RESIDENT 0 MANAGEMENT MEETING ON RECENT DESIGN CHANGES 7/18/85 ,
85-27 RESIDENT 60 OPERATIONS, EQUIPMENT OPERABILITY, RADI-7/23-9/03/85 ATION PROTECTION, SECURITY, FIRE PROTECTION, DESIGN CHANGES, AND SURVEILLANCE 85-28 SPECIALIST 25 DOSIMETRY PROGRAM, PERSONNEL QUALIFICATIONS, 8/5-9/85 FACILITIES, DOSE ASSESSMENT, QA, AND RECORDKEEPING 8S-29 SPECIALIST 69 TEST PROGRAM, PRE-CRITICAL TESTS, LOW POWER PHYSICS TESTS, POWER ASCENSION TESTS 8/19-23/85 l
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T-4-3 REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 85-30 RESIDENT 100 OPERATIONS, EQUIPMENT OPERABILITY, RADI-9/4-10/28/85 ATION PROTECTION, SECURITY, FIRE PROTECTION, DESIGN CHANGES, AND SURVEILLANCE 85-31 SPECIALIST 84 ANNUAL EMERGENCY EXERCISE 11/6-8/85 85-32 RESIDENT 69 OPERATIONS, EQUIPMENT OPERABILITY, RADI-10/29-12/30/85 ATION PROTECTION, SECURITY, FIRE PROTECTION, DESIGN CHANGES, AND SURVEILLANCE 85-33 SPECIALIST 10 REACTOR COOLANT PUMP RCP MOTOR FAILURE, 10/21-25/85 DEGRADED GRID VOLTAGE DETECTION SYSTEM AND ASSOCIATED OPERATING PROCEDURES 85-34 SPECIALIST 11 NUCLEAR MATERIAL CONTROL AND ACCOUNTING 11/12-15/85 S5-35 SPECIALIST 0 QUALIFICATION OF ELECTRIC EQUIPMENT 11/18-22/85 85-36 RESIDENT 5 UNAUTHORIZED FIREARM INTRODUCTION INTO THE 11/13-20/85 PROTECTED AREA l
85-37 SPECIALIST 27 PHYSICAL BARRIERS, COMPENSATORY MEASURES, l
'
12/16-19/85 ASSESSMENT AIDS, ACCESS CONTROL, DETECTION AIDS, ALAR!i STATIONS, COMMUNICATIONS, TRAINING, AND QUALIFICATIONS
, 86-01 RESIDENT 79 OPERATIONS, EQUIPMENT OPERABILITY, RADI-l 12/31/85- ATION PROTECTION, SECURITY, FIRE PROTECTION, 2/24/86 DESIGN CHANGES, AND SURVEILLANCE 86-02 CANCELLED 25 FIRE PROTECTION 2/24-28/86 86-03 RESIDENT 131 OPERATIONS, SURVEILLANCE, MAINTENANCE, TEN-2/25-4/07/86 YEAR CONTAINMENT TENDON SURVEILLANCE,
.
SHROUD HEAD BOLTS, FUEL RACKS, ISOLATION l
CONDENSER VALVE OPERABILITY 86-04 SPECIALIST 17 NON-RADIOLOGICAL CHEMISTRY CONTROL 3/17-21/86 86-05 SPECIALIST 49 PHYSICAL SECURITY l 3/24-28/86
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T-4-4 REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 86-06 SPECIALIST 15 TRANSPORTATION PROGRAM FOR RADI0 ACTIVE 3/24-27/86 MATERIAL 86-07 RESIDENT 130 OPERATIONS, SURVEILLANCE, MAINTENANCE, TEN-4/8-5/19/86 YEAR CONTAINMENT TENDON SURVEILLANCE, DESIGN CHANGES, TRAINING, SPENT FUEL P0OL RERACKING, MAIN TUR8INE INSPECTION PLANNING 86-08 SPECIALIST 22 LIQUID AND GASE0US RADI0 ACTIVE WASTE CON-4/14-18/86 TROL PROGRAM
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-
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MILLSTONE 2 TABLE 5
LISTING OF LERs BY FUNCTIONAL AREA CAUSE CODES *
AREA A B C D E X TOTAL Plant Operations- 2 1 2 5 Radiological Controls 2 1 3 Maintenance and Modifications 1 1 2 Surveillance 1 1 1 3 Emergency Preparedness 0 Security and Safeguards 3 2 1 9 1 16 Refueling and Outage Management 1 1 2 '
Training and Qualification Effectiveness 1 1 2 Licensing Activities 0 Assurance of Quality 0 0 Other _ _ _ _ _ _
TOTALS 7 6 3 2 14 1 33 i
- LER Cause Codes (NRC Categorization)
A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D'- Defective Procedures E - Component Failure X - Other
,
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.
, ~
MILLSTONE 2 TABLE 6 LER SYNOPSIS LER NUMBER EVENT DATE CAUSE CODE * DESCRIPTICN 85-002-00 03/02/85 A CONTAINMENT PURGE ISOLATION SIGNAL 85-003-01 03/05/85 E EXCESSIVE LOCAL LEAK RATE LEAKAGE 85-004-01 03/14/86 E STEAM GENERATOR TUBE DEGRADATION 85-005-00 04/01/85 A DIESEL STARTUP CAUSED BY ENGINEERING SAFE-GUARDS (ESF) ACTUATION 85-006-01 03/29/85 D ESF ACTUATION DURING I&C WORK 85-007-00 04/13/85 C ESF ACTUATION OF CONTAINMENT PURGE VALVES 85-008-00 03/24/85 E INOPERABLE SNUBBER ON PRESSURIZER VENT PIPE 85-009-01 06/11/85 B DESIGN DEFICIENCY IN CHARGING PUMP CONTROL 85-010-00 06/15/85 A REACTOR COOLANT SYSTEM (RCS) LOW TEMPERA-TURE OVERPHESSURE PROTECTION INOPERABLE 85-011-00 07/15/85 E REACTOR TRIP CAUSED BY PRESSURE DROP DUE TO STUCK OPEN SPRAY VALVE ,
85-012-00 07/26/85 B LOSS OF ONE SERVICE WATER SYSTEM DUE TO STRAINER FOULING E5-013-00 08/22/85 B CHARGING PUMP "C" CRACKED BLOCK 85-014-00 09/27/85 C LOSS OF 0FF-SITE POWER DUE TO HURRICANE GLORIA l
85-015-00 10/08/85 A LOSS OF SAMPLE FLOW THROUGH RADIATION MONITOR 86-001-00 04/29/86 E BROKEN ANCHOR BOLT ON SERVICE WATER LINE TO CHLORINATION SYSTEM 86-02-00 04/17/86 0 NONCONSERVATIVE ACCEPTANCE CRITERIA FOR RCS FLOW SURVEILLANCE 86-03-00 05/16/86 B IMPROPER INSTALLATION / RATING OF 20 FIRE DAMPERS
- Assigned during NRC revie _ _ _ _ _..__ ___ ___ _ _ _
, .-
T-6-2 The following Unit 1 LERs are also applicable to Unit LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 85-03-00 04/17/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-04-00 05/16/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-05-00 06/19/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-06-00 07/01/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-07-00 07/06/85 X SECURITY RELATED - VITAL 000R FAILURE 85-10-00 07/15/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-12-01 07/17/85 A SECURITY RELATED - VITAL DOOR UNPROTECTED 85-14-00 09/12/85 E SECURITY RELATED - COMPUTER MALFUNCTION 85-15-00 09/26/85 A SECURITY RELATED - VITAL DOOR UNPROTECTED 85-24-00 11/13/85 A SECURITY RELATED - FIREARM IN VEHICLE 85-30-00 12/04/85 B SECURITY RELATED - COMPUTER OVERLOAD 86-04-00 02/04/86 E SECURITY RELATED - COMPUTER MALFUNCTION 86-07-00 02/18/86 B SECURITY RELATED - COMPUTER OVERLOAD 86-11-00 04/10/86 E SECURITY RELATED - VITAL DOOR ALARM 86-14-00 04/21/86 C SECURITY RELATED - B0MB THREAT 86-15-00 04/28/86 E SECURITY RELATED - VITAL 000R ALARM - 86-06-00 05/01/86 A SECURITY RELATED - VITAL 000R UNPROTECTED
- LER Cause Codes (NRC Categorization)
A - Personnel Error B - Dasign, Manufacturing, Construction, or Installation Error -
C - External Cause D - Defective Procedures E - Component Failure X - Other
.
- Assigned during NRC revie *
.,
MILLSTONE 2 TABLE 7 REACTOR TRIPS AND UNPLANNED SHUTDOWNS POWER PROXIMATE ROOT DATE LEVEL CAUSE CAUSE 07/15/85 100% UNIT TRIP UNIT TRIPPED DUE TO REDUCTION OF REACTOR PRES-SURE CAUSED BY STUCK OPEN PRESSURIZER SPRAY VALV CAUSE CONSIDERED TO BE COMPONENT MAL-FUNCTIO /27/85 . 100% SHUTDOWN PRECAUTIONARY SHUTDOWN IN PREPARATION FOR HURRICANE GLORIA, EXTENDED TO A MONTH FOR RCP REPAIRS NECESSITATED BY MOTOR ELECTRICAL FAULT .
%
.
_
- -- - ,-y---- --- ----.y .
m- w--,--, ,7-yy 3 _. , . - - ,-__ e y-- ,,---, - --
., :r FIGURE 1 MILLSTONE 2 NUMBER OF DAYS SHUTDOWN PER MONTH I
MAR l/////////////////////////////// 744 hours0.00861 days <br />0.207 hours <br />0.00123 weeks <br />2.83092e-4 months <br /> - Refueling / Maintenance l Outage I
APRIL 1////////////////////////////// 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> l
l MAY \/////////////////////////////// 744 hours0.00861 days <br />0.207 hours <br />0.00123 weeks <br />2.83092e-4 months <br /> 1 l l
9 JUNE l////////////////////////////// 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> l
8 l JULY l///////// 197.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> - End of R/M Outage and PRV Trip 5 l l
AUG l l
l SEPT l//// 84.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> - Hurricane " Gloria" and Reactor Coolant Pump (RCP)
l Repair l
OCT I/////////////////////////////// 744 hours0.00861 days <br />0.207 hours <br />0.00123 weeks <br />2.83092e-4 months <br /> - RCP Repair l
NOV l//////// 175.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> - RCP Repair i
DEC I I
JAN I l
1 I FEB l 9 I l
8 MAR I I
6 l APRIL l l
l MAY 1/// 70.5. hours - Turbine Inspection (startup was on 6/1)
l I I I I I I I 5 10 15 20 25 30 NUMBER OF DAYS