IR 05000336/1989001

Insp Rept 50-336/89-01 on 890103-06.No Violations or Deviations Noted.Major Areas Inspected:Evaluation of Effectiveness of Licensee Implementation of QA Program

ML20235W105
Person / Time
Site:	Millstone
Issue date:	02/23/1989
From:	Eselgroth P, Norris B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235W094	List: IR 05000336/1989001 ML20235W091
References
50-336-89-01, 50-336-89-1, NUDOCS 8903100496
Download: ML20235W105 (10)

Text

. -

_ _ - - _ - . . - - - . - - - _ _ .--_ _ _ - - _ _ . _ - - - - - - - - _ _ _ _ _ - _ - - ..

- -

. .

UNITED $TATES NUCLEAR REGULATORY COMMISSION

REGION I

Report N /89-01 Docket N License N DPR-65 Licensee: Northeast Nuclear Energy Company P. O. Box 270

<

Hartford, Connecticut 06141-0270 Facility Name: Millstone Nuclear Power Station, Unit 2 Inspection At: Waterford, Connecticut Inspection Dates: January 3 - 6, 1989 Inspector: N

%arry f). Norris

Date M7b Senio6' Operations Engineer Approved by: M r

, 2-23' N Petar W. Eselg,44.h, Chief Date Pressurized W Wer Reactor Section Operations Branch, DRS i Inspection Summary: Routine unannounced inspection on January 3 - 6, 1989 Areas Inspected: Evaluation of the effectiveness of the licensee's implementation of the quality assurance progra Results: No violations or deviations were identified. Over the last three SALP periods, the p rformance at Millstone Unit 2, with respect to the assurance of quali . has g m rally been trending down. The licensee management has recotjnized this trend and has fostered an attitude of correcting the problem before it occur It appears that these cor, r,i ve measures may reverse the downward tren PDR ADOCK 05000336 Q FDC

_ -_-_---___-___-__

. .

.

,

.. . ,.

i DETAILS'

1.0 PERSONS CONTACTED Licensee Representatives:

P. Blasioli, Supervisor, Nuclear Licensing G. Clousius, Supervisor, Plant Quality Services F. Dacimo, Engineer Supervisor, Millstone Unit 2

• H. Haynes, Station Services Superintendent

• J. Keenan, Millstone Unit 2 Superintendent

• J. Laine, Millstone Unit 2. Radiation Protection Supervisor F. Libby, Supervisor, Assessment Services

'J. Maher, Supervisor, General Nuclear Training  ;

'J. Resetar, Engineer, Millstone Unit 2

• S. Scace, Millstone Station Superintendent

• Sforza, Senior Engineer, Assessment Services '

• J. Sullivan, Health' Physics Operations Supervisor W. Varney, Manager Plant Quality Services

• P. Weekley, Security Supervisor Nuclear Regulatory Commission Representatives:

l S. Barber, Resident Inspector, Millstone Unit 3

• F. Bonnett, Operations Engineer, Region I P. Habighorst, Resident Inspector, Millstone Unit 2 L. Kolonauski, Resident Inspector, Millstone Unit 1 i

• B. Norris, Senior Operations Engineer, Region I i

• W. Raymond, Senior Resident Inspector, Millstone Station l l

• Denotes those personnel attending the exit meetin {

i 2.0 EVALUATION OF LICENSEE QUALITY ASSURANCE PROGRAM IMPLEMENTATION (35502) {

!

2.1 Scope: {

The scope of this inspection was to evaluate the effectiveness of I the licensee's implementation of the quality assurance progra !

And, based on that evaluation, to determine those factors that were !

indicative of shortcomings in the licensee's quality assurance i program implementation. Tne documents reviewed during the  ;

inspection are listed in Attachment ;

- _______ ____-_____ _ ___-__- ____ _ __ -

_ _ ____

l

l .

l

-

.

l .

l I

2.2 Background:

This inspection consisted of a review of the following documents and interviews of personnel:

- The NRC inspection reports for calendar year 1988,

- The last three Systematic Assessments of Licensee Performance (SALP),

- The Resident Inspector's Open Items List,

- The Licensee Event Reports (LERs) for the past twelve months, and

- The licensee corrective action responses to NRC inspection finding Review of Licensee Quality Assurance inspection, audit, and surveillance reports of activities at Unit 2,

- Review of the SALP reports for Units 1 and 3 (to use as a comparison point),

- Interviews with selected supervisors and managers having responsibility for either Millstone Unit 2 or Millstone Site activities,

- Review of the results of the survey conducted by the Senior Resident Inspector, and

- Discussions with the Resident Inspectors of all three unit The review of the above documents, mainly the last three SALP reports, indicated that the overall performance of the Millstone Unit 2 program for assuring quality was trending downward away from an overall level of excellenc .3 Radiological Controls The area of health physics and radiological controls (HP/RC) has historically been a station function with small groups assigned to

~

each of the units. The SALP ratings received for HP/RC have been fluctuating between 2 and 3, with the most recent rating being a It appears that significant steps have been taken within this area to improve the performance of this function. Specifically, the training program for HP/RC is now INPO accredited and performance based, there was a recent reorganization, ALARA coordinators have been assigned to the field, new equipment has been funded, and a Quality Circle group has been formed within the HP/RC grou _ .

= m 6 =*

~*~

,,_

hap W Whe L 'N _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _

_ _ - - _ _ _ _ _ - _ - _ __ - __-- - _ _

- - . _ _ . __. -

.

. - j o ; .

< . .

.

,

The HP/RC Supervisor for Unit 2 stated that the Unit's morning  :

meetings are helpful in that all departments are able to hear the problems encountered within.the HP area and will therefore attempt to prevent recurrenc .4 Surveillance The management of Unit 2 believes that the only significant data point that caused the SALP rating for this functional area to decrease to a 2 was a problem encountered during eddy current testing of the steam generator U-tubes and the subsequent plugging of the

' tubes. Several steps have been initiated to prevent this type of problem from recurring. Specific to eddy current testing, the program for reviewing the results of the eddy current tests has been expanded to add a computerized review of the results. . Additionally, the quality program has been shifted from a " hold point" type of inspection to an overview of an entire activity; however, the responsibility for overview is not clearly defined as to which of the Quality Services organizations'should be performing the functio (See Section 2.9 for further details.)

2.5 Security and Safeguards The Supervisor of Station Security was interviewed to determine why the SALP rating in this area had decreased, what had been done to correct that specific situation, and what actions had been taken to prevent those problems from recurring. The Station Security Supervisor attributed the problem to (1) an attitude of acceptance on the part of the station security personnel and (2) the depth of the inspections conducted by corporate sece-ity staf The major improvement to the security function is a reorganization and expansion of the security force. Previously, all personnel reported directly to one supervisor, now there are four first-line

- supervisors reporting to the Supervisor of Station Security. A second change is that the audits of security are now being performed by the site Quality Services organization with support from corporate security; previously, the audits had been performed only by corporate security, and one of the team members had previously been the Station Security Supervisor. The Supervisor considers this a significant improvement in the assessment of the security function since it incorporates an independent revie .,

_ _ _ _ _ . _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ __-_-

__-

.

.

.

2.6 Engineering Support The Engineering Supervisor for Unit 2 is currently licensed as a Senior Reactor Operator (SRO) on Unit 2, and was previously the quality assurance supervisor. Within the engineering department, four first-line supervisors and five other engineers are SRO licensed. The supervisor stated that' licensing of engineering personnel gives the engineering department an advantage in that they can be proactive to the other departments with a focus on safet Additionally, he stated that his previous experience in quality assurance has been carried over to the engineering functio During the review of the Unit 2 LERS, it was noted that the root causes and corrective actions were identified, but in some cases, did not describe the problem or corrective action in sufficient detail. Also, the timeliness in promised updates was slo Cognizant engineering and licensing personnel indicated in discussions with the inspector that closer review and greater attention to detail was neede .7 Training Effectiveness The depth of the inspection in the training area was limited to that aspect of indoctrination training dealing with the quality assurance program and the concept 1of quality work ("do it right the first time"). Within this limited scope, training has developed two video tapes and a classroem presentation. The program is reviewed i annually, and updated, based on identified Millstone station 1 problems (such as audit findings and NRC reports), industry feedback, student feedback, and subject matter expert .8 Licensing Activities The licensee's performance in this functional area had been a '

constant rating of 1 in previous SALP periods. However, their performance declined to a rating of 2 in the latest SALP period. As indicated in the latest SALP report, the basis for this decline was primarily due to consistently late submittals without, in some cases, arranging revised submittal dates with the NR The root causes and the corrective actions taken in response to the recommendations given in the last SALP were discussed with the Supervisor of Nuclear Licensing for Unit 2. The licensee indicated that with respect to timely responses to regulatory correspondence, that they had been aware of the problem, but were slow in trying to correct the problem. After the last SALP Report was issued, the licensee management assessed and instituted a program to enhance the performance standard in Licensing activities. The latest timeliness l report was reviewed, the report indicated for the period May to 1 f October,1988, sixty-one reports were issued on time or early, and j

,

!

I I

l

, -

w_________-____________

__ -__- ____ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ -_ ____ __ -

. .

. . .

.

one report was issued lat Eleven open items are on the facility's open item lis The licensee indicated that since these changes in work practices have been implemented, performance within the department has improved. It appears that the licensee is taking appropriate action in response to the SALP recommendation .9 Assurance of Quality The Quality Services Department (QSD) at Millstone station has responsibility for the Quality Assurance Program at the statio Since the station is made up of three separate and unique units, QSD is tasked with auditing and inspecting to three different sets of unit procedures. QSD has a policy of random surveillance. This policy is based on a review of industry standards that shows detailed inspections of routinely performed functions are not warrante (This policy is not applicable to required " hold point" inspection on Category 1 systems.) Due to the reduced number of inspections, an increased number of random surveillance may be performed by QS The Manager of Plant Quality Services indicated that not all-of the surveillance are conducted by QSD. Additionally, the Manager of Plant Quality Services could not provide evidence indicating coordination between the various groups that do perform surveillanc Quality Services surveillance are graded for significance and required timeliness of response. The inspector reviewed the QSD Surveillance Summary Report and compared the number of surveillance to the number of QSD open items for the past quarter. It appeared that Unit 2 was not aggressive in ensuring timely responses to surveillance finding It was brought to the attention of the inspectors that the maintenance department (responsible for a large number of the findings) was attentive to these surveillance reports and that many of the responses were in the process of being submitted to the Quality Services Department for their review. The QSD Surveillance Program could be improved by ensuring that timely .

responses are submitted by the cognizant departmen )

A combined Utility Assessment in the Northeast Utilities S9rvice Company was conducted in June, 198 This assessment of the licensee's quality assurance program was limited in scope, and did not address overall program coordination.

l The combination of quality assurance inspections, surveillance, and i audits encompass all of those safety-related activities that require a quality assurance overvie It appears that there is no mechanism within the Millstone organization that ensures that the needed coordination is, in fact, being accomplishe (0 pen Item 89-01-01)

. _ - - _ _ _ _

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ . - _ . .

.,

, .. . .

o 2.10 CONCLUSION

.Within the scope of this inspection, the management of Millstone

~

Unit 2, and Millstone station as it applies to Unit 2, recognizes that:their performance in the past had been heading in a direction away from excellence. . Based on the review of the documents listed in' Attachment 1, and the interviews with the licensee's management, it appears that steps are being taken to correct the deficiencies noted in the latest SALP report. One concern was identified relative to the coordination of quality assurance activitie .0 MANAGEMENT MEETINGS .

Licensee management was informed of the scope and purpose of the inspection at the entrance meeting conducted on January 3,1989. The findings were discussed with licensee representatives during the course of.the inspection and presented to licensee. management during the exit meeting on January 6,.1989 (see paragraph 1 for attendees).

At' no time during the inspection was written material provided tot he licensee by the inspectors. The licensee did not indicate that proprietary information was involved within the-scope of this inspection.

i

___._---__---_-_------_m_ _ - . _ _ _ - - _ _ - . .

_ - _ _ _ _ _ _ _ _ _ _

- .

. . . .

ATTACHMENT 1 Page 1 of 3 DOCUMENTS REVIEWED l

NRC Inspection Reports:  ;

88-01 Radiation Protection Activities Unit 2 Outage .

88-01 Residents Routine Summary (01 Jan 88 - 08 Feb 88)  ;

88-03 ISI Activities, Eddy Current Testing, Weld Inspection 88-04 Containment ILRT 88-06 Residents Routine Summary (08 Feb 88 - 21 Mar 88)

88-07 Residents Routine Summary (22 Mar 88 - 02 May 88)

88-08 Physical Security Inspection 88-09 Radiation Protection Activities 88-10 E0P-1. Team Inspection 88-11 Physical Security Inspection 1 88-12 Radio-Chemical Measurement Program  ;

88-13 Resident Routine Summary (03 May 88 - 13.Jun 88) I 88-14 Physical Security Inspection  !

88-15 Licensed Operator Requalification Training i 88-16 Residents Routine Summary (14 Jun 88 - 29 Jul 88) l 88-17(0L) Licensed Operator Exam Report 88-18 Radiation Protection Activities 88-19 Residents Routine Summary (30 Jul 88 - 12 Sept 88)

88-20 EQ Inspection i 88-21 Emergency Preparedness Program ,

88-22 Residents Routine Summary (13 Sept 88 - 12 Oct 88) {

88-23 Operational Radiological Environmental Monitoring Program i 88-24 Residents Routine Summary (13 Oct 88 - 23 Nov 88)  !

Licensee Event Reports:

88-001 Steam Generator Plugging Error 88-002- Loss of Normal Power  !88-003 Spurious Engineered Safeguards Actuation j 88-004 Inadvertent Auxiliary Exhaust Actuation t 88-005 LNP Resulting from Operator Error & Subsequent i Discovery of Failure of EDG Sequencer 88-006 Combined Bypass Leakage Rate Exceeded 88-007 Change of Modes With Diesel-Generator Inoperable 88-008 Unrecoverable Oropped CEA 88-009 Unrecoverable Dropped CEA due to Upper Gripper Coil Failure SALP Reports: i 50-245/85-98 Unit 1 (01 Mar 85 - 31 May 86) 1 l

50-245/86-99 Unit 1 (01 Jun 86 - 31 Dec 87)

50-336/85-98 Unit 2 (01 Mar 85 - 31 May 86)

50-336/86-99 Unit 2 (01 Jun 86 - 31 Dec 87)

50-423/87-99 Unit 3 (01 Mar 87 - 31 May 88)

- _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _-__ -_ _ _ _ _ _ . _ _ _ _ _ __ _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

- .

. . .

ATTACHMENT 1 i Page 2 of 3

DOCUMENTS REVIEWED (continued)

Quality Services Department Documents:

i Quality Assurance Program Topical Report Quality Services Department Procedures:

QSD-1.02 Quality Services Department Procedures QSD-1.05 Control of Nonconformances QSD-1.06 Procedure to Stop Work QSD-1.07 Computer Tracking Programs QSD-1.08 Quality Services Department Indoctrination and Training Program QSD-1.12 Preparation and Issuance of Quality Services Department Quarterly and Annual Activity Report QSD-2.02 Performance, Reporting and Follow-up of Audits QSD-2.03 Performance, Reporting and Follow-up of Surveillance Activities QSD-2.04 Corrective Action Request QSD-2.06 Training and Qualification of Lead Auditors QSD-2.08 Selection, Training, Qualification, and Certification of Inspection and Testing Personnel QSD-2.09 Performance, Reporting, and Follow-up of In-Process Verification QSD-3.08 Performance of Receipt Inspection Activities QSD-4.02 Performance and Reporting of Inspection and Inspection

.. Surveillance Activities Quality Services Department Instructions:

QSDI-PS-MP-2.01 Field Observations Quality Services Department Surveillance Reports:

QS288-08 CEDM Coil Stack Repair (includes rebuttal A and B)

QS288-10 Use of Fermanite not receipt inspected QS288-11 Changing PDCR work order review & no material control log QS288-16 Inadequate procedure MP 2719A, EDG Overhaul QS288-19 Final work order review SF-235 lifted lead / bypass jumper not used QS288-22 M&TE Controls QS288-27 Missed Hold Points QS288-28 Automated Work Order Documentation not in accordance with ACP requirement QS288-29 RBCCW H/C "C" Tubes, Expansion of QS288-30 Pressure Gage and Steelman Dven QS288-31 Level E Cleanness Requested. Waived by Engineering with out NCR l

. _ _ _ _ _ . - _ . _ _

._ - _ ._ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ _ _

4 . .

.

. . .

ATTACHMENT 1 1 l

Page 3 of 3 DOCUMENTS REVIEWE (continued)

Quality Services Department Audit Reports:

No. A22015 Millstone Unit 2, Corrective Action System No. A60488 Millstone Unit 1 Operations No. A60489 Millstone Unit 2 Operations No. A60490 Millstone Unit 3 Operations No. A60492 Millstone Station Radwaste Activities Quality Services Department Inspection Reports:

M2-88-06958 CEDM No. 30 Replacement (MNT)

M2-88-06959 CEDM No. 31 Replacement (MNT)

M2-88-06960 CEDM No. 32 Replacement (MNT)

M2-88-06961 CEDM No. 33 Replacement (MNT)

M2-88-03147 RPS Char.nel D Tc RCS Temp Circuit Replacement (I&C)

M2-88-03353 RPS Channel A J-6 BNC Connector Replacement (I&C)

M2-88-04106 RPS PNL A ' Isolation Mod Needs Cap Re-Lugged (I&C)

M2-88-05692 Control Room Radiation Monitor Loop (I&C)

Millstone Station Training Material:

General Employee Training Student Handbook

. Combined Audit of Northeast Utilities June 20-24, 1988 Report of the Combined Utility Assessment of Northeast Utilities Service Company l

l r

!

I

_ - _ _ _ _ _ - _ _ _ - _ _ - _ _ _ _ -