Text

Forwards 851104 SALP Rept 50-423/85-99 for Sept 1984 - Aug 1985.Assessment Concluded That Plant Performance Characterized by Strong Mgt Involvement Evident During Transition from Const to Operations
	ML20210E113
Person / Time
Site:	Millstone
Issue date:	03/21/1986
From:	Murley T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Opeka J; NORTHEAST NUCLEAR ENERGY CO.
References
	NUDOCS 8603270205
	Download: ML20210E113 (3)
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n0M1211986 Docket No.

50-423 Northeast Nuclear Energy Company ATTN:

Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Report No.

50-423/85-99 This refers to our November 4, 1985 SALP for your Millstone Unit 3 facility.

The SALP report was discussed with you in a January 9,1986 meeting at the NRC Region I Office, King of Prussia, Pennsylvania.

The list of meeting attendees is attached as Enclosure 1.

The NRC SALP Report is provided as Enclosure 2.

Our letter of December 27, 1985 (Enclosure 3) previously forwarded the SALP report and solicited comments.

Your submittals dated September 17, 1985 and February 11, 1986 are also enclosed.

Our overall assessment is that Millstone 3 performance has generally been charac-terized by strong management involvement and that this has been evident in the transition from construction to operations.

However, there are areas where we perceive that performance has been in need of better self-evaluation by NNECo.

With respect to the evaluation of Licensing Activities (Functional Area J), we recognize your considerable efforts in this area.

Further, we agree that the ad-ditional review needed to address unique or alternate licensee positions is not grounds for penalizing a licensee.

Nonetheless, our evaluation is that greater initiative and responsiveness on your part was needed for a higher rating.

An example is your having previously identified your position on operator experience.

Had your staff also more vigorously pursued resolving with NRR management the dif-ference between your position and the current NRC and industry position, we feel this issue would have been resolved sooner.

Our assessment is that, although specific examples may be arguable, the SALP writeup represents the overall NRC view of your performance in the Licensing Activities area.

We believe that our meeting and interchange of information was beneficial and im-proved mutual understanding of your activities and our regulatory program.

No reply to this letter is required.

Your actions in response to the SALP will be reviewed during future inspections of your facility.

0603270205 060321 PDR ADOCK 05000423

PDR M

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Northeast Nuclear Energy Company

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4 Your cooperation is appreciated.

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Sincerely,

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Original Bigned by i

Thomas E. Murleg.

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Thomas j Regional Administrator

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Enclosures:

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SALP Management Meeting Attendees

2.

NRC SALP, Millstone Nuclear Power Station, Unit 3, November 4, 1985

3.

NRC Region I Letter, to J. Opeka, December 27, 1985 i

4.

Northeast Utilities Letters B11640, dated September 17, 1985 and A05472, j

dated February 11, 1986 f

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REGION I==

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-423/85-99 NORTHEAST NUCLEAR ENERGY COMPANY (NNECo)

MILLSTONE NUCLEAR POWER STATION, UNIT 3 ASSESSMENT PERIOD:

SEPTEMBER 1, 1984 - AUGUST 31, 1985 BOARD MEETING DATE:

NOVEMBER 4, 1985 pig M

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SUMMARY (9/1/84 - 8/31/85)

MILLSTONE NUCLEAR POWER STATION, UNIT 3

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Functional Area Hours

% of Time A.

Operations Supports 552

4 t.

3.

Radiological Controls 181

C.

Maintenance 169

D.

Surveillance 195

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E.

Preoperational Testing 1865

F.

Fire Protection 172

G.

Emergency Preparedness 140

H.

Security

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Construction 4774 J59

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Licensing Activities

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TOTAL 8201 100

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NOTE:

The above values are approximate.

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TABLE 3

. INSPECTION ACTIVITIES MILLSTONE NUCLEAR POWER STATION, UNIT 3 INSPECTION REPORT INSPECTION /

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NUMBER AND DATES HOURS AREAS INSPECTED 84-14 Resident Open items; preoperational testing; incore 8/19 - 9/29/84 114 hours0.00132 days 0.0317 hours 1.884921e-4 weeks 4.3377e-5 months thermocouples; structural settlement monitoring program; procedures; diesel fuel storage; lic-ensee/ contractor self audits; significan'. def t-ciencies; ACRS items.

84-15 Specialist Previous SALP period.

84-16 CANCELLED 84-17 Specialists Preoperational test program review including 9/17 - 21/84 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months program requirements, cortrol of documents, -test procedures, engineering drawings, manuals, de-sign changes and modifications, jumpers and by-passes; plant maintenance, preventive mainten-ance, and maintenance records; test procedure reviews and test results evaluations.

84-18 Specialists Followup on previous inspection findings; work 9/17 - 21/84 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months observation; review of.QC of pipe supports.

84-19 1984 Millstone Unit 3 SALP.

84-20 Resident Follow-up on previous inspection findings; start-9/30 - 11/10/84 266 hours0.00308 days 0.0739 hours 4.398148e-4 weeks 1.01213e-4 months up test program review and observation; event follow-up; welding electrode control; training; maintenance; construction; and housekeeping.

84-21 Specialists Facility tour; pipe and pipe support welding;

'0/15-19/84 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months copper-nickel welding; repair welding; and follow-up on open items.

84-22 Specialists Follow-up on open items; preoperational test 10/15-19/84 39 hours4.513889e-4 days 0.0108 hours 6.448413e-5 weeks 1.48395e-5 months program requirements and implementation; test procedure review and witnessing emergency diesel generator set test verification; and facility tour.

84-23 Specialists Installation of safety-related electrical and 10/22-26/84 66 hours7.638889e-4 days 0.0183 hours 1.09127e-4 weeks 2.5113e-5 months instrumentation system components.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED 84-24 Specialists Preoperational test program requirements and 11/5-9/84 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months implementation; test results evaluation and witnessing; auxiliary boiler repair and testing; preparations for' steam generator hydrostatic testing; quality assurance and quality control; facility tour.

84-25 Resident Preoperational testing; follow-up on open items; 11/11/84-1/7/85 192 hours0.00222 days 0.0533 hours 3.174603e-4 weeks 7.3056e-5 months control room practices; plant tours; control rod drive fabrication review; event follow-up;

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IE Notice review; implementation of security measures; audit activities; fire protection testing; hazards program review; changes to plant management; and Tubeco repairs.

84-26 Specialists Preoperational test program requirements and 11/26-12/5/84 134 hours0.00155 days 0.0372 hours 2.215608e-4 weeks 5.0987e-5 months implementation; test procedures and results 12/ 3-5/84 results review; steam generator hydrostatic 12/10-12/84 testing; quality assurance and quality control; and facility tours.

85-01 Specialists Construction Deficiency Reports 1/8-10/85 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months 85-02 Resident Preoperational testing; previous inspection 1/9-2/4-85 151 hours0.00175 days 0.0419 hours 2.496693e-4 weeks 5.74555e-5 months findings; control room practices; plant tours; rotential significant deficiencies; flushing program activities; IE Bulletins; allegations; valve positioning anomalies; fuel receipt pre-parations; service water hydraulic testing; safety injection plump test anomaly.

85-03 Specialists Preoperational test program requirements and 1/21-25/85 70 hours8.101852e-4 days 0.0194 hours 1.157407e-4 weeks 2.6635e-5 months implementation; test procedure and results re-views; test witnessing; auxiliary boiler status; quality assurance and quality control; and facility tours.

85-04 Specialists Construction appraisal team: Electrical and in-2/19-3/1/85 2200 hours0.0255 days 0.611 hours 0.00364 weeks 8.371e-4 months strumentation construction; mechanical con-

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3/11-22/85 struction; welding and non-destructive examin-

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ation; civil and structural construction; mate-rial traceability and control; design change control; corrective action systems.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED 85-05 Resident Review of activities including refueling cavity 2/5-3/18/85 183 hours0.00212 days 0.0508 hours 3.025794e-4 weeks 6.96315e-5 months seal ring leak test, emergency diesel generator EDG-A gage repair, EDG-A lubrication system performance, system flushes, ~ hydraulic expansion of steam generator tubes, emergency plan train-ing, and FSAR/ design verification. maintenance training; open items; NRC Bulletins, steam generator field service report; construction deficiencies; and allegation followup.

85-06 Specialists Preoperational test program requirements and

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2/12-15/

63 hours7.291667e-4 days 0.0175 hours 1.041667e-4 weeks 2.39715e-5 months implementation; test procedures and results re-2/25-3/1/85 view; test witnessing; open items; and plant tour.

85-07 Specialists Combined report for Units 1, 2 and 3: Preopera-2/11-15/85 31/10 hours ** tional program for operational environmental monitoring program including management controls, quality control'of analytical measurements, meteorological monitoring, radiological environ-mental monitoring program.

i 85-08 Specialists Installation of safety-related instrumentation.

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2/4-7/85 31 hours3.587963e-4 days 0.00861 hours 5.125661e-5 weeks 1.17955e-5 months 85-09 Specialists Physical security plan and implementing proce-2/11-15/85 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months dures for security and audits program, records and reports, testing and maintenance, locks,

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keys, physical barriers, security system power supply, lighting, assessment aids, access con-t

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trol, detection aids, alarm stations, communi-cations, training and qualifications, security contingency plans and proposed 10 CFR 73.55 and 73.67 plan commitments.

85-10.

Specialists Preoperational test program requirements and 3/18-22/85 66 hours7.638889e-4 days 0.0183 hours 1.09127e-4 weeks 2.5113e-5 months implementation; test procedure reviews; test witnessing; open items; reactor coolant system i

hydrostatic test; new fuel receipt and storage; quality assurance and quality control; facility tours.

85-11 Specialists Procedure review, test witnessing, and evalu-

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3/25-28/85 56 hours6.481481e-4 days 0.0156 hours 9.259259e-5 weeks 2.1308e-5 months ation of the preoperational Integrated Leak Rate Test, Structural Integrity Test, and Local Leak Rate Test; facility tour.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED 85-12 Resident Primary cold hydrostatic test and Chemical Ad-3/18-4/22/85 222 hours0.00257 days 0.0617 hours 3.670635e-4 weeks 8.4471e-5 months dition Tank Drawdown test witnessing; event followup; open items; potential significant deficiencies; IE Bulletins; IE Information No-tices; steam generator "J" tube inspection; and preparations for initial fuel receipt.

85-13 Specialists Installation of safety-related electrical and 4/8-12/85 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months instrumentation equipment;' quality control documentation; training of personnel; status of audits and findings.

85-14 Specialists Preoperational test program review; test proce-4/8-27/85 121 hours0.0014 days 0.0336 hours 2.000661e-4 weeks 4.60405e-5 months dural review, witnessing, and evaluation; open items; emergency diesel generator status; reac-tor coolant system cold hydrostatic test wit-ness; new fuel receipt inspection and storage; quality assurance and quality control inte--

faces; facility tour.

85-15 Examiner Oral, written and simulator examinations for 5/14-17/85 sixteen Senior Reactor Operators and five Reac-tor Operators.

85-16 Resident Observation of limited emergency exercise; event 4/23-5/27/85 268 hours0.0031 days 0.0744 hours 4.431217e-4 weeks 1.01974e-4 months followup; auxiliary feedwater pump flushing; field welding; ultrasonic testing of low pres-sure safety injection system; and eddy current testing of a steam generator.

85-17 Examiner Use of Millstone 3 simulator for NRC operator 3/25/85 licensing examinations.

85-18 Specialists Preoperational test program implementation; 5/6-10/85 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months engineered safety feature test status; emergency diesel generator status; pre-core hot functional test status; test procedure review and verifi-cation; new fuel receipt, inspection and stor-age; turbine building hot functional test status; quality assurance and quality control; facility tours.

85-19 Specialists Preoperational status pertaining to radiation 5/7-10/85 70 hours8.101852e-4 days 0.0194 hours 1.157407e-4 weeks 2.6635e-5 months protection and radioactive waste management, including organization, personnel training and qualifications, facilities and equipment, and procedure development.

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INSPECTION REPORT INSPECTION /

N'JMBER AND DATES HOURS AREAS INSPECTED 85-20 Specialists Safety-related pipe welding; Post Weld Heat 5/13-17/85 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months Treatment of containment shell penetrations; reactor vessel clevis hard surfacing; review of in progress work including welding; allega-tion followup; and review of service water clad elbow leakage.

85-21-Specialists Maintenance program; I&C program; and quality 5/13-17/85 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months assurance and quality control interfaces.

85-22 Specialists NRC independent measurements inspection using~

5/20-6/14/85 575 hours0.00666 days 0.16 hours 9.507275e-4 weeks 2.187875e-4 months the Mobile Nondestructive Examination Laboratory on selected safety-related piping fabricated to ASME Code Section III, Classes 1, 2, and 3.

85-23 Resident Open items; facility events; Type C leak rate 5/20-6/14/85 95 hours0.0011 days 0.0264 hours 1.570767e-4 weeks 3.61475e-5 months testing; and vital batteries.

85-24 Specialists Preoperational' test program implementations; 5/20-24/85 67 hours7.75463e-4 days 0.0186 hours 1.107804e-4 weeks 2.54935e-5 months emergency diesel generator status; pre-core hot functional test status; test procedure review and verification; new fuel receipt, inspection and storage; quality assurance and quality con-trol interfaces; facility tours.

85-25 Specialists Preoperational test program; test procedure re-6/24-27/85 82 hours9.490741e-4 days 0.0228 hours 1.35582e-4 weeks 3.1201e-5 months views and witnessing.

Emergency diesel genera-8/8-11/85 tor status; quality assurance and quality con-trol; and identification of new EDG components.

85-26 Resident Steam generator "J" tube modifications; eddy 5/28-8/8/85 151 hours0.00175 days 0.0419 hours 2.496693e-4 weeks 5.74555e-5 months current testing and tube plugging; preparations for Containment Structural Integrety Test; IE Bulletins; Preoperational testing.

85-27 Specialists Preoperational test program; EDG status; pro-6/3-7/85 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months posed technical specifications status and re-view; test procedure review and verification; engineered safety features tests; pre-core hot functional tests; valve problems: turbine building _ hot functional tests; cm.tainment HVAC; new fuel receipt, inspection and storage; qual-ity control and quality assurance interfaces; facility tours.

85-28 Specialists Installation of safety-related instrumentation 6/3-7/85 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months and associated control circuits.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED 85-29 Specialists Engineering' Assurance In-Depth Technical Audit:

5/28-29/85 inspection of the program preparation.

85-30 Specialists Continuation of Preoperation Security Reviews; 6/17-21/85 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months review of receipt, storage, and protection of new fuel.

85-31 Specialists Engineering Assurance Program Technical Audit 6/24-28/85 Implementation: inspection of program 85-32 Specialists Followup of violations, unresolved and construc-8/8-12/85 58 hours6.712963e-4 days 0.0161 hours 9.589947e-5 weeks 2.2069e-5 months tion deficiency reports; verification of FSAR commitment to Reg. Guide 1.94 for exemptions from concrete testing.

85-33 Specialists Containment leakage testing program: review, 7/5-15/85 106 hours0.00123 days 0.0294 hours 1.752645e-4 weeks 4.0333e-5 months witnessing and evaluation of integrated leak rate test, structural integrity test, and local leak rate test, and online primary containment leakage monitoring; facility tour.

85-34 Specialists Installation of safety-related electrical /in-7/8-12/85 68 hours7.87037e-4 days 0.0189 hours 1.124339e-4 weeks 2.5874e-5 months strumentation components and associated cir-cuits; quality control documentation and open items.

85-35 Resident Preoperational inspections; repairs to condenser 7/9-8/12/85 201 hours0.00233 days 0.0558 hours 3.323413e-4 weeks 7.64805e-5 months air piping; auxiliary feed pump endurance runs; allegations; electrical termination for diesel generators; event follow up; steam generator wet layup; status of reactor water level moni-toring; and status of Safety Parameter Display System.

85-36 Specialists QA/QC administration; audit program; procurement 7/22-26/85 111 hours0.00128 days 0.0308 hours 1.835317e-4 weeks 4.22355e-5 months program; receipt, storage and handling program; record storage program and document control program.

85-37 Contractor Inspection / evaluation of specific aspects of 7/8-19/85 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months licensee's Probabilistic Safety Study to assess whether significant discrepancies exist between Technical Specifications, the Final Safety An-alysis Report, the Safety Evaluation Report, and the as-built configuration.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

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85-38 Specialists Preoperational test program procedure review, 7/15-19/85 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months test witnessing and evaluation; ESF test status;

Emergency Diesel Generator status; Quality As-i surance and Quality Control; ESF valve testing.

85-39 Specialists Emergency Planning Implementation Appraisal;

7/22-26/85 organization, training, emergency facilities,.

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equipment and emergency implementing procedures.

85-40 Examiner NRC licensee meeting to discuss operator lic-7/8/85 ensing examinations for Millstone 3.

85-41 Specialists Quality records and work activities related to 8/5-9/85 35 hours4.050926e-4 days 0.00972 hours 5.787037e-5 weeks 1.33175e-5 months the inspection and testing of safety-related

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electrical equipment and open items.

85-42 Specialists Chemistry and radioactive effluent control pro-8/5-9/85 76 hours8.796296e-4 days 0.0211 hours 1.256614e-4 weeks 2.8918e-5 months grams organization, and staffing, training and qualification facilities, equipment, plans, and procedures.

85-43 Specialists Preoperational test program procedure review, 8/5-9/84 87 hours0.00101 days 0.0242 hours 1.438492e-4 weeks 3.31035e-5 months test witnessing, and evaluation; review status j

emergency diesel generators; engineered safe-guards test status; quality assurance and quality control.

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85-44 Examiners Oral, written,-and simulator examinations for

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Senior Reactor Operators and Reactor Operators.

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l 85-45 Examiners October 1985 examinations, outside the SALP assessment period.

85-46 Specialists Open item followup; ASME Code N-5 certification 8/12-16/85 226 hours0.00262 days 0.0628 hours 3.736772e-4 weeks 8.5993e-5 months program; stress reconciliation program, struc-

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tural steel bolting; welding (structural steel, pipe support, tack weld); preservice inspection data for RCS piping; applicants response to IE Bulletin 79-02.

85-47 Specialist Dosimetry program: open items, organization 8/5-9/85 75/25 hours ** ~ personnel selection, facilities and equipment, calibrations, dose assessment, quality assur-ance, documentation and recordkeeping, indepen-dent performance.

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INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED 85-48 Specialists Continuation of preoperational security reviews; 8/5-9/85 25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months review of receipt, storage and protection of new fuel, review of proposed consolidated site security.

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85-49 Specialists Operational Q.ality Assurance Program for design 8/19-23/85 107 hours0.00124 days 0.0297 hours 1.76918e-4 weeks 4.07135e-5 months changes and modifications, tests and experiments,

. measuring and test equipment, and Safety Com-

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mittee activities.

85-50 Specialists Allegation and open item followup in electrical 8/12-16/85 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months area.

85-51 Specialists Preoperational test program OIL witnessing of

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8/19-9/13/85 184 hours0.00213 days 0.0511 hours 3.042328e-4 weeks 7.0012e-5 months Engineered Safeguards Features (ESF) tests, reactor plant component cooling water pump per-formance test, normal service station transfor-mer test, and the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months testing of Emergency Diesel Generator EDG-3; test result evaluation; and assessment of EDG status.

l 85-52 Resident Review of Main Condenser Structural 8/13-9/23/85 238 hours0.00275 days 0.0661 hours 3.935185e-4 weeks 9.0559e-5 months Reports, diesel generator reliability, Three Mile Island items, main steam indication and cable repair, Safety Evaluation Report Items, prevention of cable damage, potentially significant deficiencies and open items.

85-53 Specialists Capability to shutdown plant in event of design 8/19-9/23/85 172 hours0.00199 days 0.0478 hours 2.843915e-4 weeks 6.5446e-5 months basis fire; emergency lighting; reactor coolant pump oil collection system.

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- - Site inspection; Millstone 3 one-third of total hours.

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TABLE 4 ENFORCEMENT DATA (September 1, 1984 - August 31, 1985)

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MILLSTONE NUCLEAR POWER STATION, UNIT 3 A. Number and Severity level of Violations and Deviations

1.

Severity Level

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Severity Level I

Severity Level II O

j Severity Level III O

Severity Level IV

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Deviations

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Violations and Deviations vs. Functional Area ja

1 Severity Level Functional Area IV V

Deviations A.

Operations

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Radiological Controls

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Maintenance

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D.

Surveillance

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Preoperational Testing

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Fire Protection

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G.

Emergency Preparedness

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H.

Security

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Construction

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Licensing Activities

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TOTAL

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Listing of Violations and Deviations l

SEVERITY FUNCTIONAL

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REPORTS DATES SUBJECT REFERENCE LEVEL AREA 84-20 9/30-11/10/85 Failure to maintain Appendix B IV I

control of low hydrogen Crit. IX welding electrodes j

84-23 10/22-26/85 Failure to follow elec-Appendix B V

I trical installation Crit. V

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procedures 85-04 2/19-3/1/85 Failure to translate Appendix B IV I

3/11-22/85 class 1E wiring design Crit. III

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requi.rements into docu-ments

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tructions for post-Crit. V~

wiring changes and document control l

Failure to establish Appendix B IV I

measures to assure pur-Crit. VII

.l chased equipment con-

forms to procurement

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documents i

Failure to establish con-Appendix B IV I

trols to prevent use of Crit. VIII incorrect / defective l

items Inspection program did Appendix B IV I

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not verify conformance Crit. X i

with design documents Failure to assure con-Appendix B IV I

ditions adverse to Crit. XVI.

quality promptly identi-j fied 85-12 3/18-4/22/85 Failure to provide ade-Appendix B IV E

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quate procedure for Crit. V testing and flushing

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85-16 4/23-5/27/85 Failure to provide ade-Appendix B.

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quate procedure for Crit. V flushing i

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SEVERITY FUNCTIONAL REPORTS DATES SUBJECT REFERENCE LEVEL AREA 85-22 5/20-6/14/85 Failure to properly con-Appendix B.

IV I

trol nondestructive ex-Crit. IX aminations

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Failure to properly Appendix B V

I identify welds on con-Crit. V trol drawings

i 85-23 5/20-6/14 Failure to provide ade-Appendix B IV E

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quate procedure for Crit. V flushing 85-33 8/19-8/23 Failure to provide hy-Fire Protec-DEV F

drogen recombiner area tion Evalu-and several floor levels ation Report of main steam valve en-closure with fire detec-tion and steel members of ESF building walls not fire proofed.

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ENCLOSURE 3 e

UNITED STATES

[ps!v NUCLEAR REGULATORY COMMISSION f

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REGION I

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$31 PARK AVENUE E

f KING OF PRUSSI A. PENNSYLV ANI A 19406

DEC 2 71985

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,

Docket No.

50-423 Northeast Nuclear Energy Company ATTN: Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06101 l

Gentlemen:

j Subject:

Systematic Assessment of Licensee Performance (SALP) Report No.

50-423/85-99 The NRC SALP Board has evaluated the performance of activities at Unit 3 of the Millstone Nuclear Power Station for the period from September 1, 1984 through August 31, 1985. The results of this assessment are documented in the enclosed

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SALP Board Report dated November 4, 1985.

A meeting to discuss the assessment is being separately scheduled during January 1986 at NRC Region I.

The overall per-formance of Northeast Utilities will be addressed after we have had the opportunity to discuss with you the Board's assessments.

At the SALP meeting', you should be prepared to discuss our assessments and your plans to improve performance.

The meeting is intended to be a dialogue wherein any comments you may have regarding our report may be discussed.

Since you pro-vided your perspectives on the SALP in advance of the SALP Board's review, I un-derstand that the factual information you noted was also considered by the Board in assessing your performance at Millstone Unit 3.

Notwithstanding, there may be

different views expressed in the report due to our observations.

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Additionally, within 30 days after the meeting, please reply in writing to the SALP j

Board's findings.

That reply should describe your plans to respond to the SALP Board's recommendations and it may also include comments on the SALP Report or the

SALP Program.

After your reply is evaluated, we will supplement the SALP Report (if necessary), transmit the final report to you, and place the final report in the NRC Public Document Room.

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Your cooperation is appreciated.

Sincerely, NA Thomas Regional Administrator

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Enclosures:

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SALP Report No. 50-423/85-99 2.

Northeast Utilities Letter B11640, dated 9/17/85

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Northeast Nuclear Energy Company

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t cc w/ encl:

l V. Papadopoli, Construction Quality Assurance Supervisor

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E. R. Foster, Director of Generation Construction E. J. Mroczka, Vice President, Nuclear Operations D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing W. D. Romberg, Station Superintendent Public Document Room (PDR)

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Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector State of Connecticut

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ENCLOSURE 4

NORTHEAST UTILITIES

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HARTFORD. CONNECTICUT 06141-0270 (203) 66s-s000 September 17,1983 Docket No. 50-423

_B11640 Mr. R. W. Starostecki, Director SALP Board Chairman Division of Project and Resident Programs U. S. Nuclear Regulatory Comrnission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 Systematic Appraisal of Licensee Performance (SALP)

Northeast Utilities (NU) places high priority on achievin of performance.

The SALP ratings provide NU with one assessment of our performance in those areas of activity evaluated by that program and achievement of superior ratings provides an indication that our management controls are functioning properly and that our primary corporate goal of strivin for excellence in the maintenance of nuclear safety is being realized.

In the past, we have met to discuss the SALP ratings and NRC's evaluation of our initial NRC SALP report. strengths and potential areas for improvement subs As a result, the initial reports have at times not by an exchange between ourselves and NRC. To maxi consideration of relevant views, we are taking this opportunity to provide some of our perspectives on our level of performance on Millstone Unit No. 3 du the past year.

We believe it necessary for us to interact positively with the Staff whenever it is given the finite resources at the disposal of both NU and the interest of further improving the regulatory process and assuring that through discussion, all aspects of a proposed action are understood and considered by NRC and NU. A significant factor which should be considered in and quality of the exchange with the regulators, both

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with the NRC and participating actively in efforts to disseminate needed information to the industry. Northeast Utilities executive management is active before the Commission as well as meeting with individ appropriate. The NU management team is active in, and in some instances chai various industry groups addressing a broad range of nuclear issues.

We also I

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consistently attempt to further improve the quality of the regulatory process by taking the opportunity to provide comments on proposed rulemakings and generic letters as evidenced in the examples provided in Attachment L During this SALP assessment period all major construction and test milestones have been met to support the November,1985 fuel load date.

As of the end of August, the Millstone Unit No. 3 project is 98.2% complete which is 1.8% above the management target.

that have occurred during this SALP period are as follows:Some of the key Completed Steam Generator Hydrostatic Test o

Completed Reactor Coolant System Hydrostatic Test o

Completed Millstone Unit No. 3 Emergency Drill o

Completed Structural Integrity Test and Integrated Leak Rate Test o

Completed Engineering Safety Features Test o

Conducting Turbine Building Hot Functional Test o

in June,1985 a!! system turnovers were completed and any building turnovers that remain will be completed on a schedule that supports the November,1985 fuel load date.

Licensing activities during this SALP period have been at a high level.

Millstone Unit No. 3 Safety Evaluation Report (SER) was issued in July,1984.

The The. SER identified 19 open items, 70 confirmatory items and 7 licensing conditions.

Most of these items have been resolved and have ieen or will be documented in SER s applements. The remaining issues have resolution schedules which support the November,1985 fuel load date.

During this period numerous meetings, site audits and reviews and conference calls have been held to supp licensing activities.

Also, during this period several amendments to the FSAR well as NRC questions resulting from site audits or re management involvement, clear understanding of technical issues, timeliness, and responsiveness to NRC initiatives.

demonstrating this are provided in Attachment I to this letter. Examples of individua Regarding day-to-day licensing activities, our licensing staff is consistently v responsive to the NRC Licensing Project Manager.

As a result of a recommendation received from the NRC Project Management, been made to improve the interface with NRC by establishing a single point of changes have contact within the NU licensing staff. This has centralized and helped prioritize Project Manager and our licensing staff. The NRC Li routinely NU's licensing activity status and schedule for response to a remaining SER items and identified licensing actions to OL issuance.

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in general, we. believe that this information rnay prove useful in your

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j Should you have any questions, please contact us.

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Very truly yours,

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Senior Vice President

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Vice Pre ent

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cc:

E. L. Doolittle, Licensing Project Manager, NRR

E. B. McCabe, Chief, Reactor Projects Section 3B, DPRP j

T. E. Murley, Regional Administrator j

i T. Rebelowski, Senior Resident inspector, Millstone Unit No. 3 i

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ATTACHMENTI

_1_nputs to SALP Evaluation Process The following items provide summary examples of some of the meetings, l and other activities which we believe are relevant to the SALP e process for Millstone Unit No. 3.

pertinent issues and documents and is not intended to suggest th not discussed herein are less important.

The NRC staff performed Seismic Qualification Review Team (SQRT)

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and Pump and Valve Operability (PVORT) Audits during the week of March 4,1985.

At the audit exit meeting, the Staff praised the responsiveness and diligence of NNECO personnel in questions raised by the Staff during the document review phase of theanswerin audit.

The Staff indicated that all questions raised during the audit qualification program and a thorough understanding to maintain seismic qualification throughout the life of the plant

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During the Construction Appraisal Team (CAT) Inspection, conducted

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between February 19 and March 22,1985, four Construction Weaknesses were noted and subsequently identified in the Inspection Report (50-423/85-04).

Although no specific response inspection Report, NU provided the NRC our planned course of action was required by the for each of these items in a letter dated July 11, 1985.

We subsequently received a request from NRC to provide a response to these weaknesses and to six violations that were identified separate

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Millstone 3 management's commitment to take an

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responding to NRC concerns and proposing timely corrective actions.

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We subsequently responded to the violations in an appropriately docketed follow-up letter.

On May 21,1985,

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Assessment Branch (RAB). The purpose of the visit wa commitments related to the Radiation Protection program including staffing, radiation monitoring and plant design features included to maintain radiation exposures ALARA. Various aspects of the Radiation Protection Program and the Health Physics Organization were discussed with the Health Physics Supervisor and a tour of the plant conducted. The NRC reviewer was very satisfied with the Radiation was Protection Program and the facilities.

NNECO had qualified personnel and was well prepared to implem Radiation Protection Program.

i On June 5,1985 NNECO was granted a schedular exemption to General

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whip restraints for primary loop piping. Design Criterion and agency studies which a!! owed the NRC S plant safety, reduces the accessibility for and effe

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-2-service inspection, increases in-service inspection radiation dosages, and adversely affects construction and maintenance economics."

The NRC published the proposed modification to GDC 4 in a July 1,1985 Federal Register notice.

At NU's option, since this is not a licensing requirement, a simulator

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training and examination program was developed and implemented for Millstone Unit No. 3. The Millstone Unit No. 3 simulator was delivered to the site in December 1984. Following installation, the simulator entered a verification test phase which was completed on January 15, 1985. From January 15, to February 11, 1985, the simulator was used to test the training program curriculum and to validate the simulator against this curriculum. On February 11,1985 training on the simulator commenced. Each cold license candidate receives 5 weeks of simulator training which includes 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months of actual simulator experience, along with 75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months of classroom training.

The accelerated program culminated in the administering of the NRC operator licensing exams on the simulator for our first class of cold license candidates, beginning on May 13,1985.

The implementation of the simulator training and examination program is an example of NU's proactive stance and responsiveness to NRC initiatives.

An allegations program was developed and implemented. It consists of

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the following elements:

A full-time administrator has been appointed for providing

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overall coordination for allegation reviews. He will report directly to our Vice President-Generation Engineering and Construction and is located on site.

A visible, on-site facility designated the Quality Concern

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Office (QCO) has been established where allegations regarding project safety can be expressed with an individual independent of Project Management with a guarantee of anonymity.

A full-time consultant has been hired and is stationed at the site to work with us in establishing our allegations program. This consultant has been involved with worker allegations in the past and is familiar with the processes being used at other sites.

An Allegation Review Team (Review Team) has been

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i established to review safety concerns raised and to determine whether or not there is any basis for the a!!egation.

The Review Team responsibilities are delineated in a specific project procedure as well as in a specific charter which has been established.

The Review Team is comprised of key management personnel who have a wide range of backgrounds l

and extensive experience in the nuclear industry.

An Independent Review Board is being assembled to conduct

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-3-which has been determined by the Review Team to potentially have substance. This Board will be comprised of one or more individuals who have expertise in the areas of labor relations, law, nuclear construction, and quality assurance / quality control.

NRC regulations do not require that an emergency preparedness

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exercise be performed for Millstone Unit No. 3 prior to receipt of a full-power operating license since the operating license for Millstone Unit No. 3 will not be the first operating license for the Millstone site.

Nonetheless, an onsite emergency preparedness drill for Millstone Unit No. 3 was conducted on May 15, 1985 to validate the Millstone Unit No.3 specific aspect.s of the Millstone Nuclear Power S tation Emergency Plan. This drill is illustrative of our efforts (beyond those necessary to obtain an operating license) to assure ourselves that we are ready to operate Millstone Unit No.

3 in a manner that will adequately protect the public health and safety. The Millstone Unit No. 3 drill was quite successful and demonstrated the readiness of our organization to respond to an emergency at Millstone Unit No. 3.

The NRC Staff conducted an audit of the Safety Parameter Display

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System (SPDS) for Millstone Unit No. 3 on July 29-30,1985.

Although a formal audit report has not yet been received, the NRC Staff indicated at the exit meeting that our overall program was quite good and that they were impressed with the type of program which we had implemented. On a related matter, unsolicited responses to several NRC concerns were formally provided to the NRC two (2) months before the SPDS audit in an attempt to expedite resolution of these items during the audit.

In the resolution of fire protection issues we believe we have exhibited

a clear understanding of the issues and conservative, sound technical approaches are routinely employed.

For example, the information provided in support of the suppression systems in the cable spreading area and other areas was judged by the NRC staff to be a valid and acceptable justification for the existing design. Other examples of our pro-active approach to addressing issues are the docketed submittals and meetings with the NRC fire protection reviewer well in advance of the Fire Protection Audit. We identified potential deviations to the NRC along with thorough technical justifications in advance to resolve them without waiting for the audit to be conducted. The NRC Fire Protection Audit for Millstone Unit No. 3 was conducted at the site from August 19 through 23,1985. The audit was successfulin that NRC questions were promptly addressed and there were very few significant

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items requiring followup af ter the audit. The staff observed that the t

engineering analysis for safe shutdown of the plant was one of the best observed, to date.

There has been a high level of NU management involvement noted by

the auditors for all of the NRR audits conducted at the site. A high i

level of management review and approval of all correspondence to the l

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NRC is procedurally required at NU, this ensures a consistently clear licensee understanding and reponsiveness to NRC initiatives.

In letters dated October 26, 1984 and February 19, 1985, NU provided

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documentation of our assurance that Millstone Unit No. 3 had been designed and constructed in accordance with applicable requirements based on Stone & Webster Engineering Corporation (SWEC) Engineering _

Assurance (EA) Program, our strong Quality Assurance Program and other verification programs. The NRC concurred on April 17,1985 that a separate Independent Design Verification Program (IDVP) or an Integrated Design Inspection (IDI)' conducted by the Staff was not necessary to achieve design assurance for Millstone Unit No. 3 and approved SWEC's EA audit as an acceptable alternative to a third party review performed at the end of design and construction efforts.

We feel the above examples serve to provide evidence of some of NU's efforts and accomplishments in the construction, licensing, and testing of Millstone Unit No. 3 during this SALP period.

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NORTHEAST UTILITIES o.nerai osc... s.iaen street. Bernn. Conn.ciicut

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L February 11,1986 Docket No. 50-423 A05472 Dr. Thomas Regional Administrator R egion I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Reference:

(1)

T. letter to 3. F. Opeka, Systematic Assessment of Licensee Performance (SALP) Report No. 50-423/85-99, dated December 27,1985.

Dear Dr. Murley:

Millstone Nuclear Power Station, Unit No. 3 Resoonse to SALP Report 50-423/85-99 In Reference (1), the Staff forwarded the Millstone Unit No. 3 SALP report for the twelve month period ending August 31,1985. On January 9,1986, a meeting was held between representatives of the NRC and Northeast Nuclear Energy Company (NNECO) to discuss the SALP Board's assessment.

As requested in Reference (1), we hereby provide, in Attachment A, our written responses and comments on the SALP Board's findings.

As we have stated to you in past meetings and letters on the subject, NNECO takes very seriously the assessments performed by the SALP Board as a gauge for evaluating and improving our performance. It remains our goal to achieve Category I ratings in all functional areas for subsequent SALP evaluations.

Attachment A describes some of the actions we will be taking to meet that goal.

As reflected by our comments and observations during the January 9,1986 meeting, we generally concur with the Board's observations and have previously taken or are now taking steps to address the issues identified.

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Despite our general agreement with the SALP assessment, there is one SALP finding with which we disagree. Specifically, pages 28 and 29 of the report

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discuss Licensing Activities. NNECO was rated as Category 2 in this functional area with a recommendation to increase management involvement in the licensing review process to assure timely resolution of licensing issues.

We contend that the very highest level of NNECO management attention wes i

focused on the resolution of licensing issues throughout the entire licensing process. We believe that this is exemplified by the commitment of necessary

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resources by NNECO management to resolve licensing issues in a thorough, technical manner; a fact which is acknowledged in this and other NNECO SALP assessments. NNECO's approach to meeting certain NRC requirements has been and will continue to be the use of the most appropriate engineering solution for Northeast Utilities in concert with its mandate to protect public health and safe ty.

We firmly believe that licensees should not be penalized for use of alternate or unique methods to meet NRC requirements as we seem to be in each of our Millstone Unit No. 3 SALP reports. We recognize that this may require more NRC attention in the review of a certain issue relative to others, however, this is not indicative of substandard performance on behalf of a licensee. Our views relative to this matter are provided in detail in the Licensing Activities section of Attachment A.

We trust that the actions discussed in Attachment A for addressing the SALP Board's findings in addition to our general comments will be considered in subsequent SALP assessments.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY E 011$w 3. F. Opekd V

Senior Vice President cc:

V. S. Noonan

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Docket No. 50-423 A05472 Attachment A Northeast Nuclear Energy Company Millstone Unit No. 3 Response to SALP Report Findings February,1986

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A-1 Functional Area: OPERATIONS SUPPORT Board Recommendation 1:

Review control of and training for jumpers and lif red leads, tagging, log keeping, and shift turnover requirements to assure controls are adequate for power operation.

Response 1:

The specific event referenced in the report, i.e., the fuel oil spill caused by overfilling of the fuel oil storage tank while transferring from one tank to the other has been reviewed, however, the complete report is not final and approved by the Plant Operations Review Committee nor plant management. Therefore, the complete corrective action assessment has not occurred. However, based on the information we have obtained about this event, we have conducted interim training through night orders and discussion with all operating shifts concerning the use of the shift turnover logs and the necessity for proper briefings and control of evolutions through shift turnover.

We have no indications currently that this is a generic problem to the routine conduct of operations. In addition to this event, there are other issues which we have addressed in preparation for the transition of the operations group from the startup testing phase into the plant operations phase.

In particular, we have completed training of all Plant Operations Review Committee members in the importance of safety evaluations during the review of bypass jumpers and lifted leads as an overview to the day-to-day operations of the Unit. We have also conducted specific discussions with the shifts as the startup testing and power operating phases are approached, in the necessity for proper shift turnover and log keeping. We will closely monitor our controls in all these areas to assure their adequacy for startup and power operation.

Board Recommendation 2:

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Assess whether formal methods and personnel orientation on correcting root causes are sufficient.

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i-Millstone Unit No. -3 currently uses the same procedures for incident reporting i

and investigation as Millstone Unit Nos. I and 2.

These procedures have proven

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to be highly effective in addressing root cause failure analysis and establishing the appropriate corrective action to prevent recurrence. At this time, we have

no indication that our Millstone Unit No. 3 procedure implementation is in any

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way deficient. The review of the diesel fuel oil overfilling event is discussed in s

Response 1, and it is emphasized that the investigation is still underway.

We have taken what we feel to be appropriate corrective actions by way of briefing the shift crews and placing additional emphasis on turnover practices, i

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Functional Area: R ADIATION CONTROL Board Recommendation:

Assure the FSAR accurately describes the solid radwaste system.

Response:

We have submitted, or processed for submittal, all necessary FSAR changes to ensure the description of the solid radwaste system reflects the as-built design.

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Board Recommendation:

Establish a schedule for the completion and implementation of maintenance related procedures and training programs.

Response:

We have completed preparation of all maintenance original scope procedures and surveillance procedures necessary to support preoperational ~startup testing and initial operations of the Unit. There are a number of specific maintenance procedures, notably in the instrumentation and controls area, which have not been approved in final form. These procedures, however, have been tested during the startup test program and are fully acceptable for performance of the work and approved at this time through the department. Each will be final approved prior to actual use. Our schedule is to complete the final approval ~of this small number of procedures by the end of 1986.

Any additional maintenance procedures. which are currently not prepared will be prepared, as required, to support any corrective maintenance evolutions on the Unit. At this time, all preventive maintenance procedures are in place and they are scheduled to be performed.

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Functional Area: SURVEILLANCE Board Recommendation:

Assure surveillance procedures support future planned testing and operations.

Particular emphasis should be placed on orderly development and review of procedures.

Response:

All surveillance procedures have been approved for use at Millstone Unit No. 3 and have been conducted, at this time, through Mode 1.

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Functional Area: PREOPERATIONAL TESTING Board Recommendation 1:

Upgrade timeliness of issuance of startup and power ascension test procedures and of evaluation of test results.

Response 1:

We have issued and approved all startup; test procedures through initial criticality and low power physics testing, and the majority of the procedures for power. ascension testing have been through approval by the Plant Operations Review Committee.

We have also completed the evaluation of all test Frocedures, on schedule, necessary to support the plant startup test program.

Board Recommendation 2:

Assure that any as-built plant, SAR, and Technical Specifications discrepancies revealed by preop tests are corrected.

Response 2:

We have submitted, or processed for submittal, all FSAR changes which we have found necessary as a result of startup testing and surveillance testing.

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None.

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A-7 Functional Area: EMERGENCY PREPAREDNESS Board Recommendations:

Increase management attention to assure corrective actions are accomplisaed~in a timely manner.

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This recommendation is directed at the delay in establishing an integrated emergency preparedness training and retraining. program.

This one-time situation resulted from delays due to a reorganization of the Nuclear Training Department and allocation of adequate resources to accomplish this task. The Training Department management was aware of the commitment ~ and was moving as rapidly as possible to complete the commitment.

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assistance was required. Final approved lesson plans, and Training Department procedures have been in place since early 1985.

All NRC comments and the licensees internal critique items in the emergency preparedness area are routinely tracked by the station emergency preparedness coordinator on a commitment follow system. We have instructed the station emergency preparedness coordinator and his supervisor to immediately inform their line function management and station management whenever significant commitments are not being met. This corrective action will ensure that NNECO management becomes aware of delays in meeting NRC commitments in a timely manner and additional corrective actions can be initiated as necessary.

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Functional Arm SECURITY Board Recommendation:

None.

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Functional Area: CONSTRUCTION Board Recommendation:

Assure more timely closeout of CDRs and outstanding items.

Response:

In accordance with Attachment 1 of the Millstone Unit No. 3 low power operating license, N PF-44, all outstanding construction deficiency (10 CFR 50.55(e)) reports had been submitted to NRC Region I prior to achieving initial criticality.

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Functional Area: LICENSING ACTIVITIES Board Recommendation:

Increase management involvement in the licensing review process in order to assure more timely resolution of licensing issues.

Response:

NNECO management has a high level of involvement in licensing issues. This is ack Towledged and well documented by the NRC in a number of SALP reports issued on all of our plants including Millstone Unit No. 3. All levels of NNECO management have focused a great deal of attention on the Millstone Unit No. 3 licensing issues during this SALP evaluation period. Given the resources and management applied to Unit No. 3, and the strict adherence to a construction, licensing and startup schedule that was established eight years ago, it is hard to conceive how any plant could have a higher level of management involvement.

The Staff recommendations are based on a conclusion that NNECO was unresponsive on three issues: 1) Technical Specifications,2) Seismic Interaction-and 3) Shift Staffing / Operating Experience.

NNECO disagrees with this conclusion.

NN EChbmitted Technical Specifications and provided a justification for all deviations for NRC review a year before the plant was licensed.

For 6 months following our submittal of the draft Technical Specifications, the NRC did not support NNECO's requests for meetings and review. An accelerated review schedule became necessary in the last half of 1985 because of the lack of NRC response on our draft Technical Specifications for 6 months, not because NNECO was unresponsive.

With respect to the Seismic Interaction program, the SALP report indicates NNECO's program was unknown to the Staff until identified by the NRC during the Engineering Assurance Audit Program Audit Report (June 1985). In fact, NNECO's method of compliance with Regulatory Guide 1.29 and our program was reviewed in detail with the NRC during the Construction Appraisal Team (CAT)

inspection conducted in February and March 1985. NNECO was very responsive to' NRC requests for further information as the program was expanded and was implemented.

Additional confirmatory analyses were performed to support specific staff requests.

With respect to Shift Staffing / Operating Experience the SALP report indicates NNECO made no attempt to pursue discussions with the Staff. NNECO's policy on Licensed Operators, Engineering Expertise-On-Shift and Shift Technical Advisors was identified to the Staff in late 1980.

In late 1983, NNECO

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responded to Staff surveys and open items identified in the draft Safety Evaluation Report for Millstone Unit No. 3. The Staff has been fully aware of NNECO's positions and NNECO has been responsive to all requests for information.

Therefore, NNECO disagrees with the Staff conclusions that NNECO was unresponsive. High levels of NNECO management were directly involved in these items. Our approach to meeting NRC requirements in these areas may have differed from preferred staff practice. However, we should not be penalized for using positions that may require more NRC attention relative to others. Such-x

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o instances should certainly not be construed as a lack of NNECO management f

involvement. We will continue to aggressively pursue with the staff the timely resolution of items affecting the unit's activities with the NRC in the future.

We anticipate _that adequate NRC management attention will be given to these topics to allow timely resolution.

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IR 05000423/1985099

Text

Enclosures:

REGION I

Dear Dr. Murley:

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IR 05000423/1985099

Text

Enclosures:

REGION I

Dear Dr. Murley:

Navigation menu

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