IR 05000423/1986012

Insp Rept 50-423/86-12 on 860414-18.No Violations Noted. Major Areas Inspected:Mgt Controls Over Surveillance Maint, QA & Fire Protection Activities.Strengths & Weaknesses at Facility Listed

ML20198E511
Person / Time
Site:	Millstone
Issue date:	05/08/1986
From:	Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198E500	List: IR 05000423/1986012 ML20198E496
References
RTR-NUREG-0737, RTR-NUREG-737 50-423-86-12, NUDOCS 8605280036
Download: ML20198E511 (28)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.: 50-423/86-12 Docket No.: 50-423 License No.: NPF-49 Priority --

Category C Licensee: Northeast Nuclear Energy Company

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P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Unit 3 Inspection at: Waterford, Connecticut Inspection conducted: April 14-18, 1986 Inspectors: T. Elsasser, Chief, Reactor Projects Section 3C T. Foley, Senior Resident Inspector, Calvert Cliffs A. Cerne, Senior Resident Inspector, Seabrook P. Bissett, Reactor Engineer R. Summers ro Engineer Approved by: /. W U T. C. Elsas g Chief, Reactor Projects Section 3C Date Inspection Summary: Inspection on April 14-18, 1986 (Report No. 50-423/86-12)

Areas Inspected: Special announced operational team inspection of the Millstone Unit 3 facility management controls over operational, surveillance, maintenance, quality assur6n e, and fire protection activities. The inspection involved 145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br /> onsite by two senior resident inspectors and two region, based inspector Results: No violations were identified. However, the inspection team did conclude that the following strengths and weaknesses (requiring-further licensee attention and/or written response) exist at Unit 3. These strengths and weaknesses are dis-cussed in detail in the attached inspection repor "

Strengths: (3) Licensee management is particularly strong, corporate and unit goals are detailed and communicated, meetings are succinct and controlled, a safety perspective is maintained in PORC meetings and daily activities, routine activities are well planned and controlled; (2) operators are professional, knowledgeable, and thorough in the conduct of control room activities, such as turnbvers and con-trol of surveillance activities, and Plant Incident Reports are effectively used to address problem occurrence and generic applicability; (3) management and opera-tors are knowledgeable and aware of Technical Specifications (TS) and Action State-ments in effect, the Maintenance Department uses an accurate computer-based system for scheduling surveillance, fire protection measures satisfy TS compensatory measures, and the Independent Safety Engineering Group and Operational Assessment 8605280036 860514 PDR ADOCK 05000423 O PDR

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Group effectively uses experience from the licensee's other plants; (4) QA/QC groups are adequately staffed and consist of well-trained, con:cientious indivi-duals, the new site QC surveillance program is being used as a management tool, and NUSCO Operational QA has been transferred to the site where the group can be

, more effectiv l i Weaknesses: (1) The number of lit annunciators in the control room is unreasonably high in relation to human factors considerations; (2) rubber-lined valves, suspected

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of having lining detachment problems, have not been adequately addressed; (3) an

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independent check of departmental surveillance test control lists has not been conducted; (4) communications between site QC and other site departments could be improve ,

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OPERATIONAL TEAM INSPECTION

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MILLSTONE UNIT 3 TABLE OF CONTENTS Page Scope................................................................ 1 2.0 Inspection Process................................................... 1 3.0 Plant 0perations..................................................... 1 3.1 Control Room Annunciators....................................... 1 3.2 Control Room Activities......................................... 4 3.3 Main Control Board Layout and Indication........................ 5 3.4 Post-Trip Reviews and Incident Response......................... 6 3.5 Operations Control for Maintenance / Surveillance................. 7 3.6 Independent Verification........................................ 8 3.7 Maintenance Managemen ........................................ 9 3.8 S u mni a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 4.0 Technical Specification Compliance Monitoring........................ 11 4.1 Management Controls and Awareness............................... 12 4.2 Surveillance Progran............................................ 13 4.3 Planning and Centrol............................ ..,............ 13 Independant Technical Specification Monitorin 15 Fire Protection..............................g.................. ................... 15 Summary......................................................... 16 5.0 Quality Assurance / Quality Control.................................... 17 5.1 Organization............... .................................... 17 5.2 NNEC0 QA........................................................ 18 5.3 NUSCO QA........................................................ 20 Summary...............................................,......... 21 6.0 Observations o f Licensee Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

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6.1 Unit Meetings................................................... 22 6.2 Nuclear Safety Engineering Group................................ 24 7.0 Persons Contacted.................................................... 24 8.0 Management Meeting................................................... 25 i

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1.0 Scope Millstone Unit 3 received its full power license on January 31, 198 To assess the facility's operational effectiveness, particularly as it pertains to transition from the startup testing phase to normal operation, NRC Region I conducted a team inspection on April 14-18, 1986. The inspection focused on the adequacy of controls over operational, surveillance testing, and main-tenance activities by direct observation, personnel interviews, and program review. Particular emphasis was placed on the interfaces among the various groups with responsibilities for planning, accomplishment and review, and on plant management oversight and review of these activitie .0 Inspection Process The inspection team, consisting of a Team Leader and four inspectors, observed operational and turnover activities on all three shift Interviews were conducted with the Unit 3 S'merMtendent, all department heads, and the onsite QC manager. Comprehensive tour: of the facility were conducted to observe fire protection, housekeeping, operational, and maintenance activities. The NRC senior resident and resident inspectors, assigned to Millstone Units 1, 2, and 3, were not formally part of the team, but interacted frequently with the team regarding the conduct and findings of the inspectio Since the site already contains two operational units, particular emphasis was placed on determining if operations at Unit 3 were completely integrated with overall site operational activitie Also, since tho facility is in transition from startup testing to an operational status, an evaluation was made to determine readiness of the plant to make this shif .0 Plant Operations 3.1 Control Room Annunciators During the team inspection and while the reactor was at 90% power, the control board annunciator panels routinely displayed approximately 100 energized annunciators. As many as eleven new annunciators in one period were energized, then silenced but not acknowledged, i.e., the operator recognized and silenced the alarm but left the specific alarm " flashing" until the cause of the condition was determined. More often approxi-mately six annunciators were continuously left flashing unacknowledge Discussion with the operations staff and reactor operators revealed that nuisance alarm However, two annunciators, the "com-most puter" were simply' radiation monitor" were significant in that they indi-and the cated when other multi point status devices were also in an alarm condi-tion. In other words, a later input by an out-of-specification parameter could be masked by the already lit annunciators and may not be recognized by the operator .

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D'iscussions with the plant superintendent indicated that the licensee recognized the problem and was actively. pursuing corrective ~ actio A !

list.of lit annunciators and the cause of each das provided to the in- :

spector by.the management representatives. An independent review of each alarm was conducted by the inspector who categorized the alarms as fol '

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lows: Real alarms in which action had been required - about 20%. Alarms which were energized due to continuance of testing at a par-ticular phase of construction / operation - 5%. Alarms due to the system being intentionally out of-service; tagged out as inoperable - 10%. Alarms caused by a broken. device within the system or associated with the alarm function which was'under repair - 10%. ' Alarms caused by inappropriate setpoint adjustments to the alarm or to the system - 15%. Alarms caused by, design, i.e., alarm is normally energized at power operation or is providing information that a system or device is operating as designed - 40%.

Several of the annunciator units requiring a setpoint change were_close to the actuation point, causing the unit to clear and then recur; this requires repetitive action and unnecessary attention by the operato Operatcrs were continuously responding to these nuisance alarm Sig-nificant recurring alarms in this category consist of:

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" Radiation' Alert Alarm" due to Radiation Monitoring System (RMS)~

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voltage adjustments. The licensee is' actively (daily) working'on this as observed during the inspection. Operators must refer to the Radiation Monitoring compute'r each time-the annunciator is energized to determine what parameter is alarming. Operators in--

dependently evaluate the condition and acknowledge the alar Problems associated with the RMS causing approximately190 ESF actu--

ations (i.e., Control Building Isolations) per month.are' described in Inspection Report 50-423/86-02. As a result of troubleshooting, the licensee has made some minor changes, Land is presently pursuin with the vendor.more major design changes to resolve thistissu ."Feedwater Heater Hi/Lo Alarm" due to an unstable heater level con-

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Operators must'have the alarm verified by the Equipment

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Plant Operator and take corrective actio '

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" Turbine Vibration Hi Alarm" due to actual turbine vibration being 6.5-7.0 mils and the alarm setpoint being 7.0 mils. The Operations Department is attempting to reduce vibration by raising turbine lube oil temperature.

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The more significant alarms in a continuously energized state are as follows: i

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" Loose Parts Monitor Alarm" - a real alarm which repeatedly actuates and the operator does not reset. This system is apparently being adjusted at each power level to obtain and evaluate reference value " Computer Trouble Alarm" - due to numerous computer inputs requiring adjustments. Minor difficulties exist in the interface between the computer group and the operational group reading the compute trouble alarms. Personnel are actively pursuing resolutio " Pressurizer Safety Valve Discharge Temperature High"

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" Pressurizer Relief Tank (RPT) Pressure High"

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" Pressurizer Discharge Flow Alarm" The above three alarms are due to pressurizer safety valve weepag Discussion with the operators revealed that although no alarm func-tion would be available, Pressurizer Relief Tank (PRT) Pressure, Temperature and Level indication would still be available to ascer-tain if a safety valve lifted. Additionally, the tailpipe tempera-ture indication would proportionately increas This problem is further discussed under Paragraph In summary, NRC concerns are as follows: Operators may be developing a sense of complacency in that when alarms are either continuously energized or repeatedly cleared and re-energized, the operators may not recognize or believe an actual alarm indication and respond appropriately.

. If several annunciators are continuously flathing in the unacknow-ledged state, and a truly abnormal condition exists in another an-nunciator unit, operators may not readily distinguish which annun-ciator is the new, real alar i Annunciators which are either continuously recurring or in the energized state may distract the operators from monitoring plant parameter ._ _ _

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Plant management is aware rf the problems and is actively pursuing reso-lutions to the above annunciator problems. Observations of and discus-sions with operators reveal that they are knowledgeable, alert, and at-tentive to plant conditions. When questioned about each alarm, operators demonstrated knowledge of the annunciators' statu However, Unit 3 management is encouraged to continue trouble-shooting of these nuisance alarms and strive for a " Blackboard" concept, i.e.,

no lit annunciators. The condition where a high number of annunciators are continuously lit is perceived to be a significant weakness in the operations are .2 Control Room Activities The inspector observed control room activities, including shift turnovers and briefings on all three shifts; randomly interviewed operators and supervisors; reviewed the Shift Supervisor and turnover logs; and ex-amined operation and design reference material available in the control roo The following procedures were reviewed with respect to their administra-tive control of control room activities:

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ACP 6.01 - Control Room Procedure

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ACP 6.12 - Shift Relief Procedure

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ACP 10.05 - Log Book Requirements Other ACPs which could impact control room activities as " standing or-ders" were spot checked, as were specific operating procedures (0P) pro-viding direction to the control room operators. None of the control room activities observed or operational items inspected were found to be in violation of the documented procedural requirement The observation of shift turnovers and examination of shift turnover logs and routine shift logs revealed the transmittal of accurate and complete information, both orally and in writing, in a professional manner. The Shift Supervisor log, in particular, provided not only current plant status and a description of problem areas, but also applicable Technical Specification (TS) conditions. As an attachment to the turnover log, a computer listing of TS Limiting Conditions for Operation (LCO) and Action' Statements, updated by the Shift Supervisor, provided an effective TS monitoring ai The inspector examined the following categories of reference material available in the control ruom:

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Piping and Isometric Drawings (PIDs)

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Elementary One Line Electrical Drawings

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Process Control Block Diagrams

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Logic (LSK), Flow (FSK), and Electrical (ESK) Diagrams

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Operating procedures, including. surveillance, abnormal, and emer-gency operating procedures

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Instrument Loop Diagrams and Calibration Reports Interviews with the operators revealed they were knowledgeable of the available reference material. The inspector also observed operator

readiness to use such information (e.g., curve book data), when necessar In summary, the Unit 3 operator activities in the control room, including ~1 the demonstration of a professional attitude,- awareness of plant status,-

thoroughness of shift turnovers, and use of procedures and reference .

material, are considered a strength to the operations progra *

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3.3 Main Control Board Layout and Indication Two areas of the main control board (MCB) were selected by the inspector ,

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for evaluation of MCB mimic-layout accuracy. Both the Safety Injection (SI) system and the Reactor Coolant System (RCS) loop mimicking were-checked against the PID and training manual flow path design. - While no l'

errors were identified in the case of the SI system,-one minor' deviation on the RCS loop mimic was identified in that the Residual Heat Removal (RHR) hot leg injection was illustrated as discharging _into all four RCS locps, when in fact, only Loop 2 and 4 hot legs receive RHR discharge flow. The inspector also identified an RCS mimic omission, i.e., while normal Chemical and Volume Control _ System (CVCS) a ch'rginp is. illustrated,

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normal CVCS letdown from loop 3 is not mimicked. Both minor errors were discussed with the assistant operations supervisor. The licensee, who' t is considering appropriate corrective action,'should also' consider in- '

specting the entire MCB mimic design for similar errors and omission While examining the MCB, the inspector noted that the position indicating

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lights for each of the three Pressurizer safety valves were erroneously-'

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providing " Valve Open" signals. Each light operates off_ a flow switch (3RCS-FS48A, B, or C) that uses thermocouples to measure-temperature dif- "

l -ferential and convert the electrical output to a signal which is in-versely related to flow. .Thus, the intent of this.syst direct. indication of Pressurizer safety. valve position em in lineis towith provideTMI Action Plan (NOREG-0737),-Item II. '

Interviews with the operators revealed that despite the erroneous valve i position indications, the operators would be able to detect open Pres-

surizer safety valves through RTD tailpipe temperature indicators, PRT level and temperature indicators, and/or RCS pressure variations. How-ever, the existence of such erroneous MCB information appeared to be in i

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direct conflict with NUREG-0737, Item II.D.3 whose intent is to provide the operator with unambiguous indication of valve position (open or closed) so that appropriate operator actions can be take A Unit 3 Deficiency Report (DDR 779) had been issued on the erroneous signal for FS48A, B, and C, but had been closed based upon a Northeast Utilities memo (NED-85-086) dated December 23, 1985, recommending that the flow switch setpoints not be changed and that the operators use other indicators to determine Pressurizer safety valve position status. Since this memo appeared to be contrary to the requirements of TMI Action Plan Item II.D.3 and the corresponding discussion in Section 5.2.2.1 of the Unit 3 SER, the inspector questioned plant management as to whether im-plementation of corrective action on this system was intende The inspector was provided a copy of a NUSCO Millstone Unit 3 Engineering and Design Coordination Report (E&DCR N-EC 02918) dated April 11, 1986, which described the subject problem and proposed future corrective action to revise the switch setpoints once steady state plant conditions are reached. While this issue currently appears to be adequately addressed by engineering action, the inspector noted that the closure of DDR 779 was both premature and based upon an incorrect evaluation of the require-ments for direct indication of the Pressurizer safety valve position This improper closure of DDR 779 had, until the recent (4/11/86) issuance of the E&DCR, provided no record that a deficiency remained to be cor-rected. This item represents an isolated case of inadequately addressing a deficiency in a safety-related syste In a larger context and in line with the apparent weakness discussed in Paragraph 3.1 cn Control Room Annunciators, the Pressurizer safety valve position errors and, to a lesser degree, the MCB mimic errors discussed in this paragraph, represent weaknesses in the exactness to which the operators are provided correct and unambiguous control board informatio .4 Post-Trip Reviews and Incident Response The inspector reviewed three complete Post-Trip Review packages and two Plant Incident Reports (PIR) discussing plant trips. Of the seven trips which have occurred since Unit 3 achieved initial criticality, five of these events were reviewed by the inspector to evaluate licensee re-sponse/ action. The inspector ascertained that probable causes of the trips were established and corrective actions to prevent recurrence were implemented. Licensee Event Reports, pursuant to the requirements of 10 CFR 50.73(a)(2)(iv), were also issue The inspector reviewed Operations Procedure OP-3263 on Duty Officer re-quirements after a trip or ESF actuation and evaluated the reviewed document package Duty Officer checklists which provide an evaluation of the proper post-trip functioning of equipment and parameter response, as expected, were noted to have been completed in the Post-Trip Review

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proces Other OP-3263 forms, completed by the responsible operations personnel, were. reviewed and found to provide relevant information to the identification of the cause of the trip and the implementation of corrective action. The inspector spot-checked certain post-trip event corrective measures and identified no problems with.either corrective ,

action implementation or control / administration of the Unit 3 Post-Trip '

Review program.

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Several recent Plant Incident Reports (PIR), not related to plant trips, were also reviewed to verify proper management overview and reporting

of potentially reportable occurrences or safety conditions. In the case of all 20 PIRs reviewed, the cause of the event, corrective action, and measures to prevent recurrence were documented and the procedural re-quirements of Administrative Control Procedure, ACP-QA-10.01, for PIRs were followed. In several PIR examples, the inspector noted evidence '

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of additional inspections, reviews for generic applicability of the

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indicated a potential for future adverse impact. This aspect of the PIR program appears to be a strength because it addresses the potential for problem occurrence and illustrates corrective measures broad enough to

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! The inspector also witnessed control room response to a Steam Generator 1 (SG) level transient caused by feed / steam flow mismatch, as it occurred on the day shift (4/15/86). Operator response to the transient was both immediate and knowledgeable, with the switchover to manual control of l SG levels effectively reestablishing normal conditions. This transient

, was discussed with the oncoming operations shift personnel for subsequent i

swing and mid-shift turnovers. The inspector verified operations man-

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agement cognizance of the event and evaluation with the responsible en-gineering department to both determine a cause and implement a-fix.

[ With respect to all of the above incident-response review / inspection

activities, no violations were identified.

l 3.5 Operations Control for Maintenance / Surveillance

. The inspector observed operator interface during the routine maintenance i and surveillance activities in progres He spot-checked the Admini-strative Control Procedures (e.g., ACP-QA-2.02C on' Work Orders):for-

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evidence of programmatic controls directed toward including the on-shift-

. operators in all appropriate plant work activities (e.g., maintenance).

L Operations management and shift supervisory personnel were-interviewed regarding these interfaces and appeared-knowledgeable-and dedicated t +

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making them work effectively.

i The inspector noted that the " relief" shift supervisor was'used to aid i in the planning and coordination of maintenance and surveillance activi-ties. This practice promotes a thorough review of these activities from

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not only a Technical Specification compliance standpoint, but also a view

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as to whether plant conditions can. support the intended activity. . Since '

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the on-shift supervisor also reviews and approves the commencement of such work, an independent two-step review is achieved. The inspector also observed that the utilization of the relief supervisor in this capacity removes some of the administrative burden from the on-shift l

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supervisor, thereby allowing the onshift supervisor the time to more effectively monitor and control the operators and shift.

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In reviewing the plant surveillance procedures, specifically on the ASME Boiler and Pressure Vessel Code,Section XI pump testing, the. inspector

had noted some. missing information'(not all data was available because some startup tests were still in progress). A sample review of later revisions of those procedures revealed that the missing data /information 1 had subsequently been incorporated, as required. Discussions with both licensed and plant equipment operators on component lineups for either j surveillance or maintenance activities indicated that they were knowl-

, edgeable on not only the specific procedural steps, but also the.admini-1 strative control requirements (i.e., standing orders) as applicable to i surveillance and maintenanc l 1 No violations were identifie In fact, the operations control of and  :

i interface with maintenance and surveillance programs appears to be-a f strength at Unit 3.

! 3.6 Independent Verification i'

The inspector reviewed the licensee program for. independent position verification of safety-related components / systems, established to meet

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TMI Action Plan (NUREG-0737), Item I.C.6, as discussed in Section 13. of the Millstone 3 FSAR and Section 13.5.1.6 of the SER. He examined i

Administrative Control Procedure, ACP-QA-2.12, for System Valve Alignment

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Control and Operating Procedure, and GP 3260, on the Conduct of Opera-l' tions, which both establish guidelines for independent position verifi-t cation of those repositioned valves, circuit breakers, and control switches for safety-related and other important. systems. These systems.

are defined by Station Form, SF 227-3, as the " Listing of Procedures Re-quiring Independent System Alignment Verification."  ;

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. For those safety related components without remote position indication in the control room, independent verification is required at Unit 3 when-  ;

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ever the subject equipment is repositioned. If the change in component position is controlled procedurally (e.g., surveillance activities), the applicable surveillance procedure (SP) contains.a form for independent

verification of the affected components. If the change-in position re-sults from maintenance, outage or other management controlled activities, ,

3 v alve/ electrical lineup forms are utilized for correct position indica- l

tion and checks, with " dual verification" performed by.a second indivi-- '

dual subsequent to the initial check, provided as the method of indepen-dent verification.

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During this inspection, the NRC inspector examined a sample of surveil-lance procedures and valve and electrical lineups, which had been re-cently accomplished, to determine if the licensee's independent verifi-cation program was being correctly implemented. He spot-checked com-ponents, procedurally required to be repositioned, but not listed on the independent verification forms, to ensure that these subject components had control position indication, as committed. Shift supervisors were interviewed as to when " dual verification" would be required on valve or electrical lineups. The inspector also discussed the intent of the Unit 3 independent verification program with senior operatior,s management personne Generally, the independent verification program appears to be properly implemented, with the responsible supervisory and operations personnel cognizant of both the intent and requirements of the program. No viola-tions were identified as the procedural controls of those systems sampled by the inspector proved adequate evidence of program effectiveness. In the case of certain procedures, however, minor problems were identified as follows:

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Surveillance procedure, 3610A.1 on the "A" RHR pump (primarily a mechanical component surveillance), requires repositioning of an electrical circuit breaker and therefore, independent verification of the final breaker position is required. However, it appeared that independent verification was not performe Surveillance procedure, 3646A.2 on the "B" Emergency Diesel Genera-tor (primarily an electrical component surveillance), requires re-positioning of the fuel oil day tank drain valve and therefore, independent verification of the final valve alingment is require However, independent verification was not performe The inspector discussed this with senior operations personnel and was informed that in the case of SP 3610A.1, breaker restoration was ade-quately confirmed by subsequent stroking of the affected valve. In the case of SP 3646A.2, the licensee agreed that the valve repositioning should be independently verified. The licensee has agreed to review the procedures which involve more than one discipline to ensure that any component repositioned during a surveillance will have its required post-surveillance position verifie The inspector determined that, in general, components repositioned during surveillance are being independently verified for their final required positions; the above-noted valve not being independently verified for final alignment is considered an isolated case. Licensee steps to cor-rect this apparent weakness, in an otherwise strong Independent Verifi-cation program, are expected to make the implementation of this program even more effectiv , _ _ __ _ . _ _ _ _ _ _ _ . - . . . ._ . . _ . _ _ _ _ . ... =

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3.7 Maintenance Management

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The inspector reviewed a sample of recently completed, safety-related

] (i.e. , CAT 1) Authorized Work Orders (AW0) for evidence of proper plan-l ning and conduct of work, and QA/QC inspection involvement. He discussed-  :

i . the handling of AWO's under the Production Maintenance Management System t j (PMMS) with the Acting Maintenance Supervisor and reviewed the AW0's to

the criteria established by Administrative Control Procedure ACP-QA-2.02C

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for Work Order For all 25 AW0's sampled, procedural controls for authorization and-

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documentation were verified to have been followed. .Where QC involvement -

was required, acceptance criteria were noted and visual inspection was

conducted, as applicable,-in such areas as torque application, electrical

termination and crimping, housekeeping, material accountability, and in-

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ternal component cleanliness. The inspector confirmed that quantitative acceptance criteria (e.g., torque values) could be traced to the techni-cal reference (i.e. , a manufacturer's catalog) requiring use of the - -

documented value In all cases, each AWO documented the problem'and job description; the quality requirements, as reviewed by QC prior to the commencement of work; j and the actual work accomplished, with QC visual inspection, where re-

quired. As a result of the AWO review, the inspector. verified no viola-j tions or unresolved safety concerns existed.

Two of the AW0's (M3-86-07606 and-M3-86-07617) referenced NCR No. 386-0654 for implementation of corrective action.on the deterioration of the rub-ber lining of service water (SWP) valves MOV 102 A and C. The inspector

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reviewed this NCR and determined that while long term corrective action necessitated the replacement of the-lined valves with unlined valves of

suitable material, the immediate disposition was to remove all loose i lining, replace the valves and conduct in service inspection (ISI)

i ultrasonic thickness measurements on the valve bodies to monitor for-1 potential corrosion on those valves where the carbon steel was in direct

contact with the salt water. Interviews with the responsible engineers ,

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and review of ISI data and a special procedure (86-3-6) instituted for-the subject corrosion monitoring were reviewed.

I While no problems in the area of corrosion monitoring were identified, i the inspector did note that the NCR discussed two additional SWP valves

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to the valves for which the lining was removed. While these two addi-

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tional valves (MOV 102 8 and D) have been placed under the special pro-cedure for corrosion monitoring,1the acceptability of the lining on MOV 102 B and D, while suspect, has not-been determined, to date. Since.

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detachment of the valve lining could potentially plug,- in part, the downstream heat exchangers, the inspector' questioned licensee personnel

as to the technical justification for not requiring internal inspection i of the condition of the lining on theLsubject valves.

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While the licensee decision not to inspect the internal surfaces of MOV 102 8 and D at this time, appears to be based upon the rationale that the lining deterioration would exhibit itself in other ways, such a de-cision on a " Priority 1" (per ACP-QA-5.01) is perceived to be inconsis-tent with both the suspicion that M0V 102 B and D have been adversely affected and the fact that detection of future deterioration might occur at the same time the adverse impact (i.e., heat exchanger flow blockage)

would evidence itself. While the NRC recognizes management prerogative in such decisions, it believes that prudency dictates continued licensee evaluation of this rubber lining detachment problem, not only for the four noted valves (3 SWP MOV 102 A, B, C, and D), but also for any other l rubber lined valves which might exhibit evidence of a generic proble l 3.8 Summary Strengths

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Unit 3 operators maintain a professional attitude and awareness of plant status, conduct thorough shift turnovers, and appropriately utilize procedures and reference material The Plant Incident Report program addresses the potential for prob-lem occurrence as well as corrective measures broad enough to pro-vide generic effectivenes )

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The Operations Department maintains a good level of control and interface with the maintenance and surveillance program Weaknesses

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A high number of energized annunciators appears to continually exist in the control roo Main Control Board mimic errors / omissions represer.t incorrect and/or ambiguous control board informatio Inconsistency in dealing with M0V 102 B and D in light of problems with other rubber lined valve . Technical Specification Compliance Monitoring l The inspection team reviewed the licensee's programs to assure compliance with the plant Technical Specifications. This review consisted of interviews of-personnel; attendance at planning meetings, control room shift turnovers, and shift briefings; review of Station Administrative Control Procedures governing maintenance and surveillance activities; observation of surveillance testing in progress; and, independent verification of' selected Technical Specification Limiting Conditions for Operation (LCO). No violations of NRC requirements

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were identified during this review; however, certain strengths and weaknesses in the licensee's programs were identified and discussed with Unit 3 manage-ment as documented in the following paragraph .1 Management Controls and Awareness The licensee has implemented station wide procedures and practices that have been tried and proven successful during operations of Millstone Units 1 and 2. The inspector determined that Unit 3 has been integrated

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into these Station Administrative Control Procedures. Selected proce-dures that ensure Technical Specification compliance were reviewed for various attributes including, authorization of entry into LC0 Action Statements for repairs; monitoring of surveillance test intervals for equipment operability; and, monitoring and effecting shift communications during turnover of both LC0 status and offnormal conditions resulting from tests and/or maintenance activities in progress. The following procedures were reviewed:

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ACP-QA-2.02C, Work Orders

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ACP-QA-2.06A, Station Tagging ACP-QA-2.06B, Station Bypass / Jumper Control

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ACP-6.12, Shift Relief Procedure

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ACP-9.02, Station Surveillance Program The procedures implemented adequate controls of activities to ensure Technical Specification complianc Two notable strengths were apparent during the review of management con-trols, namely, planning meeting discussion and shift turnover practic The licensee management team routinely holds planning meetings daily to discuss various upcoming scheduled activities. As part of this schedule, a list of LC0 Action Statements that are in effect, including the required action, responsible department, and potential affect on scheduled acti-vities, is discussed. This discussion, at the senior plant management level, ensures a sound awareness of technical specification requirement In addition, the current shift turnover practice highlights the current LC0 Action Statements in effec A computer generated list of LCOs is attached to the shift turnover log which is required to be read and understood by oncoming shift personnel. Also, during the verbal brief-ings conducted as part of the shift turnover, various LCOs were fully discussed, based upon equipment availability due to maintenance or test-ing activities in progres _, _ _ _

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4.2 Surveillance Program The Unit 3 Surveillance Program is implemented through the Administrative Control Procedure ACP-QA-9.02. This procedure provides the guidelines through which Unit 3 and departmental Technical Specification surveil-lance responsibilities are accomplished. One minor discrepancy was noted with ACP-QA-9.02, in that it references ACP-QA-9.02C, " Unit 3 Master Surveillance Test Control List." The Unit 3 master surveillance list has not been incorporated into a Station ACP, and at this time, is not planned to be handled in that manner. However, the Unit 3 master sur-veillance list is being properly maintained as required by ACP-QA-9.02 by the Operations Department. This discrepancy was brought to the at-tention of the individual responsible for maintaining the master sur-veillance list so that action could be taken to either correct the reference or incorporate the surveillance list into the ACP, as has been done with Units 1 and The inspector reviewed the methods employed by the Operations, Instru-mentation and Controls, and Maintenance Departments to ensure completion of required surveillances. These three departments are responsible for completing most of the Technical Specification surveillance activitie The Master Surveillance Test Control (MSTC) List and the Department Test Control List (s) were reviewed on a sampling basis for completion and accuracy. No discrepancies were identified at that time. However, dur-ing discussions with the department planners and the QA/QC supervisor, it was determined that no independent audit or quality check of the De-partment Test Control Lists had been conducted to ensure that all of the required surveillance activities listed in the Master Test Control List were appropriately included. The licensee should consider performing an independent verification of the MSTC versus the Department Test Con-trol List (s).

4.3 Planning and Control The various departments each schedule and control surveillance activities in slightly different manner A brief description of each follow The Operations Department maintains the current MSTC Lis The Assistant Operations Supervisor inputs the department surveillance responsibilities into the corporate computer based Plant Maintenance Management System (PMMS). On a weekly basis, a "two-week look ahead report" printout is generated to determine the surveillance activities that need to be ac-complished. This report is used to schedule the required surveillances and is maintained current in the control room as the activities are com-pleted. In addition, the Operations Department maintains a second sur-veillance data base on a PC which is used to check the accuracy of the PMMS schedule. Actual scheduling of surveillances, to ensure that specified time intervals are not exceeded, is accomplished manually by

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the planner because PMMS does not have the capability to automatically control surveillance intervals based on technical specification allowed grace period In addition, the Assistant Operations Supervisor manually tracks sur-veillance completion on a copy of the MSTC List, which does provide added security that all Operations Department surveillance responsibilities are accomplishe The I&C Department schedules its surveillance responsibilities in a similar manner to Operations. The I&C planner inputs the department surveillances into the PMMS. A periodic look-ahead report is generate This report is used to schedule activities, which are then tracked through completion by use of a scheduling board. Once again, the sur-veillance test interval is manually controlled. In addition, a separate manual list of completed surveillances is maintained; however, the MSTC List is not utilized for this purpose, and therefore I&C is more depen-dent upon the PMMS data base being correct. When a specific activity is scheduled, the PMMS is used to generate an Automatic Work Order (AW0).

The AWO must be reviewed and approved by Operations (the Shift Supervisor or Supervising Control Operator) to ensure that the activity can be ac-complished based on plant / equipment conditions and within the Technical Specifications prior to starting the wor The Maintenance Department does not use the PMMS to schedule its sur-veillance responsibilities. They have developed an independent computer based tracking and scheduling system, which automatically schedules future surveillances based upon actual prior completion dates and ac-counts for the allowable surveillance intervals specified in the Tech-nical Specifications. The inspector reviewed the program and determined that the departmental surveillance activities are accurately schedule Once an activity is scheduled, the planner then inputs the item into PMMS which generates an AW0, which must then be reviewed and approved by Operations prior to implementation. In addition, a status board is also used to track the activity through completio Corrective and preventive maintenance activities are normally scheduled on the PMMS and accomplished via the AWO that is issue The AW0s for maintenance activities also are reviewed and approved by Operations prior to initiating work. Normally the AW0s are reviewed by the " relief" shift supervisor. (This individual is a qualified shift supervisor who is as-signed various operational support functions during off-shift periods ,

as part of a normal shift rotation.) This review is conducted to inte-grate scheduled activities and, in part, to identify potential Technical ]

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Specification implications. The AWO is then forwarded to the appropriate shift for final review and approval to start work. This practice appears to be a strength becaere it provides a two tier SR0 review of the AW0s prior to starting the work activity.

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4.4 Independent Technical Specification Monitoring ,

Daily, during the team inspection, the inspector verified LC0 compliance .

for selected control room parameters including the following:  ! Power Range Channel Operabilit ,

i Safety Injection Accumulator pressure, level, and flow path operability.

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ii Safety Injection Flowpath - motor operator valves power locked out as required; pumps and flowpath operabl i Containment Pressure and Temperature limits within specification t Rod Position Indication System operabilit v RCS Tavg within-specificatio '

3 vi Rod Insertion Limits maintained within specificatio vii RCS Leak Rate within specification.

l i Auxiliary Feedwater System Pump and Flowpath operable.

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No out-of-specification conditions were identified during the review except for conditions resulting from scheduled surveillance or mainten-ance activities for which the operators had taken the appropriate action >

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L In addition, surveillance testing of the Recirculation Spray System (RSS)

Pumps A and C per Operations Procedure SP 3606.1 and SP 3606.3 was ob-

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served. These two procedures had previously identified " blanks" for test

acceptance criteria during. initial NRC review of surveillance procedure The inspector verified that the

acceptance criteria were placed 'in the procedure prior to use and that the tests were conducted in accordance with the approved procedure It was noted that a substantial amount of revision had occurred to various operations procedures, including RSS pump surveillances. However, most of the revisions have been issued as " marked-up" copies of the original procedure and therefore, some procedures are difficult to follow. During discussions with the operators, they expressed confidence in their abil-ity to properly implement the procedures but felt that .it would be ad-  !

vantageous to re-issue clean, typed versions. The inspector had no fur- l ther questions on procedure adherenc .5 Fire Protection The licensee has had on a routine basis since November =1985, 22 (hourly .

or continuous) compensatory fire watches in various locations throughout i the plant. These have been established due to the inoperability of the I

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Halon system and/or the C0 2"Cardox" system and as compensatory measures for degraded fire barrier penetrations. During the inspection, the Halon system was made operable, thereby eliminating two continuous fire watche Twelve other continuous watches were established due to the inoperability of the CO2 systems. These systems are functional and have been tested; however, they are subject to inadvertent actuations which the licensee considers an unacceptable risk to personnel safety. Therefore, twelve CO 2 systems are intentionally locked out of service while improvement items are designed and incorporated into the system to improve personnel safet Items required for C02 system safe operation are tracked on a daily basis in the daily report. The licensee's representative estimates that the C02 systems should be fully operational within three month The remaining fire watchts are stationed in support of degraded fire-barrier penetrations or areas where fire barrier penetrations may be

, possibly degraded or not inspected and verified to meet requirement The inspector toured the areas where fire watches were stationed. All areas toured were clean with little or no fire hazards present. Minor discrepancies were brought to the attention of the licensee management.

. Fire watches were on station and alert. Watches were knowledgeable of their responsibilitie The program was adequately controlled by co-ordination between the licensee operation department and Stone and Webster (S&W) safety department with primary supervision by S&W general foreme The inspector noted minimal degradation of fire barriers and minimal work ongoing in the specified areas.

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The Designated Fire Watches for these specific areas (seven of which are TS related areas) are assigned on a permanent basis with no other re-sponsibilities or duties. The inspector noted that in areas where

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grinding and/or welding was in progress, a designated fire watch for each separate activity was present. The inspector concluded that the program is well controlled, that corrective actions to reduce the number of fire watches are being actively pursued by the licensee, and that good house-keeping practices in these areas are maintained. The licensee's attitude on personnel safety and its management of this program are considered a strengt .6 Summary Strengths

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There appears to be a good level of understanding in management and control room staff for control of activities related to Technical Specification __ _ _ _ . - .

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Licensed operators (SR0 and RO) in the control room have a good understanding of the Technical Specifications and the plant condi-tions. Shift turnover practices are very good with accurate Tech-nical Specification discussion.

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The Maintenance Department surveillance scheduling program has been i developed to automatically account for Technical Specification al-

! lowed surveillance intervals. This method provides good assurance that surveillance activities are completed in a timely manne Weaknesses a

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Department Test Control Lists have not been independently verified for accuracy. In addition, the PMS data base is not a " secure" system, which could allow for inadvertent deletion of data since

any number of personnel may access the data base from corporate l headquarter .0 Quality Assurance / Quality Control The scope of inspection effort in this area included an overview of Quality i

Assurance (QA) and Quality Control (QC) involvement in Unit 3 activities to assess the licensee's overall effectiveness. Until recently, QA/QC coverage of Unit 3 activities was organizational 1y and administratively separate from that of Unit 1 and 2. However, as the licensee neared completion of the Startup Testing phase, plans were made and action initiated to integrate the QA/QC functions with those of Units 1 and 2. Completion of this transition is tentatively scheduled for mid-June of this yea .1 Organization Quality Assurance representation is found both at the Millstone site.and at the corporate level, located in Berlin, Connecticut. However, both corporate and onsite QA groups are totally separate from each other, in that they fall organizatiunally under different Vice Presidents. Onsite

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QA activities fall under the control of the Northeast Nuclear Energy Company (NNECO), whereas corporate QA is part of the Northeast Utilities

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i Service Company (NUSCO). Both NNECO and NUSCO Vice Presidents report to the same Senior Vice President. It is at this level where disagree-ments between NUSCO QA (corporate) and the Millstone station are ulti-mately resolved if resolution is unattainable at the lower levels. Dis-agreements between NNEC0 QA (onsite) and the Millstone station are re-solved at the Station Superintendent level if resolution is unattainable at the lower levels. Resolution of differences is resolved at diffe' rent levels in accordance with applicable quality related procedures, which are different for the two organizations. NNECO QA activities are governed under Administrative Control Procedures (ACP) and NUSCO follows Nuclear Quality Assurance procedures. This was cause for some concern which will be discussed later in more detai ,

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5.2 NNEC0 QA NNEC0 QA is comprised of an audit group, a procurement /radwaste group, and a QC grou The QC group is subdivided into three sections with each section responsible for one of the three units at the Millstone statio A total of twenty-seven individuals are assigned to the NNEC0 QA grou During the Unit 3 startup testing phase, the QA audit group was respons-ible for performing primarily surveillances and assisting NUSCO QA during the performance of audits. NNEC0 QA is also responsible for procedure preparation and review, and training for Level I, II, and III certifica-tio Surveillance activities were initiated for Unit 3 during the preopera-tional/startup testing phase and were applied to all testing and quality-related work activities. Surveillances are designed to provide a quick observation of some designated activity without all of the formalities normally associated with audits. Conduct of a surveillance, identifica-tion of any problems, and the resultant notification to the responsible department heads and the Unit 3 Superintendent were expected to take no more than a couple of days. Resolution of any findings and resultant corrective action were also expected to have a quick turn around tim In other words, the performance of QA surveillance essentially was to serve as a management tool, such that upper management could quickly be apprised of and resolve quality related problems or potential problem A review of completed surveillances from November 1985 through January 1986 indicated that 197 surveillances were performed covering such acti-vities as:

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Housekeeping / cleanliness controls

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Maintenance activities

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S/G J-tube removal and reinstallation

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Material issues

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Training / certification The QA surveillance program appears to be working as intended and has received significant support from the Unit 3 Superintendent. Because of its usefulness as a management tool, the Unit 3 QA surveillance pro-gram is to remain intact and also be applied to Units 1 and The surveillance program would replace the monitor program currently in place at Units 1 and 2. It should be noted that the monitor program was originally intended to serve the same basic purpose as the surveillance program. The monitor program's failure as an effective management tool could be attributed to a number of reasons, some of which would include:

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Weak administrative control procedures

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Lack of support by department heads and unit superintendents

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Untin:ely issuance of reports and subsequent responses

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Minimal QA involvement following completion of the monitored acti-vit The inspector reviewed the draft revision of ACP-QA-9.07, " Quality As-surance Surveillance Program," and stressed to the licensee that the

program's success and usefulness is strongly dependent on specific guide-

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lines being provided in the governing procedure, particularly regarding i the time requirements and responsibilities for responding to findings.

] Identification of areas to be subjected to surveillances are currently

being evaluated, utilizing the following inputs:

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Trend analysis reports

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Department head solicitation 1 -

Known problem areas The QC group of NNEC0 QA reviews all "QC required" work orders, performs surveillances of maintenance, operations, and other plant activities, and conducts inspections of work activities in accordance with inspection plan criteria.

i All work order (WO) packages that cover work activities on Category I components and components that are part of the Equipment Environmental Qualification, Fire Protection, or Radwaste program are reviewed by QC prior to and following completion of work.- This review encompasses a verification of the WO; inspection plans, including appropriateness of ,

.e QC hold points; and correct procedures ard other required documentatio QC tracks, both manually and automatically, the status of W0s and any associated nonconformances. They also regularly attend morning and afternoon meetings to maintain an awareness of ongoing work activities

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and any changes thereof that may have occurre ,

i Discussions with the QA/QC group and reviews of various surveillances, W0s, NCRs, etc., indicates that coverage of quality-related activities is thorough and conducted in a professional manner. However, the general consensus is that the NNEC0 QA/QC group is not being utilized as a man- '

agement tool as intended. Communication channels are considered weak to the extent that, unless required by procedure, department management does not routinely interact with QA/QC when matters of mutual interest arise.

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5.3 NUSCO QA NUSCO QA is basically comprised of four groups; Design, Operations, Pro-curement, and Construction. Until February of 1986, all groups had worked out of the corporate office located in Berlin, Connecticut. In February, the Operations group was transferred to the Millstone statio The Operations QA (0QA) Supervisor stated that this move was predicated upon improving its visibility and credibility as an audit grou The 0QA group presently consists of fourteen individuals. They perform both a combination of audits and surveillances. The 0QA group ensures that quality-related activities are being accomplished in accordance with the required criteria for the Northeast Utilities Topical Repor The inspector discussed and reviewed with the 0QA Supervisor the proposed 1986-1987 audit schedule. Examples of areas scheduled to be reviewed include:

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Control room activities, i.e., turnover, tagging, surveillance testing

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Maintenance

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Training

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Corrective action The 0QA Supervisor stated that an equal amount of coverage and effort would be applied to all three units for each area to be audite Emphasis would be placed on those areas in which significant problems had been identified, either through trend analysis reports, requests, or recurring problem area NUSCO QA also audits the NNEC0 QA organization to determine its effec-tiveness in identifying problem areas. Although 0QA has concluded through its audits that NNEC0 QA is performing an adequate job, 0QA has also expressed concern that NNEC0 QA may not be effective once it is in-tegrated with Unit 1 and 2 activities. NUSCO QA believes management is not wholly supportive of the onsite QA effort which quite often contri-butes to NNECO QA's ineffectiveness as a management tco NUSCO QA has identified this as a problem as evidenced by previously completed audits, i.e., Corrective Action Followup Audit A60435. The inspector noted, during the review of this audit, that various departments did not respond )

to QA findings in a timely manner and that QA did not effectively fol- ;

lowup on findings that were identifie I

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5.4 Summary Strengths

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QA/QC groups are adequately staffed and consist of well-trained, conscientious individual The new site QC surveillance program is being effectively used as a managemen too The NUSCO Operational QA group has been transferred to the site where the group can be more effectiv Weaknesses

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Resolution of site QC findings are not routinely communicated back to the site QC, and therefore not always evaluated for effectivenes Communication between site QC and other departments is generally wea .0 Observations of Licensee Management The inspection team concluded that Unit 3 management was particularly strong as evidenced by the following discussio There was a general consensus among the Unit Superintendent and his department heads regarding philosophy of operation and identification and resolution of problems. Plant management was forthright in discussing existing problems and problems which may arise once testing is completed and full commercial operation is achieved. Corporate and Unit 3 goals were clearly defined and are effectively communicated to the various department Control and planning of routine activities is a particular strength. For i

example, an operational planning document is prepared daily and is distributed prior to the morning meeting. This document is a comprenensive description l of all ongoing activities'and plant status, and includes a list of current :.

t limiting conditions for operation (LCO). The morning meeting is particularly effective because the planning document is used as an outline, thereby elimin-ating the need for lengthy explanations by cognizant individuals. - However, ample opportunity is afforded to discuss particularly sensitive or complicated issues. The meetings are brief, to the point, and set the tone for the day's operational activitie Understanding of the impact of daily activities on safety is apparent. This is evidenced by the daily list of LCOs and frequently scheduled PORC meetings to discuss events that have the potential to impact operational safety. Fol-lowing the Unit 3 morning meeting, a site managers' meeting is held. This

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meeting provides an opportunity for senior site management to interact and familiarize themselves with Unit 1, 2, and 3 problems / events which have the potential to impact safet The site QC program is currently in transition. This was required in part due to Unit 3 achieving operational status. It is envisioned by site manage-ment that site QC surveillance will be used by the various unit superinten-dents as a management tool to improve plant performance. A revised site Ad-ministrative Control Procedure (ACP), which will define and implement this program, is being prepare The surveillance program in existence at Unit 3 is a hold over from the con-struction phase. Surveillance findings are delivered directly to the Unit Superintendent who then distributes them to the cognizant department head (s)

for resolution. Responses on corrective action are returned to the Unit Superintendent for evaluation. The Superintendent views the surveillance program as a tool to " nip problems in the bud" and minimize or eliminate sig-nificant deficiencies identified by major corporate audits. Historically, few significant programmatic deficiencies have been identified by major audits; however, when needed, corrective actions have been comprehensive and effec-tively implemented, lhere is no reason to doubt the continued effectiveness of this approach toward QA/QC. However, there is some concern on the part of the inspection team that site QC may not have been afforded sufficient opportunity to evaluate the sufficiency of corrective actions. It is important that the revised ACP on site surveillance provide adequate opportunity for evaluation of corrective actions. This is discussed in more detail in the QA/QC section of this repor Interviews with first line supervisors indicate that they are effective at communicating both up and down the lin Supervisors are aware of Unit 3 goals and are fully integrated into the daily operation of the plan Effec-tive maintenance and operational programs indicate the proper emphasis by first line supervisors on training, direction, and guidanc The Plant Operations Review Committee (PORC) is effective in dispositioning safety issues. However, the team observed that the amount of interaction among committee members was dependent on whether the' Unit Superintendent or the Acting Superintendent chaired the meeting. Although all meetings demon-strated adequate safety perspectives, the team concluded that increased emphasis should be placed on total committee involvement at all PORC meeting .1. Unit Meetings 6. Unit Status Meetings Daily unit status meetings are held prior to shift turnove These meetings are attended by the Departmental senior staff and assistants. The meetings are well organized, punctual, and succinct. The conduct is semi-formal, but professiona Topics discussed are: current plant conditions, activities

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accomplished during the previous shift, upcoming activities within each department, an overview of the most significant Unit problems, Technical Specifications and LC0's, and review i of a seven-day schedule of activities. Discussion regarding

, the above is kept to a minimum wi.th fut ther discussion held i after the meeting if required. These reetings are an efficient i and effective method for conveying a large amount of informa-I tion to many people and are considered a strength.

l 6.1. 2 Plant Operations Review Committee (PORC)

! PORC meetings are scheduled to be held at least once a week.

Often meetings are conducted more frequently in order to review 3 technical information which is not scheduled, or_ procedure l which require an immediate technical change. During the in-i spection, four PORC meetings were observed. .During each meet-

ing, the staffing, composition and fulfillment of responsibil-ities were noted to meet Technical. Specifications. However, the inspector observed that one aspect of the meetings could

- impact on continued committee effectiveness.

On April 15, 1986, the Unit Superintendent, as PORC Chairman, i convened the meeting (No. 3/86-121). Although topics were

presented by the PORC members, questions were raised primarily

by the chairman (Unit Superintendent). The chairman, who wa i

aggressive, alert, complete and thorough, asked probing ques-

! tions, and did not hesitate to disapprove general items, due 1

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to incompleteness or lack of sufficient information. However, the chairman, who certainly demonstrated excellent control of i the meeting, appeared to overshadow the PORC members who dis-

! played little interaction regarding the topics discusse !

l At the three subsequent meetings that week, the Acting Unit t

Superintendent convened the meetings as chairman. During these i meetings, the person presenting the topic directed the presen-1 tation and responses to the PORC as a group rather than to just j the chairman. Group discussions in'a casual, free, unrestrained 1 atmosphere conveyed much more information both technically and

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circumstantially. Most, .if not all members of the PORC, par-l ticipated in.the discussions. ~The discussions were probing and comprehensive in nature with a good attitude towards safety.

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The group discussions provided a synergistic result.

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, The NRC is concerned about the differences observed in the j above-discussed PORC meetings in that PORC members are not ef -

! fectively " advising" the Unit Superintendent, when chairman,

! on matters related to safety as required by TS's. As a result, j the synergistic effect that group discussion provides may be

lost, resulting in a final decision based on minimal inpu +

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The licensee should consider utilizing committee chairman al-ternates more often, while maintaining oversight by the Unit Superintendent, to enhance synergism uniformly among all PORC meeting .2 Nuclear Safety Engineering Group The licensee evaluates operating experience information for applicability and incorporation to improve Unit 3 safety through fulfillment of TS 6.2.3, " Independent Safety Engineering Group" (ISEG). The Nuclear Safety Engineering Group (NSEG) is tasked with conducting the activities re-quired by TS 6.2.3 and does so through NE0 procedures 2.06 and 2.1 Both procedural activities overlap to effectively use information from Connecticut Yankee, Millstone Units 1 and 2, and industry information programs. Significant operating experience information, for which cor-rective action is not already in progress, is forwarded to the Vice President of Nuclear Operations, who initiates corrective actio The inspector discussed TS 6.2.3 responsibilities with NSEG personnel and reviewed several Significant Operating Experience Reports (SOERs),

annual and quarterly reports sent by the OAG to the Vice President of Nuclear Operations, and the resulting ccrrective actions. These reports

) provided significant information with meaningful and effective corrective actio Based on the discussions with NSEG personnel and review of the above-noted reports, the inspector determined that the requirements of TS 6. were being me No violations were identifie .0 Persons Contacted J. Crockett, Unit 3 Superintendent J. Kelley, Station Services Superintendent K. Burton, Operations Supervisor C. Clement, Maintenance Supervisor T. Cleary, PIR Plant Coordinator G. Closius, Quality Control Supervisor M. Hess, Plant Engineer J. Jensen, Quality Assurance Specialist C. Libby, Supervisor, Operations QA J. Marean, NUSCO Mechanical Engineer D. Moore, Assistant Operations Supervisor M. Pearson, Assistant Operations Supervisor T. Rogers, PMMS Planner, I&C

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R. Rothgeb, Technical Assistant - Maintenance Supervisor R. Sharp, PMMS Planner, Maintenance (SWEC)

S. Sudigala, Assistant Engineering Supervisor

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8.0 Management Meeting On April 18, 1986, an exit meeting was held with senior plant management to discuss the scope and findings of this inspection. During this inspection, the NRC inspectors received no comments from the licensee that any of their inspection items or issues contained. proprietary information. No written material was provided to the licensee during this inspection.