IR 05000423/1987099

Forwards SALP Final Rept 50-423/87-99 for Mar 1987 - May 1988

ML20205Q590
Person / Time
Site:	Millstone
Issue date:	11/02/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8811090292
Download: ML20205Q590 (2)

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NOV 0 21988 Docket N Northeast Nuclear Energy Campany ATTN: Mr. E.1. Mroczka 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 50-423/87-99 and Your Reply Letter Dated July 16, 1988 This forwards the Millstone 3 SALP Final Report for the period from March 1,1987 through May 31, 1988 (Enclosure 1). The SALP Board Report was forwarded to you by our July 25, 1988 letter (Enclosure 2). On September 1, 1988, we discussed the SALP with you and your staff (see Enclosure 3 for attendees). Your September 30, 1988 SALP comment letter is appended as Enclosure 4.

, In your comment letter, you requested a March 1989 Management Meeting to discuss your actions in the surveillance area. We feel that such a meeting and the pro-posed timing are appropriate and look forward to discussing this topic with yo Your comment letter not .1at the training staff contains contractors as well as company employee Than. Su for that clarification. Because no change in the the SALP perspective or racings was involved in this case, no change was made to the SALP Board Report. We will, of course, consider all of your comments during the next SAL Thank you for your comments and, in particular, for the discussions of your plans for improving performanc

Sincerely,

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ORIGINA1. SIGNED BY William T. Russell Regional Administrator Encl o sure s .- Systematic Assessment of Licensee Performance Final Report 50-423/87-99 NRC Region I Letter, W. T. Russell to E. J. Mroczka, dated July 25, 1988 SALP Management Meeting Attendees Northeast Nuclear Energy Company Letter, E. J. Mroczka to NRC Document Control Desk, dated September 30, 1988 0FFICIAL RECORD COPY DL50-423/87-99 FINAL - 0001. /21/88 h G811090292 SG1102 PDR ADOCK 05000423 .J.-

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Northeast Nuclear Energy Company 2 g

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W. D. Romberg, Vice President; % lear Operations 0. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Ge:: 2 ration Facilities Licensing S. E. Scace, Station Superintendent Chairman Zech Commissioner. Rogers Commissionar Curtiss Commissioner Carr ' '

Commissioner Roberts K. Abraham, PAO, RI (19 copins)

Vandana Mathur, McC w -Hill Publications (2 copies)

' Art McJuire, Conscruction Industry Litigation Reporter (2 copies) *

Public Document Room (POR)

local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector State of Connecticut bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, ORMA (w/o enc 1)

J. Taylor, DERO V. Russell, RI S. Ebneter, DRSS T. Martin, DRS W. Kane, ORP SALP Marigement Meeting Attendees R. Brady, ORP J. Lieberman, 01

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W. Oliveira, DRS 0. Holody, ES G. Kelly, ORP E. Conner, ORP ORP Section Chief S. Barber, RI, Millstone 3 W. Raymond, SRI, Millstone 1&2 D. Jaffe, LPM, NRR l

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ENCLOSURE 1

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

FINAL REPORT SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER S0-423/87-99 MILLSTONE NUCLEAR STATION, UNIT 3 ASSESSMENT PERIOD: March 1, 1987 to May 31, 1988 BOARD MEETING DATE: July 12, 1988

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-SUMMARY OF RESULTS II Overall Summary During the previous SALP, the. licensee staff was assessed as strong, with visibly involved managers. Strengths were observed in problem identification and response, and in locating root causes. There was diligent attention to performance at all levels. ' Performance imp oved as the period progresse Licensee performance continued to improve during the current SALP period. Strong

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operations programs, procedures, and management controls were evident. Command and control was very good. Activities were carefully planned and conducted, with outages being a noteworthy example. Managers were actively involved in decision making and activity direction at appropriate levels. Operating supervisors and plant personnel were knowledgeable and alert. Strong corrective action was evident when errors or malfunctions occurre The organization was staffed with capable and knowledgeable managers and supervi-sors. Workers attended to detail and demonstrated a safety conscious attitud Procedures and programs were effectively implemented and focussJ on safe operation Morale and attitudes were good. High standards were set and followed. Consis-tently high performance was strived for and achieved. A high regard for plant and personnel safety was strongly eviden The previous SALP noted a need to decrease scrams (reactor trips) due to steam generator (SG) level transients. Replacement of the SG level measurement conden-scte pots with nigh pressure pipe taes improved steam generator level stabilit That enhancement and improved operator handling of feedwater transients reduced the number of scrams: there were 11 scrams during this 15-month SALP period (0.7/

month) and 16 scrams during the previous 18-month SALP period (0.9/ month). Of the 11 scrams this period, two were due to inadequate control of feedwater, a signifi-cant improvement over the 10 such scrams during the last SALP period. While the scram reduction efforts have resulted in improvements, there needs to be continued emphasis on this program in the next SALP perio The last SAlp noted an improving, but still high, number of illuminated control room annunciators during operatio Licensee reassessment resulted in delaying their commitment to achieve a "black board" from the end of the first refueling outage to the end of the third refueling outage. That is generally appropriate, but some radiation alarm annunciators deserve increased attention. Currently, these alarms tend to desensitize operators to additional alarms on the same windo Overall, this SALP reflects careful and safe performance during the first full operating cycle. There is, however, an ongoing licensee need to reduce avoidable

. . scrams and unnecessary illuminated control room annunciators. The licensee also needs to prioritize changes to operating and surveillance procedures and assure that sufficien'. staffing is provided to accomplish those changes effectivel _

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II Background III.B' . Licensee Activities The licensee completed the first operating cycle and began the second during this SALP period. Millstone 3 operated at 70.3% capacity from the beginning of commer-cial operation on Apri l 23, 1986 until the SALP period ended on May 31, 198 There were two unplanned, more than 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> outages and two planned outages (one for surveillance, one for refueling) during the period. The 5-day and 14Jday un-planned outages (June 5,1937 and April 13,1988) followed scrams and were extended for maintenance. A planned outage in March 1987 was for snubber testing. The refueling outage began on October 30, 1987 and was scheduled to last 59 days. An additional 45 days was taken to repair loose reactor coolant pump (RCP) locking cups after seven were found on the lower core plate. There were about 2700 actt-vities scheduled during the outage including refueling, resistance temperature de-tector (RTD) bypass manifold elimination, snubber reduction, steam generator sludge lancing, containment' local leak rate testing, motor-operated valve testing, and safety system train-related maintenanc .

III. Inspection Activities Four NRC resident inspectors were assigned to the site during the SALP period.

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The senior resident inspector divided his time among all three units; a resident

" inspector was assigned to Unit 3. Both of these individuals were first assigned to the site during the SALP period. The NRC inspections represent 2425 inspection hours (1940 hours0.0225 days <br />0.539 hours <br />0.00321 weeks <br />7.3817e-4 months <br /> per year), distributed as shown in Table II Facility Performance Analysis Summary Last Period This period Recent Trend (9/1/85 - (3/1/87 - (Past 3 2/28/87) 5/31/88) ~~~~ Months)

Functional Area (11 Areas) Plant Operations 2 2 -- Radiological Controls 2 1 -- Maintenance 1 1 -- Surveillance 2 2 -- Emergency Preparedness 1 1 -- Security and Safeguards 1 2 Improving Outage Management 1 1 -- Engineering Support 2 2 -- Licensing Activities 1 1 -- _ ,,

Training Effectiveness _2 1 -- Assurance of Quality 1 1 --

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IV. PERFORMANCE ANALYSIS I Plant Operations (1021 Hours. 42%j IV. Analysis

.The plant received its low power and full power license during the previous as-sessment period. It was rated in Plant Operations as Category 2, improving. Con-cerns included scram frequency, Power Operated Relief Valve (PORV) reliability and unnecessary illuminated annunciator reduction. Scram frequency is still high but has been reduced somewhat: 11 scrams (8.8/ year) this assessment period versus 16 scrams last period (10.7/ year). Three scrams in 1987 resulted from inadequate

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control of steam generator (SG) water level during startup or at power. In 1988, one scram has been attributed to inadequate SG 1evel control. This reduction was in part due to operator experience in handling feedwater transients tad in part due to replacement of the SG 1evel measurement condensing pots with high pressure pipe tees to eliminate steam generator level oscillations previously experienced between 55% and 65% power. Although the scram frequency is being reduced, con-tinued manag aent emphasis is needed to ensure future reductions are realized.

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PORV reliability showed marked improvement due to licensee programs that effec-tively dealt with seat leakage problems. The solution to this difficult problem involved installing flexible valve discs in the PORV Reduction of illuminated annunciators has continued, but delays in the annunciator reduction program have been caused by the need for significant desigr. changes.

! The original commitment to establish a "black board" by the end of the first re-fueling outage was revised to achieving a "black board" by the end of the third refueling outage. This change is generally acceptable. However, problem annun-4 ciators deserve increased licensee attention. For example, spiking on radiation

, monitors causes alarms to be received, acknowledged, and reset from about 10 to 50 times per hour, hazarding operator desensitization to that particular annunci-

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ato In one instance this led to a high radiation condition not being discovered by the licensee. Continued management attention is needed to ensure sufficient priority to and timely resolution of this problem.

d Overall, operating shift functioning was smooth and professional. Activities wero i

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conducted carefully and with sufficient formality. The operators themselves re-

mained strong proponents of control room formality. Operator attitudes were posi-tive and a concern for safety was evident. Attentive behavior was routinely ob-served in operator performance during day and backshift inspections. Distractions such as extraneous reading material were not permitted or observed in the control room. Shift turnovers were observed to be consistently thorough and effectiv Briefirgs for tests and infrequent evolutions were detailed, and involved free exchanges of guestions and answers. Written procedures were routinely followe Shif t logs and records were discrepancy-free during frequent review.

There were 11 scrams during the assessment perio Four were due to equipment failure and three were due to personnel error. (See Table 4A for a listing of causes.) Two of the equipment-related scrams were due to faulty Skinner solenoid

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valves. Due to high temperatures and currents, these valves have been open cir-cutting and causing their respective feedwater isolation (FWI) valves to clos These valver, were replaced in kind prior during the first refueling outage; low wattage valves for replacing these valves are due to arrive on site November 198 The majority of personnel error-related trips were due to feedwater control prob-lems. Differences between plant and simulator response exacerbated these problems but increased operator experience has reduced the frequency of such trips. Overall, i the scram frequency and its reduction indicate satisfactory performanc l Operator response to scrams was excellent. Performance following the September 23, 1987 scram was an example. Operators performed immediate actions from memory without error and checked emergency operating procedures to verify their action They constantly referenced the procedures while performing follow-up action j Operator technical knowledge was good, based on their consistently exhibiting de- )

, tai!ed and thorough knowledge of the equipment, its status, and associated re-t quirements. New operating license candidate knowledge was satisfactory. During

the NRC license examinations given this SALP perbd, 8 of 13 candidates passe with no significant weaknesses noted. (Further details are provided in Section 1 IV.J, Training Effectiveness.) '

Licensee management support of training and operator proficiency has been eviden The licensee conducted training on a modern plant-specific simulator with a dedi-cated training staff of about 20 individual Several experienced operators have '

been promoted into the training staff. There was a six-shift rotation during power

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operation, with full-time training for one shift being a regular part of that i rotation. Station management involvement in training was evident in their knowl- (

edgeable discussions with NRC personnel and in their obvious interaction with the i

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training staff and attendance at simulator training. Most department heads main-tained senior reactor operator (SRO) licenses and attended requalification trainin Their dedication to training and to the understanding of system operations and  !

interrelationships was especially evident in Flant Operation Review Committee f

(PORC) meeting

i l PORC performance was very good. Meeting inputs were well prepared and showed a i clear understanding of issues. The approach to problem resolution was technically I sound, very thorough, and routinely conservative. Root causes of problems were  !

j actively pursued. During meetings and in NRC discussions with higher level man-  !

l agers, there was a licensee willingness to deal with difficult issues and an at- l mosphere of healthy self-:riticis (Further details are provided in Section IV.K, *

Assurance of Quality.)  ;

I Management attention to operations was evident in plant superintendent control room

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tours ar.d detailed weekly plant material walkdowns by Health Physics and Operations 1 supervisory personnel, i A significant operating event occurred on January 19, 1988 when a low temperature overpressure (LTOP) transient was caused by pulling a fuse in a Solid State Pro- i tection System (SSPS) cabinet. That resulted in closure of a residual heat removal i

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(RHR) suction valve, isolating the on-line relief valve. Unavailability of re- l

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L quired LTOP cold overpressure protection systems (COPS) made the pressure transient possible. Prompt operator action with the plant in a water solid condition held the resulting pressure transient to less than 600 psi. Licensee post-event analysis showed that plant pressure could have exceeded 2500 psia before damage would have '

occurred. If pressure had risen near that level, the power-operated relief valves (PORVs) were operable at their high pressure setpoint to mitigate the transien !

Control of operations-related activities that led to this event was deficient in that the procedure for ensuring operability of the COPS did not adequately address operability of supporting equipment. Further, there was no positive indication in the control room when the COPS was armed. In addition, the I&C technician who pulled the fuse that resulted in the RHR relief valve isolation was not adequately trained in the associated complex circuitry interrelationships. Also, the activity was performed without a procedure and without adequate formal review. This event resulted in escalated enforcement action. (Further details on procedural aspects are contained in Section IV.D. Surveillance.)

Three other instances of deficient operational controls were identified. The first ,

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involved entering Mode 3 (hot shutdown) during heatup with one of two required charging pumps inoperable. The second involved entering Mode 3 with an auxiliary feed pump and a supplementary leak control and recovery system fan inoperabl Procedures were then changed to require a test run of safety-related pumps prior to entry into Mode 3 and to require danger-tagging safety-related pumps not spect-fically lined up for service. These procedure enhancements, along with improved attention to detail, have enhanced licensee performance as evidenced by an absence of problems during the most recent startup. The third situation involved the im- l proper securing of a locking device on an AFW suction valve. A prompt reverifica-tion of other safety-related system valve lineups was conducted, with no other in-adequacies identifie In these three matters, licensee response and corrective actions were prompt, appropriate and effectiv Personnel routinely followed procedures and operators and workers routinely recom-mended procedure improvements. Some changes were substantiative but most were minor. Procedure changes were implemented at a rate of 80-100 per month, reflect-ing a diligent effort to eliminate inadequacie The licensee's expectation that the procedure change workload would be reduced was not, however, realized. PORC meetings occurred almost every other day to cope with the numerous change Operations ad:ninistrative personnel were continually burdened with procedure change Staffing to cope with procedure changes was adequate but, because of the work load, L the individuals involved were not available to work on surveillance-related ad- t ministrative problems. (Further discussion of such proble:ns is contained in Sec- -

tion IV.0, Surveillance, and Section IV.K, Assurance of Quality.) During this SALP r period, the need to aggressively upgrade procedures continued, and a greater re-source commitment to this function may be neede Housekeeping was evaluated as satisfactory in the last SAL Significant improve-ments have since been seen. Epoxy painting of the Engineered Safety Features (ESF)

building cubicles was recently completed and reduced the amount of decontamination necessary in these area Plant spaces were very clean and workers routinely cleaned their areas when finished with assigned tasks. One housekeeping concern that was identified and corrected was the securing of non-safety related conduit

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l l covers which were removed in the upper levels of the ESF building. These had been

! lef t open for post-work inspection and remained open af ter the inspection was com-l 1ete. Otherwise, housekeeping was very good.

I Licasee Event Reports were routinely reviewed and generally found to be complete,

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accuote, timely and to contain adequate corrective action (Further details are proviv i in Section IV.J Training Effectiveness.)

l Licensee command and control of operations were strong oveiall. Managers were aware of operating status and details, and actively asserted themselves at the appropriate organizational leve Shift management was knowledgeable and exerted positive control over activities affecting operatio Three notable exceptions were a heatup with one of two charging pumps inoperable, the LTOP transient, and i

a failure to station an additional operator during startup to manually control SG water level (this resulted in a scram). Subsequent procedure enhancements were positiv Licensee review found a lack of potential for other similar event ,

Overall, licensee management was strong. Corporate and unit goals'and policies were detailed and yell communicated, and administrative controls were effectively implemented. There was a streng safety-first orientation at all levels in the licensee's organization. Licensed operators were professional, knowledgeable, thorough, and confident, and their performance improved over time. Housekeeping was very good. Previous SALP concerns were effectively addressed with the excep-tion of the masking of radiation alarms by existing backlit annunciator In summary, operating performance was satisfactory. To achieve a higher perform-ance rating, the licensee needs to reduce scrams and events such as the LTOP transient and the mode changes without required equipment operable, to ft,rther im-prove procedures, and to aggressively continue to reduce unnecessary annunication IV. Conclusion Category IV. Board Recommendations Licensee:

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Accelerate correction of radiation monitor spiking proble Identify and correct procedure problems based on safety significance. Evalu-ate operations support staffing levels established to cope with frequent pro-cedure changes and with surveillance-related administrative problem NRC:

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I Radiological Controls (334 Hours,14%)

IV. Analysis The Radiological Controls Program during the previous SALP period was rated as Category 2 improving. Minor program weaknesses identified during the previous i assessment period related to lack of attention to detail in the implementation of i radiological control audits, chemistry / radiological effluents, and transportation .

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programs. All program weaknesses identified during the previous assessment period wete effectively addressed.and corrected during this assessment perio <

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IV.B.1.1. Radiation Protection An effective, well-defined, and adequately staffed organizational structure was ,

in place to control Unit 3 Radiological work activities. Levels of supervisory and technical personnel were adequate to support radiological activities. Staffing and' oversight of significant radiological operations, such as containment entries at power to perform repairs, were good. Radiological Protection (RP) management staf f exhibited a strong "in-the-field" presence and were actively involved in the

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i radiation protection program on a continuing basis. RP and Operations continue to regularly perform joint tours of the radiologically controlled areas to identify sources of exposure, contamination and potential radiological concerns. As a re-sult, the licensee successfully minimized the spread of contaminatio .The number and quality of radiological operations audits of routinely performed by the Quality Services Department with assistance from the Corporate Radiological Assessment Branch (RAB) was assessed as good. a. past criticism of the audit pro-gram conducted by the RAB was that it tended to review station RP activities in total without providing an in-depth review of individual unit activitie This weakness was corrected by pisnning and performino separate audits of each unit under the direction of the Quality Services Department. Overall, during this as-sessmert period, corporate management involvement in on-site activities was fre-quent and of high quality, with timely corrective action on audit finding Clear radiation protection procedures and policies were in place and effectively implemented. Radiation protection records are complete, well maintained and available for review. Procedure adherence was a strengt Radiation protection personnel were trained and qualified in accordance with a well defined program, which was implemented with dedicated resources and applied to all staff. The licensee's integration of good training, qualification, and program oversight contributed to safe conduct of radiological operation The program for surveying, posting, and controlling radiological areas continued to be well implemented. An extensive and thorough radiation survey program to evaluate shielding effectiveness was performed by the licensee during Unit 3 startup. The results were used by the licensee to control radiological work acti-vities and make adjustments to the radiation work permit syste _ _ _ - _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - -

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The ALARA program was effective with good management support, and represented an ,

additional program strength. ALARA reviews for planned work, completed work, at:d continuous exposure evaluation of work in progress were good. A notable positive example of the licensee's ALARA program involved the Reactor Coolant Pump (RC Locking Cup Repair that extended the refueling outage for 6 weeks. The'use of e spare RCP to plan work was viewed as a very useful mock-up that allowed workers to complete repairs while receiving 50% less than the projected exposur The licensee's ALARA person-rem exposure goal for 1987 (first refueling outage) l was 444 person-rem. Although the goal compares favorably with the industry average  !

for pressurized water reactors for 1987, it was not a particularly aggressive goal when considering that the plant recently completed their first operating cycl ;

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Actual exposure accumulated during 1987 was 357 person-rem which was good when considering that the goal was not increased when repair work to the RCP locking cups became necessar Overall, occupational radiological safety was a notable licensee strength. This is attributed to a sound program, a capable staff, and supervisory excellence.

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IV.B.1.2. Chemistry / Radiological Effluents Gaseous and liquid radioactive effluent control programs were inspected midway l

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through the SALP period. The chemistry group was responsible for program imple-mentation. Clear corporate support for effective program implementation was evi-dent. Management controls were evident in the procedures for controlling dis-

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charges and for scheduling surveillances. Radioactive effluent control instru-mentation was maintained and calibrated in accordance with requirements. All ef-i fluent release records were complete and well maintained. The licensee was re- ,

sponsive to NRC initiatives in this area. Corporate audits of the program were  :

comprehensive and technically sound. The licensee was responsive to a weakness '

in the radiological measurements QA/QC program area identified by the NRC during ,

the previous SALP perio i

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Chemical measurement capability was evaluated against technical specification and other regulatory requirements. The licensee was adequately staffed and had state- l of-the-art equipment for nonradiological chemistry. They were responsive to NRC

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suggestions for program improvements. Licensee performance on NRC-supplied chemis-J try standards was good, with 28 of 30 (93%) in agreemen !

! A review was made of the secondary water chemistry control program implemented I"

during the February-December 1987 period. Sodium, chlorides, sulfates and silica i were generally below the values that could be determined by the on line "state-of-the-art" equipment used for analysi i r i Based on these data, the licensee was responsive to NRC and industry initiatives

] and maintained secondary water chemistry within EPRI (Electric Power and Research

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Institute) recommended guidelines. In the case of chlorides and sulfates, it l

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! appears that the quantities measured were approaching the lower limit of the  !

equipment the licensee has available to perform the analysis.

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IV.B.1.3. Transportation The solid radwaste/ transportation program was site administered for all three units

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at the Millstone site. During the prn ious Unit 3.SALP, this area was not evalu-ated because of low radwaste activity as a result of initial startup. Two trans-portation inspections were conducted during the assessment period. Following pre-vious incidents which resulted ir. several violations and weaknesses in the last assessment period, the licensee restructured the organization responsible for packaging and shipping radioactive materials'. The responsibilities and authorities of the Radioactive Material Handling Department (RMH) were defined adequatel Documentation of shipments has been improved and all paperwork for a given shipment was kept as required during the SALP period. Job-related procedures and QA audit procedures have been revised and improved. The frequency, qut,11ty and scope of QA audit activities has also improved. The Radwaste Review Committee has been reactivate Following violations pertaining to radwaste transportation training during the last-assessment period, licensee modules were completely rewritten. All staff received required training. The training and qualification contributed a positive direction to the effectiveness of RMH group activities. Close management attention to plan-ning and impicmenting the program was noted, with strong peer review of the tech-nical aspects of preparation, packaging and shipping activitie IV.B.1.4. Summary An effective, well-organized and adequately staffed radiation protection organi;;a-tion was in place at Unit 3 to control radiological work activitie Corporate management involvement with on-site activities was frequent and provided on ef-fective level of oversight and suppor The program for surveying, posting, and controlling radiological areas continued to be well implemente The ALARA program was effective, with good managernent support. Overall, in plant health physics was a notable licensee strength due to a sound program, a capable staff, and supervisory excellenc SALP performance in solid radwaste/ transportation during the current SALP period was substantially improved over the previous assessment perio IV. Conclusion Category IV. Board Recommendations Non ,

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3 a I Maintenance (317 Hours, 13%)

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IV. Analysis The. previous SALP rated maintenance as Category 1. During that SALP period, the maintenance program was found to be properly established, implemented ano staffe Plant equipment was highly reliable, with only one scram attributed to maintenanc A long standing l uensee-identified problem identified in the last SALP, power-operated relief valve (PORV) seat leakage, has been resolved. In March of 1987, the valves were disassembled, inspected and repaired. From plant startup on April 4,1987 to May of 1988, the valves remained leak tight and their associated block

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. valves did not have to be closed. Technical competence was evident in the'imple-

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mentation of bench testing of the PORVs and PORV solenoids. Further, the original requirement for the PORVs to be f.langed so that repairs and testing could be more readily done indicated good decision making and good technical planning. The fluitallic discs now used have been essentially leak-fre PORV operability and reliability has been consistently hig Improper feedwater isolation (FWI) valve packing adjustments caused a failure to isolate and an overfeeding during the last assessment period. Effective implemen-tation of a partial stroke testing program has subsequently prevented recurrence of this type of event.

In the last4SALP, three. instances were noted where fire, cantrol building, or Sup-plemental Leak Collection and Release System (SLCRS) barriers were breached by fluid hoses or scaffolding. There were also three occurrences during the current period where a fire barrier was breached or left open without a fire watch being established. LERs also identified the failure to establish required fire watches (see LER causal analysis). These events might have been avoided if the barriers were better labeled and identified. The licensee has since included a listing of 4 all SLCRS barriers and fire doors in the governing work procedure, facilitating prior identification of these boundaries in Automated Work Orders (AW0s). In ad-

dition, the licensee committed to label all doors by December 1988. These actions l were positive cnd reflected management attention to problems.

! NRC Generic Letter 83-28 discussed actions to be taken regarding reactor trip cir-

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cuit breaker reliabilit Review of the two lie.ensee procedures for reactor trip

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breaker maintenance showed that the licensee followed the recommendations of the Westinr3h ouse Maintenance Progra Further, it was noted that Itcensee procedures were updated to reflect a problem with bracket cracking on 05-416 breakers (the a type in use at MP3) and that bracket inspection was performed as part of the main-tenance program. The 05-416 reliability / operability issues have been resolve This indicated good management and engineering personnel responsiveness to NRC and vendor guidance, and appropriate addressal of applicable industry problem Other maintenance activities examined during the assessment period included repairs to leaking Main Steam Isolation Valves (MSIVs), trouble-shooting of an emergency

. diesel generator (EOG), work on normal and reserve station transformers, and re-pairs to steam generator (SG) "handholes". The maintenance manager and maintenance

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engineers were actively involved in the oversight and supervision of these main-tenance activities. Also, I&C personnel were knowledgeable in their area of ex-pertise and were well informed of site requirement Administrative control of maintenance was cited in the last SALP as a problem are Lack of licensee control was observed in the commencement of work without approved AW0 Performance in this specific area improved during the current period. Work was consistently approved prior to performance and was signed off on completio Maintenance and modification activities during normal plant operations were con-trolled and performed within the bounds of Technical Specification Limiting Condi-tions for Operation. This was evident in the routine daily performance of 6-8 preventive maintenance activities. Maintenance activities were well thought out and planned. Workers generally performed repair and testing activities without error. During this SALP, control of maintenance and testing was generally very effectiv Review found the maintenance department fully staffed with well-trained, competent and dedicated mechanics, electricians and machinists of diverse background Maintenance assistance available from the other three Northeast Utilities plants was frequently utilized. Observations and discussions found maintenance supervi-sors and managers krowledgeable, and active in oversight of activitie Effective planning minimized outage and operational scheduling impacts. Coordina-tion with other departments was excellent. Communication and cooperation between all departments, both at workar and management levels, was a key to timely and effective troubleshooting and corrective maintenance on numerous occasions. Not-able positive examples of coordination and cooperation involved the Reactor Coolant Pump (RCP) Locking Cup Repair that extended the refueling outage for 6 weeks and the repair of defective primary sample valves during an unplanned shutcown. Lic-ensee scheduling of activities during the RCP repair shortened the original down-time from an estimated 10 to 12 weeks to 6 weeks. The use of a spare RCP facili-tated timely completion of the repair wor '

Although the scheduling and coordinatien of previously unplanned work was a notable d

strength, the completion of routine activities was untimely in a few instance One example was the repair of intake structure components. This was viewed as a direct contributor to the April 13, 1988 scram. The relatively large number of intake structure componants out-of-service made the plant vulnerable to adverse weather conditions. Excessive seaweed impingement on the traveling water screens would normally hcve oeen cleaned off by the screenwash system. However, reduced system capabilities did not permit proper screen cleaning. Subsequently, increased licensee attention to such vulnerabilities was observed by the NRC. Continued licensee sensitivity to areas vulnerable during adverse circumstances is warrante The computerized Preventive Maintenance Management System (PMMS) continued to show benefits throughout the first operating cycl PMMS was used in planning, control-ling and documenting work. Its machinery history function was routinely usea to trend equipment performance for e'.tablishing corrective actions. The system was an excellent tool for managing mairitenanc ,

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5 In summary, the licensee had an effective and well-managed maintenance progra ;

Maintenance personnel were well trained, proficient in performing repairs, and '

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familiar with procedural and regulatory requirements. Maintenance managers and maintenance engineers were actively involved in the oversight and supervision of ,

maintenance. Completed work packages were well maintained. Controls were in place F to ensure that post-maintenance testing was accomplished, where t.pplicable, prior ,

to declaring systems or components operable. In only one instance did a mainten- '

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ance inadequacy lead to a reactor scram. Overall, Maintenance was a licensee strengt '

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l IV. Conclusion

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Category IV. Board Recommendations None, i

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15 >

I Surveillance (136 Hours, 6%)

IV.D.1.

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Analysis Surveillance was rated Category 2 during the previous SALP. Performance and understanding of surveillances was a strength. but weaknesses in procedures led ,

to incorrect safety system setpoints and five unnecessary system challenges. One i of these was the isolation of service water to a safety injection ' pump heat ex-

" [

change +

. During the current period, surveillance procedures were found to be a detailed and .

solid base for a successful' program. Changes were requested and drafted by persons !

working with surveillance tests, and were processed in accordance with the Techni- '

cal Specifications. These actions reflected licensee determination to eliminate procedure inadequacie , 8

The surveillance program was managed conscientiousl Surveillance procedures were generally performed properly, with well-documented test results that met technical specification (TS) requirements. Surveillance procedures contained easy to follow instructions and included features for ensuring that out-of-tolerance conditions ,

,

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were reviewed and acknowledged by supervision. There were provisions t'or ensuring that results were trended and that recommendations were sent to . management for

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action when required. Personnel were well-trained and sufficient in numbe < Technicians and operators conducting surveillances generally showed a very good.

understanding of both system and procedure requirements. The computerized Plant Maintenance Mana'gement System (PMMS) tracked TS requirements. Surveillances were generally performed when required. As the instances discussed below demonstrate, however, an administrative control problem was eviden '

a

!' There were 19 surveillance-related Licensee Event Reports (LERs) during the perio Typical examples were a missed diesel generator fuel oil particulate sample and

, a late fire protection system surveillance. All 19 of these LERs were for licensee- i

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identified conditions, and the next surveillance showed acceptable conditions in i

! each cas Eleven of the 19 LERs documented seven missed, two late and two incom- i plete surveillances; 9 of the 19 attributed the root causa to personnel error.

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Although these 19 lapses represent a very small fraction of the surveillances (19 .

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", of thousands) and no out-of-tolerance conditions were missed as a result, increased licensee attention to program implementation is needed. This is a continuing '

1 problem.

l During a shutdown (July / August 1986) before the SALP period, required visual in-

spection of snubbers mandated a second inspection of certain mechanical snubbers. For that inspection, performed in March of 1987, the licensee showed sa Sty con-

] servatism by inspecting all snubbers, not just the two types required. JRC reviev

of the licensee's evaluation, which included test data and snubber disassembly and repair records, found the testing and evaluations sound and conservativ The licensee's eddy current testing (ECT) program was effective. During Inservice Inspection (ISI) of the Unit 3 steam generators (SGs), the now standard method of controlling ECT from a remote location effectively reduced radiation exposure Data analysis by two individuals who analyzed the same data increased the assurance

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~

that no defects were missed. For differences in analysts' conclusions, a certified Level III contractor examiner was used to make the determination. The SG ISI re-suits were excellent. The steam generators for Unit 3 are in the best inspection category allowed by Technical Specificatter.s since less than S% of the total tubes were degraded and no tubes were defective. The licensee attributed these excellent results to constant attention to steam generator chemistry contro Eddy current testing was used by the licensee to detect incore thimble tube thin-ning. Fourteen tubes had greater than 20% through-wall wear, and seven had 30%

to 50% through-wall wear. The worst case tube was capped and the other tubes were withdrawn slightly to take the worn area out of the high vibration region just above the core plate. Effective use of ECT allowed early detection of this proble Further evaluation of this problem is to be conducted after ECT during the second refueling outag The use of In-Service-Tests (ISTs) to analyze equipment performance was a note-worthy strength. ISTs were well analyzed and professionally conducted, as was evident by the IST done to identify the cause of a control bank not moving as re-quired during routine surveillance. This IST led to the replacement of a bad in-strument card, correcting the problem with minimal impact on operatio Contractors were used by the Instrument and Controls (I&C) department to perform some surveillance work and were trained to the same level as licensee technician Contractor technician work was good with one notable exception. A contractor I&C technician pulled a fuse in a solid-state protection system (SSPS) cabinet in which he was not trained. (This is further discussed in Area IV.J, Training Effective-ness.) The resulting loss of low temperature overpressure protection (LTOP) sys-tems and the overpressure transient, though mitigated by operator action, demon-strated a need for more stringent control of surveillances and work activitie In this case, the surveillance procedure also was inadequate because it did not specify the proper steps for disabling the low temperature interlock (P-12) to the steam dump system. After this trarsient, the licensee committed to restrict main-tenance and surveillance of complex systems such as the SSPS to specifically qualified technician The licensee also emphasized the need for better oversight and a more formal review of work activities by qualified peers and first line supervisor Corrective actions were positive and focused on providing better control of surveillances and work activitie In summary, the surveillance program is sound overall, but administrative problems have continued to detract from overall performanc Improved technician perform-ance and better control of work on complex systems is needed. Excellence was noted in the performance of the great majority of surveillances, but the continuing problems indicate that past corrective actions have not been efft.ctive enoug IV. Conclusion Category .

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IV.D.3,, B_oard Recommendations licensee:

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Reduce the number of inaccurate, late and missed surveillances.

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Schedule a meeting with the NRC early in 1989 to discuss effectiveness of surveillance program corrective action NRC:

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Perform a mid-SALP period assessment of adequacy of surveillance performanc ..

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I Emergency Preparedness (34 Hours, 1%)

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IV. Analysis During the previous assessment period, licensee performance in this area was rated Category 1. That rating was based on observation of a full participation exercise which included the ingestion pathway results of a routine safety inspection, and ,

on licensee support of offsiis activities in response to a hurricane warnin :

"

During the current assessment period, there was one routine safety inspection and observation of a full participation exercise for Millstone Unit Emergency Pre-

'

paredness is a site function and the Emergency Plan as well as Emergency Response

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Facilities are common to all three units. Qualified Emergency Response Organiza- -

tion personnel are drawn from any unit and respond to an incident at any Millstone '

, uni t Routine safety inspection irdicated that the Emergency Plans and Emergency Plan Implementing Procedures were current, and were reviewed and approved per procedure Emergency Response Facilities were maintained ready, as evidenced by satisfactory l checks of communications systems, instrumentation being functional and calibrated, L

, and plans and procedures being current. An' Emergency Preparedness Training Manual

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has been developed, reviewed, approved, and placed in use. That Manual states ,

Emergency Preparedness Training policy, lists Emergency Response Organization positions and associated qualifications, required training for each position, and set the requalification perio The procedures for accident classification have been revised and incorporate human factors engineering principles. A review of *

these indicate they meet 10 CFR 50.47(b)(10) requirements, and that accident clas-sification is based on plant status in keeping with NRC guidance. A review of audit procedures intended to meet the requirements of 10 CFR 50.54(t) indicated

.

some minor improvements were needed: auditors needed an improved knowledge of  :

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Emergency Preparedness requirements and procedures; procedures or guidelines for  ;

preparing audit checklists needed to be developed; and documentation was needed  ;

to demonstrate compliance with the requirement to make available to State and local '

governments the results of licensee government interfaces, and an offer needed to be made to review Emergency Action Levels with offsite authoritie The annual exercise was observed on October 7-9, 1987 with one minor weakness noted.

4 Accidents were classified promptly and correctly, offsite notifications were made

within the required time, Protective Action Recommendations were developed, the

! Offsite Based Information System was available and functioned satisfactorily, pro-jected doses and dose commitments were performed frequently and differences between [

, corporate and site were quickly resolved, operation of the Post-Ac:ident Sampling (

System was demonstrated with very knowledgeable personnel, and response team ac- I

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tions showed the results of effective trainin The licensee has developed and maintains a sound Emergency Preparedness Prograer

as evidenced by very good exercise performance, well maintained Emergency Response Facilities and a satisfactory working relation with offsite authoritie ,

w I

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, 19 IV. Conclusion Category IV. Board Recommendations Nont.

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20 -

I Security and Safeguards (63 Hours. 3%)

f IV. Analysis

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During ti,e previous SALP, Millstone 3 performance was Category 1. That rating was

. largely influenced by the timely completion of the Unit 3 security systems and equipment and integration of those with the existing systems and eouipment for Units 1 and 2, while still maintaining an effective security program. During this assessment period, routine inspections by the Resident Inspectors continued throughout the period. Two routine and two spe::ial unannounced physical security inspections were performed at the Millstone Nuclear Station (Units 1, 2, and 3)

by region-based inspectors. Region-based security inspections were performed for the integrated. site (Units 1, 2, and 3) and it is not practicable to separate the units for assessment purposes. The same comments and assessments that were men-tioned in the Units 1 and 2 SALP (SALP Report 50-245/86-99 and 50-336/86-99) were repeated here if the inspections were current to this SALP period. The added com-ments reflect changes occurring during the past six month Corporate security management involveme n in site security program matters was apparent early in the period. There were visits to the site by the corporate staff to provide assistance, program audits, and direct support in the budgeting and planning processes affecting program modifications and upgrades. C6rporate secur-ity management personnel were activ61y involved in the Region I Nuclear Security Association and other industry groups engaged in nuclear plant security matter This demonstrated program support from 9pper level corporate management. However, an apparent reduction in the oversight and audit function occurred as a result of the loss of two key corporate personnel during the period, as discussed in the followin During the previous assessment period, the licensee was heavily involved in inte-grating the Millstone Unit 3 security program into the existing programs for Units 1 and 2. This was accomplished with minimum impact on the overall security progra The Itcensee decided that, with the integration of the program, modifications to and restructuring of the proprietary and contract organizations would be necessary to accommodate the increased workload. While that decision was made in late 1985, the licensee did not start acting upon the decision until late 1987. Several pro-prietary supervisory positions to which the licensee had committed were filled on a rotating basis without ensuring that the incumbents understood their duties and responsibilities, and without properly monitoring these individuals' performance, lherefore, the majority of the identified increased workload remained the respon-sibility of one person on site. As a result, effective oversight, interface and communications between the licensee and the contractor organization began to de-grade. Concurrently, it appears that a complacency with program implementation and an insensitivity to NRC requirements began to occur. These conditions were identified during an NRC inspection in August, 1987. That inspection resulted in the assessment of a civil penalty on the integrated security program. While the individual violations were of low significance, they represented a significant lapse in management attention to, and control of, the security program at Millston Five violations were identified during physical security inspections and were aggregated under the November 1987 civil penalty. Several of these violations had

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______

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, 21 existed for an extended period and should have been obvious to knowledgeable and attentive licensee security personnel. Additionally, several of the violations wsra attributed to the licers&a's oversight of the contractor's security force and tc th; training and atter.ti' cr. css of the security forc To increase the effec-tiveness of their oversight of the contract guard force activities, the licensee filled all vacant positions during the last half of the Unit 3 SALP period. Seve-ral more positions were created and filled as well. Members of the security force, as well as licensee line supervision, patrol the site frequently and should be alert for deficiencie The annual audit of the security program by the licensee's quality assurance grow :

appeared to be comprehensive in scope and depth. However, the number of violations identified by the NRC, several of which had existed for a lengthy per iod of time, called into question the effectiveness of those audits relative to NRC security objective Late in this assessment period, the licensee strengthened the corpor-ate security staff and began performing comprehensive audits as they had during prior assessment periods. In addition, the licensee submitted a security plan amendment clarifying the audit functions of the NUSCO Quality Services Croup with regard to the annual audit of the security program to increase their effectivenes In March of 1988, region-based inspectors conducted a comprehensive security pro-gram review and determined that all previous unresolved items and violations had been adequately addressed and corrective actions taken were effective to prevent recurrence. Further, no additional violations of NRC-approved security plans were observed. The licensee took strong, positive action to not only provide adequate follow-up on past issues, but initiated several significant actions to enhance the effectiveness of ihe security progra This turn-around ir direction and hands-on participation by senior management re-suited in a total security system upgrade, new administrative offices and classroom facilities for the sscurity force contractor, additional patrol vehicles and the establishment of a setirity review committee to review changes to security plans, procedures, and other security related records. These actions required large capital expenditures and demonstrated the licensee's desire to have a high quality and effective security progra Further, the licensee mobilized the resources of all essential plant operations in preparation for a forthcoming NRC Regulatory Effectiveness Review (RER). As of the most recent security inspection, the licensee had completed about 60% of the voluntary upgrades identified by this effor This further demonstrated the licensee's desire for an effective security organization and their responsiveness i to NRC concerns and initiative At the end of the assessment period, the security union's bargaining unit personnel went on strike. Union members of the contract security force walked offsite after

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being properly relieved by a pre-trained strike contingency security force. An i NRC follow-up inspection found that the picketing by contractor security personnel was orderly and peaceful. All required security posts were manned, the required i

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. 22 response force was available, and all necessary compensatory measures were in plar The walkout preplanning demonstrated that the licensee had the capability to manage a major event that could have a significant impact on the quality and effectivenesi of facility securit Review of the licensee's security event reports and reporting procedures found them consistent with the NRC's regulation (10 CFR 73.71) and implemented by personnel knowledgeable of the reporting requirements. The reports were clear and contained sufficient information for NRC assessment. Licensee actions following tach of the eventc,were prompt and appropriate. Twenty-five reports were received during the assessment period. Ten of these were attributed to see.urity fcree personnel errors which indicated a need for improved training. The remaining events were not causally linke Staffing of the contractor's security force appeared adequat The training and requalification program was sour.d and well-developed, but because of the problems

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f d.ntified during this assessment period, it needs to be reviewed for fundamental weaknesses along with the manner in which it is being implemente During the assessment period, the licensee submitted four revisions to the Mill-stone Nuclear Power Station Security Plan and two revisions to the Guard Training and Qualification Plan under the provisions of 10 CFR 50.54(p). The plan changes were of good quality and indicated knowledge and understanding of NRC security program objective The licensee's security program, when properly implemented, is sound as evidenced by the licensee's past performance record. During the first half of this assess-ment period, ineffective control of the integrated security program was evident in the multiple violations of_the approved security program. During the last half of this assessment period, the licensee actively pursued a program to ccrrect all deficiencies, fill all vacancies, increase oversight of the contract guard force, and increase the effectiveness and scope of the audit program. Follow-up NRC re-view of licensee corrective actions found very good correction of problem aspects, plus several significant enhancements to increase the effectiveness of the security program. Tha licensee's physical security program is improvin In summary, while substantive problems were identified earlier in the SALP period, later assessment of the corrective actions and effective planning and management of the security function during a strike indicated much better performance. Ef-fective continuatir,n of this trend could restore the performance rating to its previous high leve IV. Conclusion Category 2, Improvin IV. Board Recommandations Non . .

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! I Outage Management (272 Hours, 11%)

IV. Analysis Outage management was evaluated as Category 1 in the last wAL Strengths were noted in planning, scheduling, and overall conduct of outages. Minor weaknesses were noted in tagging and the control of maintenance, leading to Mode 3 bei entered with a hot leg injection valve tagged shu As discussed in Area IV.A, Plant Operations, configuration control continued to be a problem during the current period. On two separate heatups, Mode 3 was en-tered without the required full ecmplement of safety equipmen There were two unplanned outages, and one planned and one refueling outage. The unplanned outages were short (less than 2 weeks) and resulted vNin recoveries from plant trips were delayed to perform maintenance. Management at the unit and de-partment head level proved very capable et adapting to rapidly thanged conditions to support these unplanned outages. Department heads quickly provided unplanned shutdcwn work lists and generated detailed hourly work breakdowns for major c-ti-vitie Licensee management used unplanned shutdown time to accelerate work on committed repairs and modifications. Cooperation was strongly evident at all levels of management when scheduling and planning tasks and at the grass roots level when performing work. Unplanned outage duration was effectively limited in length by aggressively prioritizing and completing wor The first refueling outage was also well planned. Outage meetings were held at frecuent intervals in the year prior to the outage. Planned activities were sequenced in the licensee's sophisticated "living schedule" system. That system

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was used to generate a mister outage schecule comolete with bar charts, a sensi-tivity analysis for each task that might impact the critical path, and logical ties between tasks. The schedule received senior anu supervisory management reviews cnd modifications prior to outage commencement. Twit:e daily during the refueling outage, an expandea time-base printout of the current three-day window, including

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all recent updates to the master schedule, was provided to all supervisors during a status neeting. These meetings were characterized by accurate assessment of work

. in progress and resolution of conflicts. Tight controls over the schedule and plant conditions were maintained. Many potential problem, were avoided by early addressal. During these maetings, NRC observers noted a strong spirit of coopera-tion and a very positive attitude toward nuclear safety and high quality perform-anc Refueling outage planning was set back when foreign objects were discovered on the lower core plate on November 17, 1987. These were locking cups for hold-down bolts for the reactor coolant pump (RCP) internals. The need to remove and iden-tify these objects required a .omplete core off-load. Subsequent work extended the refueling outage for six weeks. The lic.nsee shortened the initial expected duration of 12 extra weeks to 6 by effective use of a "Living Schedule." Inspector observations found that the actual performance of work was timcly and safety con-

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scious. The use of an actual RCP as a mockup substantively improved work sequenc- -

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. ing and timeliness. Licensee control of refueling outage activities was otherwise r

- strong as wel *

In summary, control of outage activities was a noted strength. The twice daily '

meetings and use of the "Living Schedule" allowed excellent contrcl.and management i of outages.

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IV. Conclusion I Category IV. Board Recommendations Non ,

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I Engineering Sur, port (209 Hours, 9%)

IV. Analysis Engineering Support was a new area for the last SALP and was rated as Category This area encompasses technical and engineering support activities provided by onsite and offsite organizations to the line departments. It also incorporates line department activities that support operations, maintenance, s~urveillance and other technical organization In the previous SALP, recommendations were made to the licensee to resolve issues ,

requiring engineering attentio The cited issues ware: steam generator (SG) :

feedwater flow oscillations; elimination of illuminated control board annunciators; power-operated relief valve (PORV) internal loakage pmbbms: and main steam valse building heating and cooling problems. All of these issues a m addressed by the license lhe SG feedwater flow oscillation (and SG 1evel control) problem was ameliorated by a change to the SG condensate pot design implemented during the first refueling outage. Installation of a high pressure tee and straightening of the condensing line corrected the 10% level oscillation that had been observed between 55% and 65% power. Testing and operation confirmed that the design change corrected the oscillation problem. A significant reduction in scram frequency from feedwater

. oscillations has since been see A total review of annunciators illuminated during power operation was completed in 1987. At the end of the Cycle 1 refueling outage, all but 18 of the identified annunciators had been permanently corrected. M discussed in Section IV.A, Plant Operations, completion of the annunciator reouction program has been delayed to the end of the third refueling outag This delay is general iy appropriate, but continued engineering support is needed to addres; problem annunciators (radiation monitor spiking) and to assure that the program is completed as expeditiously as practicabl When maintenance was performed on leaking PORVs, technical competence was evident in the implementaiton of bench testing of the PORVs and the associated solenoid valves. In addition, the use of flanged joints on the PORV: m a coordinated de-cision involving management, engineering and maintenance and we an example of good decision making and techaical plannin The onsite and offsite engineering and technical support group': vere very capable and staffed with experienced, knowledgeable personnel. They wer3 dedicated to performing tasks correctly the first time. Examples of support u tivities to im- 1 prove safety and reliability were conversion of the service water discharge valves from a lined material to corrosion resistant materials, redesign of the feed pump i seal injection system to extend seal life, and shaving of the turning gear oil pump impeller to eliminate pressure transients caused by securing the pum , _ __

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Two other engineering support activities were noted as being beneficial to opera-tion. These were the elimination of the reactor coolant system (RCS) resistance temperature detector (RTO) bypass manifolds and the substitution of a hypochlorite system for the existing gaseous chlorine system. The removal of the RTO bypass manifold will pay ALARA dividends in future outages. Its removal has reduced the outage radiation levels to 50% of the previous levels. The removal of the gaseous chlorine system, used as a biocide in the condenser circulating water system, has resulted in the last gaseous chlorine source being removed from Millstone Statio This has allowed the removal of the chlorine monitoring requirement for control room habitability. Th se modifications have enhanced Unit 3 operation Offsite corporate engineering support was evident but not always timely. Both plant engineering and corporate engineering dealt with the same engineering issues at various times. This organizational relationship sometimes created conflict The reliability c.' the Rosemount RCS flow transn.itters was an exampl Five fail-ures of these transmitters occurred between March and October of 198 Since only one failure occurred at a time, the trip functions of the flow instrumentation remained operable. After each failure the transmitters were replaced in kin *

No sub>pquent failure > nave been experience decause of the frequency of these failures with the same root cause, the plant evaluated the failures as a potential substantial safety hazard reportable under 10 CFR Part 21 and forwarded their findings to corporate engineering in November 1927. Corporate engineering, after contacting the vendor, disagreed with plant engineering. Rosemount stated to cor-porate engineering that there was ar, error in the manufacturing process but it had already been corrected. Corporata engineering changed its position in March 1988 and the failures were then reported under 10 CFR 21. Independent NRC followup showed that this same failure mechanism was identified in prior transmitter fail-

!

ures at the J.A. FitzPatrick Nuclear Power Plant. Corporate engineering's late reporting of this problem unnecessarily celayed report dissemination to other Rosemount user Two scrams in the period were caused by the failure of normally energized Skinner solenoid valves for the feedwater system's containment isolation valves (CIVs).

The licensee also determined that an earlier, out-of period scram was due to this solenoid's ma1 performance. The original design uses high-wattage solenoids for these fail-shut CIVs. 1hese solenoids have been shorting out with age. The lic-entee replaced the solenoids during the refueling outage and ordered new low-wattage solenoids with an expected delivery date in November 1988. Licentee ef-forts to correct this problem have been reasonabl However, procurement delays due to long lead times have hindered prompt correctio In response to an allegation related to the seismic adequacy of the battery room masonry walls, NRC review found a violation and a deviation. Upon receipt of fur-ther information from the licensee, the NRC concluded that the apparent deviation was the result of an incurrect licensee assumption about the design requirements of the masonry walls and that this represented an isolated oversight. The battery room walls were built to the srxe standards as the control buildin That was

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found to be adequate af ter detailed staff review of the licensee's reanalysi Although the walls were acceptable in the as-built condition, this event indicated a need for attention to detail when implementing standard In the area of Environmental Qualification (EQ), the one inspection performed duringthisassessmentperiodidentifiedmultipleapparentviolations. The lic-ensee s efforts to support the EQ inspec'.imi were only marginally acceptable. At the time of the inspection, the licensee was attemptino to strengthen their staff to upgrade the experience levels over that previously provided by contract person-nel. Managemont involvement was evident in the response and participation of management personnel with significant EQ issues. NRC concerns raised over the electrical EQ of Litton-Vea, connectors elicited concern and an immediate response from the licensee. Cognizant personnel were gathered to discuss and address the issue. Engineering personnel quickly provided an analysis and a viable operation justification statement. Management understanding, acknowledgement and concern for iublic safety was evident in the actions taken. (The enforcement considera-tions t.ssociated with this matter carry over into the next SALP period anc will therefore be considered in the next SALP report.)

Overall, the engineering staff did a good job of supporting maintenance and sur-veillance. Engineering support contributed to good and technically sound decisions by plant management r(lative to maintenance and survaillance activitie IV. Conclusion Category IV. Board Recommendatio_ns

_ Licensee:

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Improve knowledge level of personnel implementing the EQ progra Ensure high level management attention is given to resolving EQ issue N_RC :

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I Licensing Activities (No hours assigned)

IV. Analysis The previous SALP rated this area as Category 1 and recommended that the licensee assure the accuracy of submittals to the NR During this SALP period seventeen (17) license amendments and eighteen (18) other licensing actions were completed. These thirty-five (35) licensing actions in-cluded the completion of licensee commitments, Cycle 2 reload, Resistance Tempera-ture Detector (RTO) modification and Technical Specification improvement Licensee management has been aggressive in meeting commitments, promptly resolving :

issues, and improving the Technical Specifications. This attention resulted in submittals that were mostly accurate and complete. Frequent contacts, by meetings or telephone, with the NRC licensing staff resulted in the prompt resolution of issues and on satisfactory schedules for completion of licensing actions. Most licensing actions were completed without requiring review on an exigent or emer-

'

gency basis. Prempt management attention was provided to resolve issues associated with providing overcurrent protective devices for containment electrical penetra-tions, three loop operation, ATWS consideration in tiie Cycle 2 reload analysis, and the imprw ement of licensee event report The licensee subuittals indicated a sound technical approach to resolving safety issues. They also indicated a good understanding of the safety issues, ano oro-vided technically' sound proposals with reasonable justifications for resolutu The licensee has been responsive to NRC initiatives. Priorities and schedt.les established for NRC initiatives were acceptable to both the staff and the license The licensee responded in a positive and timely manner to provide information for '

the Safety Issues Management System (SIMS), for consideration of Anticipated Transients Without Scram (ATWS) in their Cycle 2 reloaa analysis, and for resolu-tion of long standing issues associated with the Safety Parameter Display System (SPDS), the Nuclear Review Board Quorum, the vendor information program for certain safety related components, and the cleaning of feedwater venturi The quality of the licensee's submittals has improved; however, inaccuracies still existed in a few submittals: (1) in the May 20, 1987 letter on Class IE Containment l Electrical Penetration Protection, the analysis did not satisfy the requirements of 10 CFR 50.59 or 10 CFR 50.109; (2) in the March 24, 1987 letter on Containment Sy:tems Air Partial Pressure, the "no significant hazard" finding was not correct !

because the proposed change created the possibility of an unevaluated accident;

,

and (3) the February 25, 1988 letter regarding Steam Generator Low-Low Level Reac-tor Trip Setpoint did not provide supporting analysis for the justificatio In addition, the licensee subsequently informed the staff that certain errors were not considered in the analysi Notwithstanding the above noted instances, the licensee's licensing staff was well qualified and supported, as necessary, by a qualified technical staf Requests for information were promptly responded to in conference calls, correspondence or

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

f

,

meetings as deemed appropriate. Responses were usually technically sound, had appropriate management review Und approval and were submitted on or ahead of schedul In summary, licensee management was aggressive in providing prompt, accurate, com-plete and. technically sound responses that were oriented toward nu: lear safet Licensing resources were ample and effectively used to achieve a high level of performanc IV. Conclusion

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Category IV. Board Recommendations Licensee: Continue the effort to assure accurate submittals, i

l NRC: Non .

.

n a

- - -

_ .. __

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

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, 30 I Training and Qualification Effectiveness (No hours assigned)

IV. Analysis Training and Qualification Effectiveness, a new area in the last assessment period, is also an evaluation criterion for each functional area. This area is a synopsis of the assessments in the other areas. Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, through program review. During the last SALP, a Category 2 rating was assigne The plant specific simulator was a significant benefit in operator training and was used to train managers as well. The licensee developed an experienced training staff with over twenty instructors, three quarters of whom maintained operating licenses. There was a strong supervisory organization to manage the training staf Recent promotions of key in-house people within the training organization have helped the licensee to strengthen an already strong organizatio The INPO Accreditation Self-Evaluation Report for the four Northeast Utilities operator training programs was submitted by the licensee on Novemoer 1987. An INPO accreditation team visited in late January 1988 and Millstone 3 programs were accreafted in April 1988. (The Technical Training Programs had previously received INPO accreditation in the areas of instrumentation, health physics, chemistr/,

mechanical and electrical maintenance, and technical staff and managers.) Thus, INPO accreditation is complete for Millstone 3 and the station as a whole. With this accreditation, Hillstone 3 became a member of the National Academy for Train-ing by virtue of the fact that they now nave received accreditation for all ten of the INPO accreditable programs at their site. Completion of the total accredi-tation process for all three units reflected strongly on the licensee's dedication to training, especially since Millstone 3 was in the NTOL (near term operating

license) phase until late 1985. Review of Millstone 3 programs did not occur until after full power license issuance because of other INPO accreditation commitment Thirteen candidates participated in the two NRC replacement examinations admin e stered during the assessment period. Of these, five candidates failed the wricten and/or operating portion of the examination. This is an overall pass rate of 61.%

and a decline from the overall pass rate of 83% (43 of 57) achieved during the last SALP period. During the simulator portion of the examinations, the performance of crews was inconsistent. Some crews operated quite well together with good com-munications and the ability to diagnose problems, whereas other crews were some-t',mes weak in communications and problem diagnosis. Four of the five individual failures were based partly or solely on the operating portion of the examinatio Although the number of operators examined was relatively small, this indicated that better screening of operators by the licensee may bt needed prior to NRC exam administratio Cooperation between the plant and the training staffs has led to effective ds*elop-ment of programs to assist the operating staff in the preparation for complex t sk One example was a training program specifically developed to address a positive moderator temperature coefficient (PMTC). This program was given to all operat tg

. _ _ _ _

t

, 31 shif ts and covered reactor start-up, low power operation, and selected malfunctions on the simulator, permitting a successful staytup after the first refueling with no operational problems associated with PMT Maintenance and I&C technician training programs were in place during this assess-ment period. NRC observattens of these programs found that they were effectiv An inadequacy was noted in an I&C contractor technicians's training when he pulled a fuse in a SSPS panel, causing a loss of LTOP protection and an overpressure transient (see Area IV.0, Surveillance). The transient was partially attributable to the way the technician was trained to analyze system prints for the fuse pulling evaluation and partially attributable on the inadequate emphasis on the SSPS-COPS interrelationship during both operator and technician training. These programs now emphasize this interrelationship. Further refinement of the review of drawings before disabling equip:nent was established by the licensae. The licensee imposed restrictions to only allow specifically qualified technicians to work certain panel Licensee Event Report (LER) review found that, of 58 LERs, 28 were due to personnel error. "ersonnel errors fell into three categories: lack of attentiveness, lack of attention to detati, and inadequate trainin The majority of events were caused by inattentiveness or lack of attention to detail. Examples were failing to restore cooling water lineup to the operable charging pump, failure to perform an engineering evaluation after replacement of a defective snubber, and failure to perform a required Diesel generator fuel sample. However, training in systems, procedures and integrated plant response was generally effective: there was no significant c ullenge to safety systems other than the overpressure event (analyzed in Section IV.A, Plant Operations.)

It is apparent from the maintenance and surveillance activities observed during the assessment period that Millstone 3 personnel arc well-trained and carry out their j;bs in a professional manner. A particular instance of this was maintenance department identification of a problem while installing "handhole" covers on a steam generator. Even though the covers were installed per the procedure, the workers questioned the end resul Because of this, a procedure change was issued to install the covers via an alternate method. Their willingness to question the outcome of a job indicated good training of the worker In summary, licensee training was a notable strength. The licensee's commitment, to training was evident in enhanced training staffing with a high percentage of experienced licensed operators and expenditure of considerable resources for training. Operators were assessed as excalient performers on shift. Also, a high level of operater and support personnel knowledge was consistently demonstrate Training was generally effective in providing well qualified personnel who con-tributed positively to safe operation, but better licensee screening of operator candidates is needed to incresse performance on NRC exam . - - . - - - - - - - - - - - _ - - . - - - - - - _ _ . - - - - - - - - - - ,

.

. 32 IV. Conclusion Category IV. Board Recomendations Non .

,

I Assurance of Quality (No Hours Assigned)

IV. Anaissis Assurance of quality is addressed as a separate functional area even though it is an evaluation criteria in other functional areas. The licensee's quality assurance program is included, but this assessment primarily addresses the effectiveness of licensee management efforts to assure quality in day-to-day activities. Worker performance, attitudes, involvement by supervisors, and the adequacy and use of management and administrative controls were used as performance indicator During the previous SALP period, observations found Millstone 3 ptrsonnel to have a standard of completing assigned work correctly. This positive ottitude was re-peatedly displaye During the current SALP period, workers and supervisors showed pride in their workmanship and close attention to detail was typically demonstrated. Department Heads were very knowledgeable of the status of work. Plant personnel exhibited a good attitude towards QA and adherence to procedures. The individuals closest to the work (operators, technicians, mechanics, electricians, engineers, etc.)

exhibited high personal performance standards and detailed knowledge of equipment and procedures. Worker morale was observed to be high. Additionally, it was clear that management has imbued the workers with a sensitivity for quality in the work plac Workers performing maintenance and surveillance activities exhibited good work practices and brought concerns to the attention of their supervisor For example, during the installation of steam generator "handhole" covers, mechanics performing the job questioned the installation of the covers even though all the procedural requirements were met. As a result, the covers were removed and reinstalled using an improved torquing sequence. This r5 owed a concern for and attention to quality workmanship by the "front line" persont.cl deing the wor QA/QC personnel were found knowledgeable of the tests they were monitoring, as observed Juring main steam safety valve testing. QC inspectors were found to be trained, qualified and certified to the level of their responsibilitics. Site staffing levels were fcund adequate to support and normal operations, with head-quarters and contractor personnel available as neede The licensee's QA/QC organizations performed ef fective surveillances and inspec-tions and promptly identified problems to management for resolution. Discussions with QA/QC supervisors and QC inspectors and review of completed work packages indicated sufficient QA/QC involvement with site activities. Maintenance instruc-tions were clear and appropriate QC sign-offs were included in the QC inspection plans for each job. In addition to routine inspection hold points, corporate engineering QA and plant engineering QA/QC groups performed audits, surveillances and activity observations. Concerns identified as a result of QA surveillances and QC inspections were resolved in a timely fashion. Management was kept apprised of appropriate findings and resolution of findings was effectiv _ - _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _

.

.

First line supervisors provided close oversight of work activities. Maintenance, I&C, and Production Test supervisors were generally knowledgeable of the plant design and station administrative requirements. They were often observed to be providing technical guidance and oversight to workers at the work site. Further, Shift Supervisors demonstrated that they were generally knowledgeable of plant activities and that they were managing activities and shift personnel on an as-needed basis except in one instance regarding insufficient staffing for feedwater control during startup (see Area IV.A. Plant Operations).

.

Plant Operation Review Committee (PORC) performance was very good. Meeting inputs were well prepared and showed a clear understanding of issues. The apprnach to problem resolution was technically sound, very thorough, and routinely conservativ Root causes of problems were actively pursued. During meetings and in NRC discus-stons with higher level managers, there was a licensee willingness to deal with difficult issues and an atmosphere of healthy self-criticism. A conservative approach to safety was demonstrated by operating departments in the resolution of problems and routine activities. This was demonstrated in the Spring 1987 outage for snubber work and, more recently, in troubleshooting to investigate and correct

, the failure of a control bank to move. There was a high regard for meeting regu-

'

latory requirements and commitments. Site management was effective in estabitshing nuclear and persor.nel safety as well as efficiency as a prime operating goa During review of procedures for testing of the containment penetration overcurrent protection devices, the NRC noted that some procedures contained over three change Licensee procedures require that, after three changes, the changes be incorporated as a revision. This particular problem was previously identified by the licensee in a QA Surveillance Report. At the time of inspection, the licensee stated that j the backlog of procedure revisions should be eliminated by June 1988. The licer.-

see's method for updating procedures and the manpower associated with the task along with management attention and support of the update program may not be suf-ficient since, as of the SALP Board meeting 74 procedures needed revision because they contained three or more changes. The licensee failed to meet their goal of zero backlog by the end of the second quarter of 198 NRC inspections observed that corporate management was routinely involved in plant activitie The licensee has successfully implemented a tracking system (con-trolled routing) to assign corrective actions to responsible individuals for meet-ing NRC and other commitments, The use of controlled routings as a tracking tool for meeting commitments was a notable strengt Corporate management responsiveness was demonstrated by their addressal of NRC staff concerns with the environmental qualification (EQ) of Litton-Veam connector The ability of the connector's internal silicone rubber gasket to be leak-free over plant life was the focus of the issue. The questionable EQ of these connectors was attributed to licensee control of EQ during construction. During this SALP period, licensee review of the design attributes allowed the NRC staff to evaluate the connectors as posing no immediate hazard. Connector replacement is scheduled j during the next refueling outag ______________________

.

,

Another example of a stund licensee approach to problems involved their actions when foreign objects were discovered on the lower core plate on November 17, 198 These objects were locking cups for hold-down bolts for the reactor coolant pump (RCP) internals. The decision to completely off-load the core to remove and iden- '

tify these objects was a prime example of the licensee's safety conscious approac Subsequent work extended the refueling outage for six weeks. The licensee cut the initial expected duration of 12 extra weeks in half by effective use of a "Living Schedule." Use of a spare RCP as a mockup substantively improved work sequencing and timeliness. Licensee control of other refueling activities was equally stron Additional licensee attention to the timeliness of 10 CFR 21 reports was neede Oil leaks from the internal diaphragm of Rosemount transmitters was reported under 10 CFR Part 21 on March 24, 1988. Five transmitter failures between March and October 1987 were due the same root cause. Inability of the licensee's corporate engineering staff to obtain a complete historica.) record of the transmitters sig-nificantly contributed to the delay in initiating the Part 21 repor Prompt re-porting of this issue would have allowed other Rosemount users to benefit from the licensee's experience (see Section IV.H., Engineering Support).

In summary, both licensee management and staff were committed to high quality in operations. There was effective implementation of the formal QA/QC function and solid support of operations and related activities. Management exhibited a con-servative and safe approach to performing surveillances and exercised good judge-ment in decision making and technical planning of maintenance. A high level of concern and attention to quality work was strongly evident from the working level to station management. Programs were established to bring abnormal results to the attention of supervisors and management for resolution. Changes to procedures were underway to ensure that they were current with r espect to industry information and NRC requirement Increased licensee sensitivity to the timeliness of 10 CFR Part 21 Reports and the backlog of procedure changes were was the only neted problem IV. Conclusion Category IV. Board Recommendations License,e: Resolve the procedure chtage backlog proble NRC: None.

__ _

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3 SUPPORTING DATA AND SUMMARIES V.A. Investigation and Allegation Review

--

Battery walls did not meet seismic design criteria. This allegation was sub-stantiated. A violation and deviation were issued. The licensee's response

} justified their design as equivalent to that used for the control buildin This was found acceptable by the NRC staf A foul smell was emanating from radioactive releases from the sit This allegation was unsubstantiate Widespread illegibility of certified material test reports (CMTRs) associated with Millstone 3 purchase orders. Two out of 450 CMTRs sampled were found illegible during NRC follow-up; this allegation was unsubstantiate V.B. Escalated Enforcement Actions Civil Penalties

--

$25,000 - IR 87-22, Physical Security

--

550,000 - IR 88-03, Low Temperature Overpressure Transient V.C. Management Conferences

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November 3, 1987 at the Region I Office: to discuss station security viola-tion March 8, 1988 at the Region I Office: to discuss a Low Temperature Overpres-sure transien V.D. Licensee Event Reports V.D.1, Tabular Licensing Type of Events Personnel Error 28 Design / Mfg / Construction / Install Error 8 External Cause 0 Defective Procedure 10 Component Failure 13 Other _0 TOTAL 59 A tabulation of Licensee Event Reports (LERs) by functional area, and an LER synopsis, is attached as Table _ _ _ _ _ _ _ _ _ _ _ __ _ _ __ _

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

.

, 37 Licensee Event Reports Reviewed LER Nos. 87-08 through 88-15 V. Causal Analysis Millstone 3 LERs were reviewed to determine if causal links could be establishe The LERs reviewed were 87-08 through and including 88-15. These LERs are inclusive of the SALP period (3/1/87 - 5/31/88). Some supplemental LERs were published by the licensee during the period as their investigation was completed and were re-viewed as the sole source writeup on a given event since they provided the most up-to-date information. LERs were reviewed with the intent of establishing causal links, if appropriate, to events that were due to the malperformance of a procedure, an individual, a department, a program or other commonly related items. Where events were the result of isolated failure or deficiencies, no causal link was establishe LERs 87-21, 87-25, 87-37, 88-09 describe reactor trips that resulted from inade-quate integrated control of SGWLC (Steam Generator Water Level Control), steam dump snd rod control systems. SG level oscillations were compounding the control prob-lem between 55% and 65% power due to faulty design of the level condensate pots (see LER 87-22). The frequency of these events is decreasing and the replacement of the condensate pots with high pressure tee fittings has 011minated the level oscillations at 55%-65% powe LERs 87-12, 87-35,-87-39, 97-40, 87-42, 87-44, 87-45, 87-46, 87-50, 87-51, and 88-11 document the malperformance of required surveillances. Generally, the prob-lems cited were addnistrative, with one notable exception being late or missed surveillances. Sud, a problem was identified in the last SALP as due to the tardy development of procedures to implement the Technical Specification surveillance program. The continually large number of problems in this area indicates a need for further management attention to surveillanc LERs 87-20, 87-48, and 88-12 describe events where fire watches were not estab-lished as required when breaching a fire barrier or intentionally disabling sup-pression system LERs 87-30 and 88-06 document events where mode changes were made inadvertently or without a full complement of safety equipment. The licensee's internal Plant Incident Reporting system has also documented mode changes without a full comple-ment of safety equipmen .

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V.E. Licensino Activities V.E.1, NRR/ Licensee Meetinos 3/27/87 Shutdown in advance of severe weather 6/2-3/87 Inservice testing program for pumps and valves 7/7/87 Interlocks for three loop operation 8/5/87 Safety Parameter Display System ,

9/1/87 Cycle 2 Reload and RTO Modifications 4/25/88 Safety Parameter Display System V. NRR Site Visits 5/20-22/87 Orientation 10/13-16/87 Review 50.59 changes (1986)

4/11-15/88 Review 50.59 changes (1987)

V. Reliefs Granted l l

l A3ME Boiler and Pressure Vessel Code - Section XI and Applicable Addenda: 29 relief i requests granted related to inservice testing of pumps and valves.

l V. License Amendments Issued AMENDMENT SUBJECT DATE

i 2 Engineered Safety Features Atmosphere Cleanup System 4/7/87

'

3 Engineered Safety Feature Response Time for Low 4/9/87 Steamline Pressure ,

4 Diesel Generator 18-month Inspection Schedule 5/13/87

5 Centainment Purge Supply and Erhaust Isolation Valves 6/15/87 i Leak Test Interval

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6 Organization Change - Station Services 6/15/87 7 Reactor Coolant , Loops Operating During Hot Shutdown 7/9/87 l 8 Reactor Trip Bypass Breakers , 8/7/87

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, 39

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V.E.4(CONTINUED)

AMENDMENT SUBJECT DATE 9 Control Building Inlet Ventilation Signals 8/21/87 10 Diesel Generator Startup Time 8/24/87 11 Main Turbine Centrol Valve Test Interva; 9/30/87 12 Cycle 2 Reload 1/20/88 l

13 Instantaneous Trip Element Surveillance Tests 1/20/88 14 Chlorine Detection System 2/16/88 15 Nuclear Review Board Records 2/23/88 16 Snubber Sample Plans 4/7/88 17 Reactor Coolant System Leakage Systems 4/18/88 18 Reactor Coolant System Vent Area fcr Cold 5/19/88 Overpressure Protection

I I

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TABLE 1: INSPECTION HOURS AND REPORTS TABLE 1A: INSPECTION HOUR SUMMARY AREA HOURS % OF TIME PLANT OPERATIONS 1021 4 RADIOLOGICAL CONTROLS 334 1 MAINTENANCE 317 1 SURVEILLANCE 136 EMERGENCY PRE .4 SEC/ SAFEGUARDS 102 OUTAGE MANAGEMENT 272 1 ENGINEERING $UPPORT 209 *

TRAINING EFFECTIVENES$ ASSURANCE OF QUALITY

• ' TOTALS: 2425 10 *The inspection hours for these composite assessments are incorporated in the other *

8 functional areas listed in this tabl Note: The Licensing Activities functional area is not a direct inspection activity I and rio inspection time is accumulated in this are i l TARLE 18: SYNOPSIS OF INSPECTION REPORTS REPORT / TYPE OF l DATES INSPEC HOURS DESCRIPTION 87-05 RESIDENT 110 SHUTDOWN PLANNING, PLANT OPERATIONS, RADI-2/18-3/16/87 ATION PROTECTION. SECURITY, FIRE PROTECTION, SURVEILLANCE AND W 4NTENANCE

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l 87-06 SPECIALIST 2 SOLIO RADWASTE CLASSIFICATION, HANDLING l 3/9-13/87 AND TRANSPORTATION, ENVIRONMENTAL MONITOR- ,

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ING, AND RADI0 CHEMISTRY QUALITY CONTROL 87-07 3PECIALIST 57 EXTERNAL AND INTERNAL EXPOSURE CONTROLS, 3/26/87 FACILITIES AND INSTRUMENTATION, TRAINING AND OUTAGE ALARA t 87-08 RESIDENT 121 SHUTDOWN PLANNING, PLANT OPERATION, RADI-

! 3/17-5/11/87 ATION PROTECTION, SECURITY, FIRE PROTECTION, SURVEILLANCE AND MAINTENANCE I 87-09 SPECIALIST 74 MAINTENANCE ORGANIiATION AND IMPLEMENTATION, f 3/30-4/3/87 TRANSFORMER PROGRAM, TRENDING T-1-1 i

I

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. Table 1 2 REPORT / TYPE OF DATES INSPEC HOURS DESCRIPTION 87-10 SPECIALIST 36 SNUBBERS, PORVS, MSIVS, CONTROL ROOM PRES-5/4-8/87 SURIZATION SYSTEMS, SURVEILLANCE DATA 87-11 SPECIALIST 9 WHOLE BODY COUNTING PROGRAM 5/18-20/87 87-12 RESIDENT 196 SHUTDOWN PLANNING, PLANT OPERATIONS, S/12-7/10/87 RADIATION PROTECTION, SECURITY, FIRE PRO-TECTION, SURVEILLANCE AND MAINTENANCE 87-13 SPECIALIST 1 EMERGENCY PREPARE 0 NESS 6/29-7/2/87 87-14 SPECIALIST 12 RAOIATION PROTECTION, STATION AUDITS, AND 7/6-10/87 HOT PARTICLE PROGRAM 87-15 SPECIALIST 61 SEISMIC ADEQUACY OF THE MASONRY WALLS 6/8-25/87 AROUND BATTERY ROOMS 87-16 SPECIALIST 0 NRC EXAMINATION OF SIX SENIOR REACTOR 8/1'/-21/87 OPERATOR CANDIDATES 87-17 RFSIDENT 201 ACTIONS ON OPEN ITEMS, SECURITY, PLANT 7/11-9/21/87 OPERATIONS, ALLEGATION RI 87-A-65 (CERTI-FIED MATERIAL TEST REPORTS)

87-18 SPECIALISi 43 SECURITY AND SAFEGUARDS 8/31-9/4/87 87-19 SPECIALILT 17 OPEN ITEMS IN POST-ACCIDENT SAMPLING, 9/14-17/87 MONITORING AND ANALYSI SPECIALIST 33 EMERGENCY PREPAREDNESS AND OBSERVATION OF 10/7-9/87 LICENSEE'S ANNUAL EMERGENCY EXERCISE 87-21 RESIDENT 133 PLANT OPERATIONS, SECURITY, LER REVIEW, 9/22-11/2/87 COMMITTEE ACTIVITIES 87-22 (REPORT CANCELLED)

87-23 SPECIALIST 0 EXAMINATION REPORT 6/12/87

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T-1-2

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

.

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Table 1 3 REPORT / TYPE OF DATES INSPEC HOURS pESCRIPTION 87-24 RESIDENT 179 OUTAGE ACTIVITIES: FOREIGN OBJECTS ON LOWER 11/3-12/7/87 CORE PLATE, ABNORMAL RWST AND RCS SODIUM, -

MAIN 1ENANCE AND SURVEILLANCE 87-25 SPECIALIST 37 GASEOUS AND LIQUID EFFLUENTS 11/16-20/07 87-26 SPECIAl.IST 37 ECCS SURVEILLANCE AND ACTIONS TO IMPROVE 11/16-20/87 IMFROVE REACTOR TRIP BREAKER RELIABILITY '

87-27 SPECIALIST 63 REVIEW RAD PROTECTION ACTIVITIES ASSOCIATE 0 11/16-20/87 WIiH THE UNIT 3 OUTAGE 87-28 ..fSPECIALIST 0 EXAMINATION REPORT 12/14-18/0 SPECIALIST 21 SG E00Y CU.1 RENT INSPECTION, WATER CHEMISTRY 11/30-12/4/87 CONTROLS, RADIATION CONTROLS

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87-30 RESIDENT 90 SHUTDOWN PLANNING, PLANT OPERATIONS, RADI-11/25/87- ATION PROTECTION, PHYSICAL SECURITY, FIRE 1/15/88 PROTECTION, SURVEILLANCE AND MAINTENANCE 87-31 SPECIALIST 8 SURVEILLANCE CF COMPLEX SAFETY-RELATED 11/30-12/4/87 SYSTEMS, INPLANT INSTRUMENT CALIBRATION, MEASURING AND TEST EQUIPMENT 87-32 SPECIALIST 56 NONRADIOLOGICAL CHEMISTRY PROGRAM AND 12/14-18/87 ANALYTICAL PROCEDURE EVALUATIONS l 87-33 RESIDENT 118 OUTAGE, DECAY HEAT REMOVAL, UNEXPECTED i 12/8/87- SAFETY INJECTION, SNUBBER FAILURES -

1/19/88 87-34 SPECIALIST 10 SOLIO RADWASTE AND TRANSPORTATION PROGRAMS  !

12/7-11/87 ,

88-01 SPECIALIST 5 RADIATION PROTECTION DURING THE OUTAGE 1/12-15/88 i 88-02 RESIDENT 123 OUTAGE ACTIVITIES, SURVEILLANCE, SECURITY,  !

1/20-2/22/88 QA i

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, Table 1 4 REPORT / TYPE OF DATES INSPEC HOURS DESCRIPTION 88-03 RESIDENT 66 INOPERABILITY OF REQUIRED REACT 00 COOLANT 1/19-29/88 SYSTEM OVERPRESSURE PROTECTION FEATURES 88-04 SPECIALIST 153 ENGINEERING SUPPORT 3/14-18/88 88-05 RESIDENT 132 PLANT UPERATIONS, EQ OF FLOW TRAMSMITTERS, 2/23-4/4/88 OVERTEMPERATURE DELTA-T SPIKING, MAXIMUM REACTOR POWER DETERMINATION, PLAtlT INFOR-MATION REP 0RTS, SECURITY 88-06 SPECIALIST 26 SECURITY INSPECTION 3/28-4/1/88 88-07 SPECIALIST 37 RADIATION PROTECTION ACTIVITIES 4/15/88 88-08 RESIDENT 158 PLANT OPERATIONS, SAFETY SYSTEM OPERABILITY, 4/5-5/23/88 REACTOR VESSEL HEAD SEAL INNEk "0" RING LEAK, MAINTENANCE AND SURVEILLANCE T-1-4

c u (

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TABLE 2: ENFORCEMENT TABLE 2A: ENFORCEMENT ACTION SUMMARY SEVERITY LEVEL AREA 1 2 3 4 5 DEV TOTAL ~

PLANT OPERATIONS 1 2 3

>* RADIOLOGICAL CONTROLS MAINTENANCE SURVEILLANCE EMERGENCY PRE SEC/ SAFEGUARDS 1 1 OUTAGE MANAGEMENT TRAINING EFFECTIVENESS ASSURANCE OF QUALITY

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ENGINEERING SUPPORT (Note 1) 1 1 2 TOTAI.S: 2 3 1 6 TABLE 28: SYNOPSIS OF VIOLATIONS REPT/DATE REQUIREMENT SEVERITY AREA DESCRIPTION 423/87-15 10 CFR 2, 4 ENG FAILURE TO VERIFY ADEQUACY OF 6/8-25/87 APPENDIX C SUPPORT BATTERY ROOM V' DESIGN 423/87-15 10 CFR 2, D ENG DEVIATION OF MASOURY WALLS FROM 6/8-25/87 APPENDIX C SUPPORT FROM APPENDIX A 0F STANDAR0 RE-VIEW PLAN SECTION 3. /87-18 SECURITY 3 SEC/ INADEQUATE BARRIERS, VISITORS 8/31-9/9/87 PLAN SFGDS WITHOUT ESCORT, IMPROPER COM-PF.NSATORY MEASURES L 423/88-02 TS 3. OPS CHANGED MODES WITH ONE CHARGING

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1/20-2/2/88 PUMP INOPERABLE 423/88-03 TS 3. OPS LTOP INOPERABLc DURING OVERPRES-1/19-29/88 SURE EVENT WHILE SHUTDOWN 423/88-04 10 CFR (NOTE 1) ENG ENVIRONMENTAL QUALIFICATION OF 3/14-18/88 50.49 $UPPORT LITTON-VEAM CONNECTORS 423/88-05 TS 6. OPS AFV PUMP SUCTION VALVE NOT LOCKED 2/23-4/4/88 Note 1: Potential enfe-cement actions are pendin .

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~

T-2-1 l

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TABLE 3 SUMMARY OF LICENSEE EVENT REPORTS (LERsl MILLSTONE _3 CAUSE CODES AREA A B C D E X TOTAL PLANT OPERATIONS 11 3 2 4 20 RADIOLOGICAL CONTROLS MAINTENANCE 1 2 3 SURVEILLANCE 13 6 19 EMERGENCY PRE SEC/ SAFEGUARDS OUTAGE KANAGEMENT 1 1 1 3 TRAINING EFFECTIVENESS ASSURANCE OF QUALITY 1 1 4 6 ENGINEERING SUPPORT 2 3 3 8 TOTALS: 28 8 10 13 59 CAUSE CODES A -- PERSONNEL ERROR 8 -- DESIGN, MANUFACTURING, CONSTRUCTION / INSTALLATION C -- EXTERNAL CAUSE D -- DEFECTIVE PROCEDURE E -- E0VIPMENT FAILURE X -- OTHER T-3-1

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

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TABLE 3A SYNOPSISOFLICENSEEEVENTREPORTS(LERs)

MILLSTONE 3

_ER EVENT CAUSE FCT NUMBER DATE CODE AREA DESCRIPTION 87-008-00 3/7/87 E 1 REACTOR TRIP OUE TO LOW LOW STEAM GENERATOR LEVEL CAUSE0 BY FAILED SOLEN 0ID VALVE 87-009-01 3/11/87 E 9 EARLY LIFTING OF PRESbURIZER SAFETIES FOR UNDETERMINED REASONS 87-010-01 2/22/87 B 1 LOOSE PART DETECTION SYSTEM INOPERABLE CHANNEL FOR UNKNOWN REASONS 87-011-00 3/19/87 0 4 4.16KV EMERGENCY GUS TRIP SETPOINTS LOW L'UE TO SETPOINT ORIFT 87-012-00 3/20/87 A 4 MISSED TECHNICAL SPECIFICATION SURVEILLANCE ON SNUBBER VISUAL INSPECTIONS OVE TO ENGI-NEERING OVERSIGHT 87-013-00 3/21/87 A 10 MISSING CONTAINMENT PENETRATION SECONDARY PROTECTION OVE TO PERSONNEL ERROR 87-014-00 3/22/87 E 3 FAILURE OF "B" EMERGENCY DIESEL GENERATOR TO START IN LESS THAN 10 SECON05 87-015-00 3/24/87 0 1 INABILITY OF MAIN STEAM ISOLATION VALVES TO CLOSE IN REQUIRED TIME FRAME 87-016-00 3/25/87 0 4 TRAIN A SAFETY INJECTION CAUSE0 BY INSTRU-NENT TECHNICIAN DUE TO DEFECTIVE PROCEDURE

87-017-00 3/29/87 B 10 FAILURE TO ADEQUATELY DETERMINE / MEASURE I

RESPONSE TIMES i

87-018-00 4/2/87 A 4 OPERATION WITH INOPERABLE CONTROL BUILDING I RADIATION MONITOR DUE TO PERSONNEL ERROR 87-019-00 4/11/87 8 10 AREA TEMPERATURE MONITORING-ES07 l

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87-020-00 4/12/87 E 3 REACTOR TRIP OUE TO LOW LOW STEAM GENERATOR LEVEL CAUSED BY AIR LEAK TO FEEDWATER REGULATING VALVE T-3A-1

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LER EVENT CAUSE FCT NUMBER DATE CODE AREA , DESCRIPTION 87-021-00 4/12/87 A 1 FEEDWATER ISOLATION AND REACTOR TRIP DUE

TO STEM GENERATOR WATER LEVEL TRANSIENT P.AUSED BY OPERATOR ERROR

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87-022-00 4/15/87 8 10 INACCURATE STEAM GENERATOR WATER LEVEL INDICATION DUE TO SYSTEM DESIGN 87-023-01 4/25/87 E 10 AREA TEMPERATURE MONITORING CS01 87-024-00 5/6/87 0 4 "B" 1 RAIN EMERGENCY DIESEL GENERATOR-TRIP /

FAILURE TO START IN LESS THAN 10 SECONDS

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37-025-00 5/7/87 D 1 REACTOR TRIP DUE TO LOW LOW STEAM GENERATOR LEVEL CAUSED BY PROCEDURE INADEQUACY 87-026-00 5/14/87 A 4 REACTOR TRIP FROM B REACTOR TRIP BREAKER

OPENING DUE TO UNKNOWN (SPURIOUS) CAUSES

87-027-00 6/5/87 A 1 REACTOR TRIP DUE TO LOSS OF VITAL BUS CAUSED BY PERSONNEL ERROR 87-028-00 6/6/87 E 1 CONTROL BUILDING ISOLATION SIGNAL DUE TO

CHLORINE DETECTOR FAILURE 87-029-00 6/7/87 A 1 FAILURE TO POST FIRE WATCHES DUE TO OPERA-

TOR ERROR 87-030-00 6/8/87 A 1 INADVERTENT MODE CHANGE FROM COLD SHUTDOWN TO HOT SHUTDOWN DUE TO OPERATOR ERROR 87-031-01 6/14/87 E 9 REACTOR TRIP DUE TO TURBINE TRIP ON LOW LUBE OIL HEADER PRESSURE

! 87-032-00 7/6/87 0 4 INADVERTENT DISCHARGE OF CO2 DUE TO PRO-e CEDUML DEFECT 87-033-00 8/14/87 A 4 REFUELING WATER STORAGE TAhK LEVEL BELOW

PLANT TS DUE TO INCORRECT LEVEL TRANSMIT-TERS CALIBRATION AND PERSONNEL ERROR 87-034-00 9/23/87 E 10 REACTOR TRIP DUE TO LOW LOW STEAM GENERATOR LEVEL CAUSED BY FAILED SOLENOID VALVE 87-035-00 10/16/87 D 4 SURVEILLANCE TEST METHOD NOT IN ACCORDANCE WITH TECHNICAL SPECIFICATIONS I

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l o Table 3A LER EVENT CAUSE FCi NUMBER DATE CODE AREA DESCRIPTION 87-006-00 10/31/87 E 10 SETPOINT ORIFT ON MAIN STEAM SAFETY VALVES87-037 00 11/1/87 A 1 FEE 0 WATER ISOLATION DUE TO HIGH STEAM

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GENERATOR LEVEL CAUSED BY OP.co.ATOR ERROR 87-038-00 11/10/87 A 7 PERSONAL ERROR WHEN JANITOR STRUCK BREAKER ENCLOSURE WITH BROOM WHILE CLEAN!NG AND TRIPPED BREAKER 87-039-00 11/11/87 A 4 FAILURE TO SAMPLE EMERGENCY DIESEL GENERA-TOR FUEL OIL TANKS FOR PARTICULATE l 87-040-00 11/9/87 A 4 FIRE PROTECTION SURVEILLANCE PERFORMED LATE DUE TO HUMAN ERROR 87-041-00 11/16/87 A 4 INADEQUATE TESTING OF CONTAINMENT PENETRA-TION CIRCUIT BREAKERS 87-042-00 11/17/87 0 4 MISSED INTERMEDIATE RANGE / POWER RANGE SUR-VEILLANCE DUE TO PROCEDURAL INADEQUACY 87-043-00 11/18/87 E 9 BYPASS LEAKAGE IN EXCESS OF TECHNICAL SPECIFICATION LIMITS 87-044-00 11/20/87 A 4 VENTILATION RADIATION MONITOR SURVEILLANCE PERFORME0 LATE l 87-045-00 11/21/87 A 4 FAILURE TO SAMPLE DIESEL FUEL OIL FOR I

KINEMATIC VISCOSITY PRIOR TO ADDITION TO STORAGE TANKS l 87-046-00 11/24/87 A 4 SAMPLE RIG ACTION STATEMENT SURVEILLANCE MISSED 87-047-00 11/30/87 0 7 CORE ALTERATION PERFORMED WITHOUT PROPER COMMUNICATIONS OR SRO COVERAGE DUE TO PROCEDURAL ERROR 87-048-00 12/3/87 A 1 FAILURE TO MONITOR INOPERABLE FIRE ASSEMBLIES I

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87-049-00 12/16/87 A 1 MISSED ENGINEERING EVALUATION DUE TO MIS-INTERPRETATION OF TECHNICAL SPECIFICATIONS 87-050-00 12/21/87 A 4 MISSED AREA TEMPERATURE MONITORING SUR-VE!LLANCE 00E TO PERSONNEL ERROR T-3A-3

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,, Table 3A  !

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l LER EVENT CAUSE FCT  ;

NUMBER DATE CODE AREA DESCRIPTION [

L 87-051-00 12/29/87 A 4 MISSED SURVEILLANCE ON FIRE RATED DOORS i DUE TO PROCEDURAL DEFECT  !

i 88-001-00 1/5/88 8 1 INADVERTENT SAFETY INJECTION DUE TO SENSI- !

TIVE EQUIPMENT I

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88-002-00- 1/13/88 B 9 INSUFFICIENT SEISMIC SUPPORT OF REACTOR !

i COOLANT PUMP OIL COLLECTION SYSTEM i 88-003-00 1/16/88 8 1 DIESEL SEQUENCED START DUE TO SPURIOUS

' RELAY ACTUATION v i

88-004-00 1/18/88 E 1 CONTROL BUILDING ISOLATIOfl SIGNAL DUE TO i

! CHLORINE DETECTOR FAILURE  !

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88-005-00 1/19/88 A 1 COLD OVERPRESSURE PROTECTION SYSTEM FAILS '

TO OPERATE DURING PRESSURE TRANSIENT !

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88 006-00 1/30/88 A 1 VIOLATION OF TECHNICAL SPECIFICATION-MODE

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CHANGE WITHOUT REQUIRED ECCS EQUIPMENT !

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l 88-007-00 2/3/88 E 1 MANUAL REACTOR TRIP DUE TO INOPERABLE DIGITAL ROD POSITION INDICATOR 88-008-00 2/8/88 A 9 FIRE DETECTION ZONES IMPROPERLY WIRED DURING CONSTRUCTION

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88-009-00 2/10/88 A 1 REACTOR TRIP AND FEEDWATER ISOLATION DUE !

TO STEAM GENERATOR LEVEL TRANSIENT l t

88-010-00 2/9/88 B 7 IMPROPER NUCLEAR INSTRUMENT CALIBRATION

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l DUE TO LOW LEAKAGE CORE f

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88-011-00 2/22/88 A 4 NISSED CONTAINMENT LEAKAGE DETECTION SYSTEM i SURVEILLANCE $ DUE TO DEFECTIVE PROCEDURE DUE TO PERSONNEL ERROR 88-012-00 3/18/88 0 3 FA! LURE TO MONITOR AN INOPERABLE FIRE BOUNDARY 000R 88-013-00 3/28/88 A 10 INCOMPLETE INSTALLATION OF DAMPER CIRCUIT IN THE HYOR0 GEN RECOMBINER SYSTEM 88-014-00 4/13/88 E 9 REACTOR TRIP DUE TO TURBINE TRIP DUE TO LOW CONOENSER VACUUM 88-015-00 4/15/88 A 1 UNUSUAL EVENT TERttINATED W/0 A QUANTITATIVE ASSESSMENT OF THE LEAK RATE T-3A-4

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l'A8'.E _ 4 SUMMARY OF FORCED OUTAGES, UNPLAk.'NED TRIPS, AND POWER REDUCTIONS MILLSTONE 3 AREA A a C 0 g X TOTAL PLANT OPERA 110NS 3 1 4 RADIOLOGICAL CONTROLS MAINTENANCE 1 1 SURVEILLANCE EMERGENCY PREP SEC/ SAFEGUARDS OUTAGE MANAGEN.cNT 1 1 TRAINING INAC4GsACY ASSURANCE 'n cdALITY ENGINEERIi.o SUPPORT 2 2 4 >

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TOTALS: 3 2 1 3 1 10 CAUSE CODES A -- PERSONNEL ERROR ,

B -- dei!GN, MANUFACTURING, CONSTRUCTION / INSTALLATION  !

C -- EXTERNAL CAUSE D -- DEFECTIVE PROCEDURE E -- EQUIPMENT FAILURE i X -- OTHER t l

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FORCED OUTAGES, UNPLANNED TRIPS, AND POWER REDUCTIONS MILLSTONE 3 POWER LER- CAUSE AND AREA DATE LEVEL DESCRIPTION NUMBER (NOTES 1, 2, 3, 4).

3/2/87 100% POWER REOUCTION TO RE- --

EQUIPMENT FAILURE SEAL ,

PLACE FAILED PUMP SEAL DEGRADATION (N0 AREA IN MOTOR-DRIVEN MAIN ASSIGNED)

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FEED WATER PUMP (MDFWP)

3/7/87 100% REACT 0P. TRIP FROM "D" 87-08 EQUIPMENT FAILURE - FAULTY SG LOW-LOW LEVEL CAUSED SOLEN 0ID ON FWI VALVE 'i BY FWI WHEN fHE FWI (ENGINEERING SUPPORT)

VALVE SOLEN 0ID OPEN CIRCUITED 4/12/87' 66% REACTOR TRIP ON "D" SG 67-20 EQUIPMENT FAILURE - AIR LOW-LOW LEVEL CAUSED BY LEAK FROM SUPPLY LINE AIR LEAK ON "D" FRV CON- LINE FITTING ON "D" FRV TROLLER FRV (0UTAGE MGMT)

4/12/87 '15% REACTOR TRIP DURING 87-21 PERSONNEL ERROR - INADE-STARTUP DUE TO INADE- CONTROL OF MDFWP AND FRVS QUATE CONTROL OF THE (OPERATIONS)

FEEDWA?SR SYSTEM 5/7/87 44% REACTOR TRIO ON "C" SG 87-25 OROCEDURE INADEQUACY - PRO-LOW-LOW LEVEL DUE TO CEDURE DID NOT DESCRIBE TRIPPING MDFP IN SG POWER LIMITATIONS WITH LEVEL OSCILLATION PEGION EXISTING SG OSCILLATIONS (OPERATIONS)

5/11/87 100% POWER REDUCTION DUE TO --

INADEQUATE DESIGN SEAL RECUFRING FEEDWATER PUMP DEGRADATION (ENGINEERING SEA. PROBLEM SUPPORT)

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5/14/87 69% REACTOR TRIP DUE TO AP- 87-26 NO CAU$E - DISCOVERED AFTER PARENT SPURIOUS TRIP DETAILED INVESTIGATION PING OF "B" REACTOR TRIP (N0 AREA ASSIGNED)

BREAKER WHILE PERFORMING A SURVEILLANCE ON THE

"A" REACTOR TRIP BREAKER

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-Table 4A

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POWER LER CAUSE AND AREA DATE LEVEL DESCRIPTION NUMBER [ NOTES 1,2,3,4)

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6/5/87 100% REACTOR TRIP ON LOW LOW 87-27 PERSONNEL ERROR - OPERATOR SG LEVEL DUE TO LOSS OF DROPPED RACKING MOTOR HELD

• s EMERGENCY BUS 34C IN HAND AGAINST ADJACENT L 34C BREAKER ENCLOSURE TO INITIATETRIP(OPERATIONS)

6/14/87 100% REACTOR TRIP DUE TO TUR- 87-31 IMPROPER DESIGN - TGOP IM-BINE TRIP FROM LOW LOW PELLER OVERSIZED (ENGINEER-PRESSURE AFTER STOPPING ING SUPPORT)

TGOP 9/23/87 100% REACTOR TRIP DUE TO LOW 87-34 FAULTY SOLEN 0ID ON FWI VALVE 4 LOW LOW LEVEL IN "A" SG (ENGINEERINGSUPPORT)

CAUSED BY FWI VALVE CLOSING 2/3/88 0% MANUAL REACTOR TRIP 88-07 EQUIPMENT FAILURE - DRPI DURING PHYSICS TESTING CARD BOWED, INDICATED R00 ROD WITHDRAWAL DUE TO SIMULTANEOUSLY FULL AND MID DRPI DUAL INDICATION CORE (N0 AREA ASSIGNED)

2/10/88 20% REACTOR TRIP DUE TO LOW 88-09 PERSONNEL ERROR -INABILITY LOW LEVEL IN "B" SG 0F OPERATOR TO CONTROL AlL tCAUSED BY INADEQUATE FEED REG VALVES (OPERATIONS)

CONTROL OF FEED REG VALVES 4/13/88 100% REACTOR / TURBINE TRIP 88-14 OTHER - SEAWEED IMPINGEMENT CAUSED BY LOSS OF 2 CW ON INTAKE SCREENS BEYOND

. PUMPS OUE TO SEAWEED CAPACITY OF SCREENWASH

' IMPINGEMENT ON INTAKC (SCREENWASH SYSTEM ORIGIN-SCREENS ALLY OPERATING AT REDUCED CAPACITY)(MAINTENANCE)

4/28/88 70% POWER REPUCTION TO RE- INADEQUATE INETALLATION -

PAIR STEAM LEAK ON DRAIN INADEQUATE WELD ON DRAIN PIPING ' PIPING (N0 AREA ASSIGNED)

Note 1: Isolated cases of equipment malfunctioning and component failure (not directly attributable to functional area). Multiple causally linked failures are assigned to the area that should have prevented the recurrenc Note 2: Cause and erea assigned was the result of independent NRC review of the events and may not agree with the licensee's identified root caus Note 3t Cause equals root cause and is that single element, if removed, that would not have allowed the event to happe Nott 'i: Cause and Area Codes were assigned by NRC Region T-4A-2

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' ENCLOSURE 2, u

,'= [ UNITE 3 8TATES NUCLEAR REGULATORY COMMISSION

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,'e j REGION 1 o e 475 ALLENoALE ROAD '

KING oF PRUS$1A.PENNSYl.VANIA 19408 * . .s Docket / License: 50-423/NPF-49 JUL 2 51988 pid r

Northeast Nuclear Energy Company b j; ATTN: Mr. Edriard J. Mroczka "e Senior Vice President, Nuclear b, '

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Engineering and Operations P.O. Box 270 Hartford, Connecticut 05101-0270 Gentlemen:

Subject: Millstone Unit 3 Systematic Assessment of Licensee Performance (SALP)

Report 50-423/87-99 (3/1/87 - 5/31/88)

On July 12, 1988, the NRC Region I SALP Board assessed the performance of Millstone Nuclear Station Unit 3. That assessment is documented in the enclosed SALP Board Report. A meeting has been scheduled for August 16, 1988 at 1:30 p.m. at the Millstone Training Center to discuss the SALP. The meeting is intended to provide a forum for candid discussion of unit performanc At the meeting, please be prepared to discuss the SALP and your plans to foster activities that have a positive effect upon performance. Any comments you may have regarding our report may be discussed. In addition, you may provide written com-ments within 30 days after the meetin Af ter we receive and evaluate your comments, the SALP report and your written com-ments will be placed in the NRC Public Documer.t Roo Thank you for your cooperatio

Sincerely,

.

William T. Russell Regional Administrator Enclosure: NRC Region I SALP Report 56-423/87-99

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Northeast Nuclear Energy Company: 2 JUL 85 NNS-

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cc w/ encl:

W. D. Romberg, Vice President, Nuclear. Operations S. E. Scace, Station Superintendent 0. O. Nordquist, Manager, Quality Assurance R. M. Kacich, Manager, Generation Facilities Lic. -(ng Gerald Garfield, Esquire Chairman Zech Commissioner Roberts Commissioner Carr Commissioner Rogers K. Abraham, AI (14 copies)

Public Document Room (PDR)

local Public Document Room (LPDR) .

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Nuclear Safety Information Cen'.er (NSIC)

NRC Senior Resident Inspector State of Connecticut

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ENCLOTURE 3 NRC/ NORTHEAST NUCLEAR ENERGY COMPANY MANAGEMENT AcETING SEPTEMBER 1, 1988 NAME TIT!E NRC, Region I J

' William F. Kane Director, Division of Reactor Projects (DRP)

Lee H. Bettenhausen Chief, Projects Branch No.1, DRP Ebe C. McCabe Chief, Reactor Projects Section 18, DRP William J. Raymond Senior Resident Inspector, Millstone Station G. Scott Barber Resident Inspector, Millstone 3 ~

Steve T. Bart Reactor Engineer, Reactor Projects Section 18, DRP NRC, Nuclear Reactor Regulation (NRR)

John F. Stolz Project Directorate David H. J&ffe Project Manager Northeast Nuclear Encrgy Company - Corporate

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William B. Ellis Chairman and Chief Executive Officer

- Bernard M. Fox President,' Northeast Utilities John F. Opeka Executive Vice President - Engineering and Operations Edward J. Mroczka Senior Vice President - Nuclear Engineering and Operations Wayne D. Romberg Vice President - Nuclear Operations C.-Frederick Sears Vice President - Nuclear and Environmental Engineering Donald O. Nordouitt Director, Quality Services

- G. Leonard Johnson Director, Generation Engineering Robert T.-Harris Director, Nuclear Engineering Richard M. Kacich Manager, Generation Facilities Licensing Richard Gallagher Senior New Representative Millstone Site Carl Clement Superintendent, Millstone 3 Harry F. Haynes Station Services Superintendent Haddam Neck Plant Ert'. Debarba Station Services ".aperinter. 2nt

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. ENCLOSURE 4

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3 NORTHEAST UTIUTIES o.n.,.. On,c . s.m.n sir 8.,on Connmeui 9 22.EIN*cU~~

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P.O BOX 270 HARTFOA D. CONNECTICUT 061410270

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L ' J 5:C :0 0 0.'.'."~ ~ mn) ses-sooo September 30, 1988 Docket No. 50-423 A07395 Re: SALP U.S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 Systematic Assessment of Licensee Performance (SALM The NRC Staff recently forwarded the SALP Board ReportII) for the 15-month period ending May 31, 1988 for Millstone Unit No. 3. Subsequent to receipt of the SALP Board Report, a meeting was held on September 1, 1988 between members of the Staff and members of Northeast Nuclear Energy Cowany (NNECO).

We believe that our meeting on September 1,1968 was helpful and productiv Consistent with our discussion during the meeting, we are responding to the findings of th2 SALP Board with particular emphasis on the Board recomendations for the individual evaluation categories. The responses to the Board's recomendations for Hillstone Unit No. 3 are contained in Attachment A to this lette NNECO takes very ;eriously the ratings and recommendations given by the Board as an input into the continuing process of evaluating and improving our overall performance. As reflected by our comrients and observations during the September 1, 1988 meeting, we generally concur with the Boards observations and previously have taken tnd are taking steps to address the concerns identified. It remains our objective to achieve Category I ratings in all ionctional areas for subsequent SALP evaluations, and the attachment to this letter describes some of the steps we will be taking to fulfill that objective, i

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l (1) T. Russell letter to E. J. Mroczka, "Hillstone Unit 3 Systematic j '

Assessment of Licensee Performance (SALP) Report 50 423/87 99 l (3/1/87 5/31/88)," dated July 25, 1988.

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U.S. Nuclear Regulatory Commission

. A07395/Page 2 September 30, 1988 '

We trust that the actions presented in the attachment addressing the concerns of the bot 4 and our general comments will be considered in subsement SALP evaluations. We will be updating you regarding the status of implementing the corrective actions discussed herein pr'or to the next SALP evaluation. w'ith respect to the survaillance functional area, NNEC0 believes that a meeting with the Staff in March of 1989Jto discuss our efforts and prcgress in the area of surveillance monitoring would be timely. This time period will allow completion of the corrective actions identified during the procedure review and is sufficiently in advance of the start of the Cycle 2 refueling to allow NNECO and the Staff to assess the adequacy of our corrective action in this are We will be contacting you regarding a specific date and proposed agenda for this w:eting early in 198 Please feel free it, contact us if any questions arise on these matters or if additional clarification is neede Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

$ U. D se E. J. Mroczka "

Senior Vice President

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EL-By: C. F. Sears Vice President cc: W. T. Russell, Region ! Administrator D. H. Jaffe, NRC Project Manaca , Millstote Unit Nos. 2 and 3 W. J. Raymond, Senior Res', der <1spector, Millstone Unit Nos. 1, 2 and 3

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Docket No. 50-423'

A01395

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Attachment A Wortheast Nuclear Energy Company Millstone Unit No. 3 Response to SALP Report

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September 1988

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functional Area: PLANT OPERATIONS Board Recomendation:

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Accelerate correction of radiation monitor spiking proble .

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Identify and correct procedure problems based on safety significanc Evaluate operations support staffing levels estaolished to cope with frequent procedure changes and with surveillance-related administrative problem .

Supmuis: .

NNECO acknowledges that improvements could be made to reduce annunciator alarms due to radiation monitor spiking. A program has been underway during the past year to deal with the number of radiation nonitor spiking alarms. A procedure has been developed to permit the operators to directly ir.put alarm setpoint changes on radiation monitors to stop the continuous change of alarm state that resulted in missing an incoming alarm as mentioned in the evaluatio In addition, setpoint studies are ongoing and sp'!cial test equipment has been installed to identify the cause of the spurious control room radiation monitor alarms. Ongoing efforts will result in a significant improvement in the numbers of alarms received due to radiation monitor spikin The SALP report also cited the number of annunciator windows in an alarm state during power operation. About 35 annunciators (of 900 total) are still lit at power. Several of these annunciators are illuminated as a nonnal consequence of system alignment and require design modifications to achieve a black board Of the remaining annunciators, 18 require engineering configuratig resolution, 10 need special plant conditions to repair equipment, and the remaigg 7 alarms are short term. Significant progress has been made on this issue and NNEC0 remains comitted to eliminating unnecessary annunciators by the end of the Cycle 3 refueling outag '

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The large number of procedure changes, mostly minor in safety significance, were noted as a reflection of a diligent effort to incorporate lessons learned during the first operating cycle. Processing these procedure changes placed a burden on operations administrative staf Additional resources of two dedicated SRO level staff members have been assigned to the operations department since last July to cope with that burden. With the completion of the first operating cycle, all procedures have now been exercised. The number of changes being implemented this cycle are expected to be significantly reduced. There are 1400 procedures on Millstone Unit No. 3. As a result of the experience gained to date, changes have slowed to approximately 50 por l (1) E. J. Mroczka letter to U.S. NRC, "Elimination of Unnecessary Annunciator Windows," dated April 5, 1988.

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Attachment A

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month from a previous range of 80 to 100 changes per mont Additiont11y,

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procedure changes on Millstone Unit No. 3 are entered directly into the procedure affected. Extensive changes often result in page substitution to avoid problems encountered with just filing the change at the beginning of the precedure. This action goes beyond the station administrative requirement and eliminates the confusion that can be generated by multiple changes. The current program for procedure updates is effective in our view and the number of procedures with greater than 3 changes since the last revision has been reduced from 47 in July 1988 to 35 in August 1988. It should be noted that procedures ' ith potential

., safety impacts are given high priorit Programmatic root causes of procedural problems are promptly pursued. An example of this commitment to addressing root cause concerns was the review of all general operating procedures for instances where systems were placed in service without a specific system procedure (a contributing cause to a recent cold over pressure event). A formal review program of all surveillance procedures is underway to review the contents and frequency against the technical specification requiremen The report cited 11 automatic trips during the last SALP period. This rate was about average for a n a plant. Significant progress continues on reducing the number of trips. This progress has been brought about by identifying and correcting the root causes of the plant trips. Equipment improvements include changes to the turning gear oil pump, change out of the steam generator condensate pots, and total replacement of the energized feedwatar isolation valve solenoids. Trip analysis for both Millstone Unit No. 3 and industry experience is used to correct problems- Training on lessons learned, procedure refinements and constant attention to detail are expected to continue to reduce the number of plant trips as the plant matures. The trip rate per thousand hours of operation demonstrates the effectiveness of the actions taken to date. The trip rate per thousand hours of operation for the SALP period covered in Cycle I was 2.28 compared with a trip rate par thousand hours of operation of .86 for Cycle No trips have occurred since the completion of the SALP period in 2700 hours0.0313 days <br />0.75 hours <br />0.00446 weeks <br />0.00103 months <br /> of operation.

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Attachment A

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Functional Area: RADIOLOGICAL CONTROLS

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Board Recommendation: Non Response:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for improvement, and will continue to strive for better performanc NNECO continues to aggressively pursue exposure reductio While previous goals did not appear to be challenging in light of the excellent exposure records of 357 man rem, performance shows that extensive efforts were made to keep exposure low. In 1987, the exposure goal was 447 man-res and exposure was kept to 357 man-rera (including unplanned RCP repairs). The goal for 1988 is 90 man-rem (the cumulative man-rem is 84.5 as of September 26,1988). The goal for 1989 has been reduced to 381 man-rem based on using actual exposure history for repetitive tasks and estimates for additional planned refueling activities. The 1989 goal uses 2.5 man-res per month for non-outage period Again, we are committed to holding exposure below these goals when possible.

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Attachment A A07395/Page 4 e

Functional Area:

'. MAINTENANCE Board Recommendation: Non Reap ,g:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for improvement, and will continue to strive for better performance. We also plan co continue our active involvement in the Staff's contemplated rulemaking activities in the maintenance area.

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• Attachment A

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A07395/Page 5 e

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Functional Area: SURVEILLANCE Board Recommendation:

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Reduce the number of inaccurate, late and missed surveillance Schedule a meeting with the NRC early in 1989 to discuss effectiveness of surveillance program corrective action Resoonse:

NNECO is in the process of corducting a complete review of all surveillance procedure contents and frequency against technical specification requirement Every effort is being made to raise the level of awareness on the need for accurate tracking and completion of all required surveillances. Millstone Unit No. 3 Technical Specifications have approximately 1050 line items requiring surveillances and specifies 138,700 required scheduled surveillance items during a refueling cycle in addition to situational required surveillances. One hundred thirty one thousand (131,000) of the surveillance activities are daily or shiftly activities with 7700 activities being activicies scheduled weekly or less frequentl About one half of the 16 probitms with surveillances dealt with procedural defects or first time perfo mance which are being addressed by our surveillance procedure review as noteG abov The largest single group of remaining problems contributing to missed or late surveillances (5) come from situational requirements and in most cases consisted of exceeding the time interval for performance by less than a da Increased directions have been given to plant operations on control of situational surveillances. These directions include preparing all required surveillance forms prior to shift turnove As previously stated, NNECO plans to schedule a meeting with the NRC Staff to discuss the progress made in implementing the corrective actions underway in the area of surveillance monitoring.

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Attachment A A07395/Page 6

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Functional Area: EMERGENCY PREPAREDNESS

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Board Recommendation: Non Response:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for improvenent, and will continue to strive for better performanc At the SALP meeting on September 1,1988, the NRC Staff (Mr. Kane) raised a question regarding Emergency Action levals (EAls) and their guidance for a loss of annunciator event. The following information is provided in response to that questio The Incident Classification Scheme has built-in prescribed protective actions for the public that state and local officials can initiat The control room Shift Supervisor (and eventually the on-call Director of the Station Emergency Operations) has tha responsibility of classifying the event based on EAL The EAls are symptoms or conditions of plant status that have been precategorized into appropriate incident classification. The EALs have been written so that even potential equipment damage is classified. For a loss of all alarm annunciators for greater than 15 minutes, an ALIBI is classifie If the duration of the loss is less than 15 minutes, then no EAL is invoke This approach is identical for all four NU nuclear units.

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Attachment A A17395/Page 7 a-

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Eynctional Area: SECURITY AND SAFEGUARDS Board Recommendation: Non .

Resoonse:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowl6dge the need to address the issues identified as having room for improvement, and will continue to strive for better performanc i

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A07395/Page 8

, Functional Area: OUTAGE MANAGENENT Board Recommendation: Non Response:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for improvement, and will continue to strive for better perfomanc ,

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Attachment A A07395/Page 9 d,

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f_unctional Area: ENGINEERING SUPPORT Board Recommendation:

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Improve knowledge level of personnel implementing the EQ progra Ensure high level management attention is given to resolving EQ issue Response:

The SALP report addresses the one EQ inspection during the assessment period and characterized the inspection as having identified "multiple apparent violations". Four potential violations that were identified as a resugof the inspection have been reduced to two as a result of further diseassion . ,

In the exit meeting for the EQ inspection, responses to audit questions were said to be slow. The inspector attributed this to manpower. General support was never identified to be only marginally acceptable during the coursa of the inspection or at the exit meeting, and there were no coments critical of the experience levels of the EQ staff supporting the inspectio Management involvement is integrated into the resolution of EQ issues at an early stage, and this involvement was noted by the inspection team. NNECO believes that we

, have a knowledgeable and highly experienced EQ staff implementing the EQ Program, lhis is evidenced by our prompt and extensive corrective actions taken to resolve the Litton-Veam connector issue.

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Another area which we believe warrants clarification is the knowledge level of personnel implementing the EQ Progra Although NNECO use of :ontract personnel was decreasing, the core EQ staff was supplemented during the inspection period with NNECO electrical, control and instrumentation engineers normally assigned to plant support activities not specifically related to E These engineers were quite experienced in their disciplines and were selected to support the inspection well in advance of the arrival of the inspection team.

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NNECO intends to ensure that a high level of management attention to strengthening EQ staffing levels and to other EQ issues continues.

l The SALP report cited that Corporate Engineering's late reporting of the Rosemount flow transmitter repetitive failure problem unnecessarily delayed report dissemination to other Rosemount users. In response to this concern, the Corporate NE0 Procedure dealing with implementation of 10CFR21, "Reporting of Defects end Noncompliance" is being revised to clarify substantial safety hazards dete.w nations related to repetitive component failure ,

i (2) V. Johnston letter to E. J. Mroczka, "EQ Inspection Report No. 50 423/88 04," dated August 24, 198 ,

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Attachment A '

A07395/Page 10

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Functional Area: LICENSING ALTIVITIES Board Recommendation:

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Continue the effort to assure accurate submittal Resoonse:

During the past year, NNECO has strived to be very responsive to NRC Staff requests for informatio We have endeavored to provide comprehensive, accu. ate and technically sound submittals. We believe a prime example of this has been our pursuit of NRC approval of three-loop operation. In addition, NNECO has provided information required to :atisfy five (5) license conditions and seven (7) Safaty Evaluation Report commitment items requiring submittal for additional informatio As of October 1987, office space has been designated at the Millstone Site for use by Licensing personnel to facilitate increased focus on plant activities and improve the interface between the plant and Generation Facilities Licensing on licensing related issues. It is intended that this action will further improve the quality and timeliness of licensee responses and increase the frequency of pronipt, personal communications with station personne Regarding day-to day licendng activities, our licensing staff works closely with the NRC Project Manager. Our belief is that our licensing and management personnel enjoy a very productive working relationship with the NRC. There is very good daily communication between the NRC and NU Licensing Staff with frequent "face to face" meetings to maintain clear communications and reach agreement on outstanding information requests and other licensing issue In summary, we have continually strived to provide comprehensive, thorough and technically sound submittals. In cases where the NRC Staff has required additional informattun, we h:ve been quick to respond to the request with follow up telephone conference calls, meetings or additional written submittals. Lastly, we will continue to place emphasis on the multidiscipline sign off process associated with all correspondence with the NRC to ensure accuracy of submittal i

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, Functional Area: TRAINING AND QUALIFICATION EFFECTIVENESS

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Board Recommendation: Non Responut:

NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for improvement, and will continue to strive for better performanc NNE00 proposes to clarify a statement in the second paragraph on page 30 of the SALP report regarding the experienced training staff as follows:

"The licensee developed an experienced training staff with sixteen instructors, three quarters of whm maintained operating licenses. To support the accreditation efforts, che training staff was augmented using contractors to over 20 instructors."

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,' Functio.nal Area: ASSURANCE OF QUALITY P

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Resolve the procedure change backlog problem.

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Specific actions concerning the large number of procedure changes were previously discussed under the functional area of plant operations.

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