ML19327A803
| ML19327A803 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 10/06/1989 |
| From: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| B-13365, NUDOCS 8910180147 | |
| Download: ML19327A803 (11) | |
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General Offices
- Selderi Street, Nrlin, Connecticut -
ARTFORD, CONNECTICUT 06141-0270 k
L IJ EE,"","U,"$"g (203) 665-5000 4
October 6, 1989 4
Docket No. 50-213 50-245 4
g.335
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50-423 BlM51 Re:
Inspections
_U.S. Nuclew Regulatory Commission Attention: Document Control Desk l
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. Washington, DC 20555-Gentlemeni Haddam Neck Plant L
Millstone Nuclear Power Station, Unit Nos.1, 2, and 3 Imoact of Insoections and Special Meetinas J
This letter. is being submitted by Connecticut Yankee Atomic Power Company and L
Northeast Nuclear. Energy-Company to provide information and to convey some J
. observations regarding the nature and frequency of the many inspections, meetings, and visits'to our facilities.
While the NRC clearly is the organi-
!zation which visits our -facilities most frequently, other organizations
-involved include INPO, NUMARC, ANI, and other entities,. such as foreign
- delegations. One of the purposes of submitting this letter is to potentially
_ heighten your awareness of the frequency and natbre of these visits, so that the scheduling of future inspections may be performed with this broader l
perspective in mind.
These activities 'are gradually irreasing in number and duration at the sites and-.in the corporate headquarters.
Many aspects of. these activities are constructive _or rewarding as they_ provide-valuable feedback from broad exper-ience bases within the industry, useful recommendations, and opportunities for in-depth assess.nent.
Conversely, the frequency and scope of these activities
-has raised s mie questions as tc the efficient allocation of resources, the ability to optimally focus on the priority safety issues, and the ability to most effectively manage and safely operate the plants. One reason for this is
.the fact that most inspections or visits involve considerable management time and attention.
The routine inspections'that are performed mostly by the NRC Resident Inspec-tors :are mutually beneficial.
The day-to-day interface between these inspec-
_ tors and plant management provides continuous, open communication on virtually all of the important regulatory issues.
In addition to these routine inspec-tions, there are a number of major inspections.
Attachments 1 and 2 identify the major inspections and meetings at the Haddr, Neck Plant and the Millstone Station, re:,pectively, over a typical four-month period, (mid-May thru mid-September 1989).
In each casa we have summarized the key aspects of the
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l U.S. Nuclear Regulatory Commission
-B13365/Page 2 October 6, 1989 meeting or the value derived from it. is a combined chronolog-ical list of inspections and special meetings which have taken place during this period with an approximation of the number of inspection hours involved.
A review of the data indicates that approximately three man-years (7,349 hours0.00404 days <br />0.0969 hours <br />5.770503e-4 weeks <br />1.327945e-4 months <br />) of inspection (or visit) activity occurred over this four raonth period, which we believe to be representative.
This equates to ten man-years of inspection each year.
We conservatively estimate that two to four hours of licensee time is required for preparation, interface, support and follow-up,
.for every one hour of inspection time.
This would pr1 ject to twenty to forty u"
man-years of licensee time collectively spent each year to support inspections at our. four plants.
We say this with tne recognition that receive fewer inspections than the average Region I facility.yr facilities Of course, the pace varies from time to time.
Occasionally there are comparatively few L
inspections, and at other tiees the activity is very intense.
We greatly appreciate the accommodations that the NRC makes to adjust inspection initiatives whenever it is known well in advance that a more optimum schedule can be arranged.
One general observation we can make from these inspections is that the team inspections are resource intensive for the NRC and for our plants.
When team inspections are performed during refueling outages they can have a significant im)act on our ability to manage outage work.
When such large inspections ara scleduled during normal operation, any dty-to-day operational issues can impact our ability to support the team inspections as well as we woula like.
It is very: beneficial that the NRC recogn'zes that plant initiatives and good performance can reduce the need for team inspections. A particularly valuable example is Safety System Functional Inspections.
We have completed our own SSFIs on Millstone Unit Nos. I and 2 and we will be doing them in the near i
future on Millstone' Unit No. 3 and the Haddam Neck plant.
The use of our own resources has enabled ' us to fully internalize and recognize some common elements from our SSFIs that are related to configuration management and other initiatives. We have shared our SSFI objectives and findings in meetings with the NRC.
In addition, the ability to schedule this work has provided us the flexibility to use our resources in an optimum manner that is advantageous to all four of our plants.
In summary, the inspections and meetings have an overall substantial benefit to us. We encourage such activities where mutual benefits are derived. We do have some concern that from time to time, the number of inspections and the number of inspectors and visitors at the sites at any given time may challenge our resources, but we have not let this affect our ability to safely operate the piar.ts.
We view this as a neces ary prt of our job, but one that could (1) Refer to ACRS Regional Subcommittee Programs Meeting with NRC Region 1, Aup tt 29 and 30, 1989, briefing material.
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U.S. Nuclear Regulatory Commission 1
B13365/Page 3 October 6, 1989 I
perhaps be improved upon by enhanced communication.
Your willingness to consider alternative schedules, when reasonable justification is provided, is helpful.
It is equally important to us that you have a more complete appreciation of this aspect of nuclear power plant management, and we trust this letter will. confirm, if not enhance, your awareness of this aspect of our operation.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY l
.hh E. JT)froczka
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Senior Vice PresTdent cc:
W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No.1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 A. B. Wang, NRC Froject Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant
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' Attachment l'
-B13365/Page:1 2
Haddam Neck Plant Reactive Inspections and Special Meetinas o
NRC Insoection - Event V. July 24 - Auaust 4.1989 The NRC Staff conducted a two-week audit at the Haddam Neck Plan with i
respect to Event V/ Interfacing Systems LOCA.
Event V/ISLOCA represents a' postulated "beyond _ design-basis" event that involves the leakage of high-pressure reactor coolant system (RCS) fluid into lower pressure systems connected to the. RCS, such as the low-pressure safety injection system and the high-pressure safety injection system.
Such postulated back-leakage-could result in a LOCA-outside of containment and the disabling of safety injection systems.
The "one item of concern" involved the NRC Staff's suggestion that CYAPC0 perform leak testing of the valves (both manual and motor operated) that are on the RCS side - of valve DH-M0t.*-310 in the drain system.
These valves have been addressed in previous in-service test (IST) submittals to the NRC Staff in which we explained why these valves were not being leak tested.
All of this was discussed with the NRC team during the audit.
The NRC team has requested that we reconsider including these valves in the IST program for leak testing in the future, and we are evaluating the merits of this possible change.
Follow-up with the Staff j
in the near future is anticipated.
o NRC Insoection - Switchaear Buildina & Anoendix R. Auaust 14-17. 1989 Two members of the NRC Region I Staff conducted an inspection of the New Switchgear Building and-Fire Protection programs at Haddam Neck.
The inspectf an focused on the electrical construction aspects of the New i
Switchquar Building and included the normal annual Region I inspection of the piant's fira protection program.
No deficiencies were noted by the NRC Staff. The NRC Staff stated at the exit meeting that after discussions with their management, a determina-tion will be made, based on the results of this inspection, of whether any additional inspections of the New Switchgear Building will be required prior to start-up from the upcoming outage.
However, as far as an Appendix R inspection is concerned, the NRC stated that they did not know if an inspection would be conducted during this outage or what impact the current inspection results may have on the schedule for the Appendix R audit.
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' Attachment 1 B13365/Page 2 l.'
o NRC Inspection - EE0 Follow-up Audit. September 11-15. 1989 The Region-I NRC Staff conducted a follow-up EEQ Audit for the Haddam Neck Plant.at our corporate offices.
The purpose of this audit was 'to close-out all open and unresolved items as a result of the first-round EEQ audit conducted in November 1987.
The NRC Inspector visited the Haddam Neck Plant on September 14, 1989 to inspect various equipment-associated with the close-out of open items. An exit meeting was held on l-l' September 15.
Results of this audit have not been received,- but it is anticipated that most, if not all, open and unresolved items from the l'
November-1907 audit have been resolved and closed.
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-B13365/Page 1-Millstone Station Reactive Inspections and Special Meetinos o
NRC Insoection - Millstone Unit No. 1 - Hydrolazer Contamination. May 17-18. 1989 An inspection of the shipment of a high pressure pump and trailer with removable external radioactive contamination from the licensee's reactor site' to a vendor site in Morristown, New Jersey was conducted during May 17-18, 1989 Two apparent violations were identified:
1)
The failure to establish adequate procedural controls to prevent contamination of the hydrolazer equipment, and L
2)
As a result of the above failure, there were transportation violations under Title 49 of the Code of Federal Regulations:
inadequate examination and testing, contamination in excess of l
49CFR173.443 Table 10 limits, and lack of shipping papers adequately l
describing the material.
o NRC Insoection - Millstone Station - Maintenance Team Inspection.
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l-May 30;- June 16. 1989 and-July-10-14, 1989 L
Seven NRC inspectors (staff and contractors) performed an in-depth team inspection of the Millstone Nuclear Power Station, Unit Nos.1, 2, and 3 maintenance program and its implementation.
The inspection included a L
L review of maintenance documents and observations of maintenance work in I
progress.
The inspectors used the NRC Maintenance Inspection Guidance, dated September-1988, and Temporary Instruction 2515/97, dated 7
November 3, 1988.
The inspection team evaluated three major areas:
(1) overall plant performance as affected by maintenance, (2) management support of mainte-nance, and (3) maintenance implementation.
Under each of these major areas, elements considered important for proper functioning of the area L
were inspected.
For each element, the inspectors evaluated both the program and how effectively the program was implemented.
The inspection was performed as part of NRC's industry-wide effort to evaluate the effectiveness of maintenance activities at licensed power reactors.
We believe the NRC foued that the Millstone station has an extremely good maintenance training facility.
Also, we believe that the NRC's maintenance inspection module provides an effective means for self assessment.
The team concluded that management is strongly committed to m
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4 B13365/Page 2; improving maintenance activities at Millstone as evidenced by the numer-ous maintenance improvement initiatives that were instituted.
No unresolved items or violations were identified.
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-NRC Inspection - Third Party Vendor Parts Refurbishment. June 6-7. 1989 An inspection was conducted by two representatives of the Office of Nuclear Reactor Regulation (NRR).
The-inspection included information gathering for the two inspectors, to determine the extent that Millstone Station uses third party vendors as the supplier of refurbished electrical equipment. The reason the inspec-L tors :were looking for this information was due to the potential for refurbished items having been supplied by a-third party vendor,- and installed _ in Millstone Station Categor) 1 systems.
These items were suspected.of being substandard.
The inspectors were satisfied with the as-installed equipment, although follow-up continues.
o NUMARC' Visit - Millstone Station - Familiarization. June 26 -
September-l'. 1989 A NUMARC ' senior. project manager spent nine weeks.at Millstone and one week at our corporate offices, to-gain a broad understanding of NU operations.
The exposure of this individual to our organization and facilities appeared to accomplish the original objectives.
0-Russian Deleaation Visit - Millstone Station. July 18. 1989 Four scientists from the Soviet's Kurchatov-Institute of Atomic Energy visited Millstone for a daylong overview of NU's nuclear training pro-gram.
The Institute, a major national nuclear power planning and research. agency, recently purchased two interactive nuclear simulators from Singer Link Miles.
The day's activities featured presentations on each of the Training Department's major areas of instruction.
The group then observed a simulated steam generator tube rupture with loss of normal power and centrol air at the CY simulator.
o-NRC Insoection -- Millstone Station - Station Blackout. July 18-21. 1989 Five NRC inspectors and two NRC contractors conducted a Station Blackout (SBO) Audit at Millstone Unit Nos.1, 2, and 3.
The main purpose of the audit was to permit the NRC and its contractors to examine the documenta-tion and calculations supporting our April 17, 1989 and May 30, 1989 SB0 o
813355/Page 3 submittal s.
_The most significant result of the audit is that some NRC Staff members believe the Millstone Unit No. I and 2 crosstie is not adequately designed to withstand a single failure and therefore cannot be credited as currently designed, for an alternate AC power source.
The NRC team leader acknowledged this is a generic issue focusing' on differing opinions in interpreting the previously endorsed NUMARC 87-00 Report on SB0. Additionally, less significant action items resulted from the audit.
Information on these issues has been provided to the NRC.
,o NRC Inspection - Millstone Unit No. 3 - Thimble Tube Wear. July 25-26.
1912 An NRC Staff member and a contractor conducted an inspection to review the program for monitoring Millstone Unit No. 3 thimble tube performance.
The. NRC staff reviewed the following documentation as a part of their inspection:
I o
NU's-inspection report /results o
Design drawings-o Analysis supporting acceptance criteria and inspection frequency.
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It appeared that the NRC was satisfied with the Millstone Unit No. 3 thimble tube wear program, o
Russian Deleoation Visit - Millstone Station. Auaust 4. 1989 A delegation of three high-level-Soviet nuclear safety engineers, one of which was a member of the ruling body of the U.S.S.R.
Academy of Sciences, visited Millstone Unit No. 3 control room simulator.
Four NNEC0- control room ccarators demonstrated a mock emergency which included loss of reactor coolant and loss of electricity to the control facility..The Soviets observed the operators assessing the simulated l
emergency, shutting -down the plant, sending mock alerts to company and regional officials, and finally giving the order to evacuate unnecessary personnel from the Millstone complex.
The visit to Millstone was part of the three-day visit of the U.S. by the three - top civilian advisors to the Soviet government which reflects L
increased cooperation among international nuclear experts as a result of the Chernobyl accident.
o Brookhaven National Laboratory - Nuclear Power Plant Trainina.
Auaust 9. 1989
- A representative of Brookhaven spent one day between the corporate offices and the Millstone site familiarizing himself with NU's nuclear power operations in preparation for his upcoming lecture on Nuclear Power in the Soviet Union.
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813365/Page 4 i
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_o INP0-Insoection - Millstone S,tation - Plant E.gluation.
.Auaust 14-25.-1989 INPO performed an evaluation of Millstone Station against INP0's standards of excellence.
This was a relatively intense evaluation involving twenty four (24) inspectors for two weeks.
The results will be reported in a Plant. Evaluation Report which is expected to be published by mid-October, 1989.
o NRC~ Visit - Millstone Unit No. 3 - MOV Ooerability. Auaust 29. 1989 This meeting provided the NRC (AE00) with an opportunity to receive first hand operating experience and discuss MOV testing & surveillance in general with' someone they believed had some useful information on the subject.
While the exchange was originally prompted in part-by a Millstone Unit No. 3 LER, the NRC interest included all four NU units to l,
L the extent NU has operating experience and technically based opinions which relate to understanding the safety significance of the MOV testing 4
and-surveillance issue and our proposed action in response to Generic l
Letter 89-10.
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o NRC Visit - Accident Manaaement. Auaust 29. 1989 On August 29, 1989, five members of the NRC Staff and two contractors 1
visited the NU Corporate Emergency Operations' Center (E0C) to discuss l
NU's efforts in the Accident Management (AM) area. During this visit, NU L
demonstrated our data transmission system between the stations and the corporate E0C, thermal hydraulics calculational capability on a PC, and
' the PRA models on the PC.
The meeting was one of several NRC visits to licensees to learn about existing AM capabilities, o
NRC Insoect.jon - Millstone Unit No. 3 - Enaineerina Support. September 18-22. 1989 l
An NRC inspection from the Region I Staff performed an inspection of NU's Corporate Engineering Support for Millstone Unit No. 3.
The objective of this inspection ~was to assess the adequacy of NU's engineering program for design control, internal and external interfaces, management support, staffing levels and experience, training and NU's response to NRC re-quirements and requests.
Engineering support is one of the SALP catego-ries and the results of this inspection will be reflected in the next SALP report for Millstone Unit No. 3.
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ATTACHMENT 3.
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. CHRONOLOGICAL LIST OF AUDITS,INSPECITONS AND VISITS (FROM MAY1989).
10/6/89.; '-
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INSPECIOR/ VISITOR
.l
. UNIT l
.l SUBJECT / ORGANIZATION l
l DATE l-MAN / HOURS CY Routine / NRC May Jun-13 205 MP2 Routine / NRC May Jun-15 183 MP1 Routine / NRC May-9 L - Jun-15 263 MP1 & 2 Routine / NRC May May-19 40 MP3 Routine / NRC May Jun-12 160 MP1 Hydrolazer Contamination / NRC May May-18 16 MPS Maintenance / NRC May Jul-14 640 MP1 & 2 Third Party Vendor Parts Refurbishment / NRC Jun4
- Jun-7.
32 CY Radiological Controls / NRC
. Jun - Jun-9 24 MP3 Routine / NRC Jun Jul-17 273 CY Routine / NRC Jun Jun-16 24 CY Routine / NRC Jun-14 ' - Jul-25 199 MP1 Routine / NRC Jun Jul-17 67 MP2 Routine / NRC Jun Jul-26 162 MPS Routine / NRC Jun Jun-23 40 MP3 Routine / NRC Jun Jun-30 40 CY Routine / NRC Jun Jun-30 80 MPS Familiarization / NUMARC
' Jun Sep-1 400 MP1 & 2 Routine / NRC Jul-11
- Jul-14 32 Mrs Russian Delegation Jul-18 32 MP1 Routine / NRC Jul Aug-21
'
- 200 MPS Station Blackout / NRC Jul Jul-21 224 MP3 Routine / NRC Jul Jul-28 40 CY Event V / NRC Jul Aug-4 640 MP3 ThimbleTube Wear / NRC Jul Jul-26 32 CY Routine / NRC Jul Sep 181 MP2 Routine / NRC Jul Aug-30
- 200 CY Routine / NRC Jul-31
- Aug-4 44 MP3 Routine / NRC Aug Sep-5
- 200 MPS Russian Delegation Aug-4 24 CY Routine / NRC Aug Sep-11
- 200 MPS ATWS / NRC Aug Aug-11 40 GEN.
Nuclear Power Training / Brookhaven Aug-9 8
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. CHRONOLOGICAL LIST OF AUDITS, INSPECTIONS AND VISITS GROM MAY 1989) 10/6/89l 1"'
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JNSPECTOR / VISITOR L
'l UNIT l-l SUBJECT / ORGANIZATION l
l DATE l
MAN / HOURS '
MPS Plant Evaluation'/ INPO -
Aug Aug-25 '
1920.
CY
- Swgr. Bldg.& Append.R / NRC Aug Aug-17 64 MP3
- ~ Routine / NRC
' Aug _ _
4 MP1 Routine / NRC Aug Sep-15 144 MP3 MOV Inoperability / NRC Aug-29 8
GEN.
Accident Mgmt. / NRC Aug-29 56 MP2 Routine / NRC Sep - Sep-15 80 MP3 Routine / NRC
.Sep-6
- Sep-15 40 MPS NMSS Great Neck Warehouse / NRC Sep-11 8~
MPS Routine / NRC Sep-11' - Sep-15 40 CY EEQ Follow-up Audit / NRC Sep Sep-15 40 Total -
l7349l ACTIVITIES AFIIR MID - SEPIBfBER PERIOD MP3 NU Engineering Support / NRC.
Sep-18. - Sep-22 40 MPS Familiarization / INPO Sep Dec-22
- 600 MP3 Operator Requalification / NRC Sep Sep-22 160 MPS & BERLIN Operator Requalification &.Rosemount / NRC Sep Sep-27 32 MPS & CY Familiarization / NRC (Commissioner Rodgers)
. Sep Sep-29 16 BERLIN Eddy Current Testing Oct-3 40 MPS & CY Operator Requalification / NRC Oct-3 8
MP1 Emergency Preparedness Exercise / NRC Oct-4
- 240
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MP1 Operator Requalification / NRC Oct Oct-27
- 320.
MPS & CY Regulatoryimpact Survey / NRC Oct-23 48 MP1 EOP Inspection / NRC Oct Oct-27
- 120 MPS & BERLIN ACRS JAN 32
- Estimate Page2 w.,
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