ML20029D126
| ML20029D126 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/26/1994 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9405040063 | |
| Download: ML20029D126 (3) | |
See also: IR 05000245/1993016
Text
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APR 2 s 19y
Docket Nos. 50-245; 50-336; 50-423
,
Mr. John F. Opeka
Executive Vice President - Nuclear
Northeast Nuclear Energy Company
P. O. Box 270
Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT:
COMBINED INSPECTION REPORTS 50-245/93-16; 50-336/93-11;
50-423/93-13
This letter refers to your September 10, 1993, correspondence, in response to our July 22,-
1993 letter.
In your response to the Notice of Violation regarding failure to restore the reactor building
closed cooling water radiation monitor to service properly following surveillance testing, you -
noted an apparent miscommunication between the plant equipment operator and the control
room operations staff over the status of the radiation monitor and focused your corrective
action on the plant equipment operator's performance. We note that the correct status of the
radiation monitor was communicated to the control room staff and, on more than one
,
occasion, was properly indicated in the plant equipment operator's rounds logs which are
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reviewed periodically by shift supervisory personnel. We are concerned regarding the
]
apparent performance deficiencies on the part of operations shift supervision revealed by this
event, and request that you inform us of the results or progress on the action stated in your
,
letter to make the team (shifts) more effective or of any other corrective actions which you
may have taken to address these deficiencies.
With respect to the other violations in our inspection report, thank you for informing us of
the corrective and preventive actions documented in your letter. These actions will be
examined during a future inspection of your licensed program.
.
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Your cooperation with us is appreciated.
Sincerely,
Wayne D. Lanning, Acting Director
Division of Reactor Projects
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9405040063 940426
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S. E. Scace, Vice President, Nuclear Operations Services
D. B. Miller, Senior Vice President, Millstone Station
H. F. Haynes, Nuclear Unit Director
G. H. Bouchard, Nuclear Unit Director
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F. R. Dacimo, Nuclear Unit Director
R. M. Kacich, Director, Nuclear Planning, Licensing and Budgeting
J. Solymossy, Director of Nuclear Quality and Assessment Services
Gerald Garfield, Esquire
Nicholas Reynolds, Esquire
K. Abraham, PAO (2)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of Connecticut SLO Designee
NRC Resident Inslator
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Mr. John F. Opeka
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J. Stolz, NRR/PD I-4
V.' McCree, OEDO
J. Anderson, NRR
M. Shannon, NRR/ILPB
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DEC-G9-1993 16:01
MILLSTONE RESIDENT OFFICE
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NORTHEAST UTil.ITIES
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September 10, 1993
Docket No. 50-336
B14605
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U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2
Reply to a Notice of Violation
Combined Inspection Report _Nos. 50-245/93-16: 50-336/93-11; 50-423/93-13
In a letter dated July 22, 1993, m the NRC Staff transmitted to Northeast
Nuclear Energy Company (NNECO) Combined Inspection Report Nos. 50-245/93-16,
50-336/93-11, 50-423/93-13.
As discussed in that report, the NRC Staff cited
NNECO for three apparent violations of the Commission's regulations at
Millstone Unit No.
2.
Pursuant to 10CFR2.201, and in accordance with the
instructions contained in the inspection report, NNECO hereby provides, as an
attachment to this letter, the. required information in response to the Notices
of Violation.
Per a telephone conversation with Region I Staf f,
the due date to respond to
the Notices of Violation was extended to September 10, 1993.
This extension
was requested to allow Millstone Unit No. 2 personnel involved in response to
these Notices of Violation time to support operational events associated with
the unit and allow additional time to evaluate and respond to the recently-
issued NRC Staf f Systematic Assessment of 1,1 cense Performance report.
In the NRC Staff's July 22.
1993, letter, the Staff expressed concern
regarding'the apparent repetitive nature of the three cited violations. These
concerns centered on the lack of timely and comprehencive actions to prevent
recurrence, and the apparent ineffectiveness of NNECO's previous corrective
actions.
We share these concerns as evidenced by NNECO's recent decision to
task an Independent Review Team to evaluate performance issues at Millstone
Unit No. 2.
Additionally,
a Millstone Unit
No.
2 Performance Improvement Initiative
recently has been initiated to address a wide-range of unit performance
issues.
We believe that this initiative, coupled with IRT recommendation
implementation,
will help effect resolution to a number of
specific
performance issues that have recently occurred.
The Performance Improvement
Initiative is currently comprised of action plans that address the areas of
configuration control, attention to detail, management / supervisory oversight,
communications, personnel roles and responsibilities, resources, work control,
and accountability. We believe the action plans that have been developed will
immediately address those areas of concern identified. We will be prepared to
(1)
A.
R.
Blough letter to
J.
F.
Opeka, ' Millstone Combined Inspection
Report Nos. 50-245/93-16; 50-336/93-11: 50-423/93-13," dated July 22,
1993.
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U.S. Nuclear Regulatory Costunission
B14605/Page 2
September 10, 1993
discuss this initiative and the results of the Independent Review Team's
effort more fully at the management meeting to be held September 24, 1993.
We trust that you find this information satisfactory and we remain available
to answer any questions you may have.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
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J. F. @ive Vice President
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Execut
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cc:
T. T. Martin, Region 1 Administrator
J. W. Andersen, NRC Acting Project Manager, Millstone Unit No. 1
G. S. Vissing, NRC Project Manager, Millstone Unit-No. 2
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V. L. Rooney, NRC Project Manager, Millstone Unit No. 3
D. H. Jaffe, NRC Project Manager, Millstone Station
P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2,
and 3
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Docke_t No. 50-336
B14605
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Attachment 1
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Millstone Nuclear Power Station, Unit'No. 2
Reply to a Notice of Violation
Combined Inspection Report Nos. 50-245/93-16:
50-336/93-11; 50-423/93-13
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September 1993
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U.S. Nuclear Regulatory Commission
B1460S/ Attachment 1/Page 1
September 10, 1993
Millstone Nuclear Power Station, Unit No. 2
Reply to a Notice of Violation
Combined Inspection Report Nos. 50-245/93-16;
50-336/93-11; 50-423193-13
_ _ _ _
RESTATEMENT OF VIOLATION At
Millstone Unit 2 Technical Specification 6.8.1
requires that procedures
covering station activities shall be established and implemented.
Station
Administrative Control procedure (ACP) ACP-QA-3.02E, " Procedure Compliance,"
and Surveillance
Procedure
SP-2404AW,
Liquid Radiation Monitor
(RM 6038) Calibration," were established pursuant to the above.
Procedure ACP-QA-3.02E requires, in part, that the intent and direction of
procedures shall be followed, and that deviation from procedures is not
permitted.
Surveillance Procedure SP-2404AW, "RBCCW Liquid Radiation Monitor
(RM 6038)
Calibration," Steps 4.7 and 6.8.8, require that operations personnel open and
shut, respectively, the isolation valves to the sample canister on monitor RM-
6038.
Technical Specification 3.3.3.9,
" Radiation
Liquid Effluent Monitoring
Instrumentation," Table
3.3-12,
Action
3,
applicable to reactor building
closed cooling water system radiation monitor RM-6038, requires, in part, that
with monitor RM-6038 inoperable greacer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples of service
water system effluent shall be collected and analyzed for gross radioactivity
once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above;
1.
During performance of Procedure SP-2404AW on May 3,
1993, the sample
canister
isolation
valves
on
monitor
RM-6038
were
closed
by
instrumentation and controls personnel vice operations personnel; and,
at the completion of the calibration, the sample canister isolation
valves were not reopened, rendering monitor P&6038 inoperable.
2.
From 7:57
p.m.,
on May 3,
1993, to 1:00 a.m.,
on May 6,
1993, monitor
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RM-6038 was inoperable, during which time grab samples of service water
system effluent were not collected and analyzed for gross radioactivity.
This is a Severity Level IV Violation (Supplement I)
1.
Reason for the Violation
The cause of the event was procedural noncompliance.
The radiation
monitor calibration procedure specifically required that the operations
department close and reopen the isolation valves to RM-6038.
In this
event, the Instrument and Control (I&C) technician closed ' the skid
isolation valves, failed to have Operations close the system isolation
valves, and failed to reopen the skid isolation valves upon completion
of the procedure.
2.
Corrective Steps Than Havo_Been Taken And The Results Achieved
The radiation monitor was immediately unisolated and returned to
service.
Chemistry analysis of the service water system verified that
DEC-09-1993 16:03
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U.S. Nuclear Regulatory Commission
B14605/ Attachment 1/Page 2
September 10, 1993
no gross radioactivity was present.
This event was reported to the NRC
on June 4, 1993, as LER 93-009.*
NNECO considers this event alone unacceptable.
Additionally,
as
discussed between the Millstone Unit No. 2 Director and the NRC Resident
the apparent misreading by the Plant Equipment Operators
Inspector,of the equipment and the resultant incorrect logging, is equally
(PEO's)
unacceptable.
We consider this second issue to be indicative of a lack of attention to
detail and a breakdown in communication.
We have interviewed the PEOs
who mistakenly recorded that flow was evident, when in fact, there was
none.
Our investigation has determined that the PEOs did make their
assigned rounds, but were not effective in verifying flow.
no flow condition had originally
The PEO who properly identified the
reported
the
situation
to
the
control
room
on
May
4,
1993.
Unfortunately, incomplete corrective action was taken by the control
On May 5, 1993, the same PEO realized that the
room staff in response.
situation was not corrected and notified the oncoming shift PEO of the
The oncoming shift PEO identified the problem and had the
lack of flow.
situation corrected.
Plant management is concerned about this lack of attention to detail
with respect to the PEOs ineffective flow verification,
and the
miscommunication between the PEO and control room over the inoperability
of the radiation monitor.
The individuals involved in this event were
counseled, a memo was issued to provide additional guidance to PEOs.
This memo stresses that the PEOs need to individually evaluate their own
'
performance in regard to both rounds and shift turnovers and ensure that
PEO shift turnovers ae performed consistently,
that appropriate
information is passed on to oncoming PEO's, and that problems are to be
'
identified and investigated properly. Operations Department Instruction
2-OPS-6.15 was modified to strengthen the PEO job function,
and
specifically includes the requirements that shift turnovers must include
a comprehensive exchange of information.
Specifically, shift turnover
must include:
Status of various systems and equipment.
.
Reasons for any abnormal or out of specification readings noted on
.
rounds sheets.
Plant evolutions in progress.
.
Potentially hazardous activities or conditions reported during the
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previous shift.
Significant maintenance activities completed or carried over.
.
Equipment which is out of service or for which Trouble Reports or
.
Tags have been initiated.
The Operations Department has taken a pro-active approach to assure
these events do not recur.
Shift supervisors are being ' encouraged to
_
S. E. Scace letter to U.S. Nuclear Regulatory Comission, * License Event
(1)
Report 93-009-00,* dated June 4, 1993.
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B14605/ Attachment 1/Page 3
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September 10, 1993
1
develop plans to make the teams more effective, knowing full well that
they are being held accountable for safe and accurate job performance.
Items being considered include: 1) performing more frequent round
observations with their PE0; 2)
Shift Supervisor inspections prior to
4
pEO roundo and a comparison of subsequent discussions of findings and
issues.
NNECO believes the recurrence of these problems is due to incorrect or
ineffective root cause determination and, as a result, incorrect or
ineffective corrective actions have been taken.
corrective stens That Will Be Taken To Avoid Further Violationa_
3.
The I&C Technicians involved were disciplined and counseled on the
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importance of procedural compliance.
The calibration procedure for RM-6038 has been revised to include the
a
following:
Clarification of isolation valve restoration instructions.
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A verification and sign-off of normal process
flow during
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restoration.
A verification and sign-off of inlet and outlet valves open after
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restoration.
Additionally, all radiation monitor procedures have been reviewed and
revised,
as
required,
to
incorporate
the
above
changes,
where
appropriate.
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4.
Dete When. Full compliance Will 3, Achieved
Full compliance was achieved on May 6, 1993, when the radiation monitor
isolation valves were opened.
5.
Generie :tumlications
The changes made to the Radiation Monitor procedures are applicable to
Millstone Unit No.
2.
The impact of the changes at the Haddam Neck
Plant and Millstone Unit Nos. 1 and 3 will be evaluated.
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B14605/ Attachment 1/Page 4
September 10, 1993
RESTAI _--I 0F VIOLATION B
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Unit 2 Technical Specification 4.0. 5.a - requires, in part, that
Millstone
inservice testing of valves shall be performed in accordance with Section XI-
of the ASME Boiler and Pressure vessel Code as required by 10CFR50,
Section 50.55a(g).
Surveillance
Procedure
" Chemical
and Volume
Control . System
operational Readiness Test,* implements the requirements of the above for
2-CH-510 and 2-CH-511.
Procedure SP-21131, Step 7.5.4,
requires, in
valves
part, that if either valve does 2ot meet the acceptance criterion specified by
the procedure, the valves shall be inenediately declared inoperable; a plant
incident report shall be submitted: and the inservice' test coordinator or the
engineering department inservice inspection supervisor shall be notified as
soon as possible.
Contrary to the above, on May 25, 1993, valves 2-CH-510 and 2-CH-511 failed to
the ' f ailure mode test acceptance criterion of Procedure SP-21131, and
meet
were not declared inoperables a plant incident report was not submitted until-
June 3, 1993; and neither the inservice test coordinato.T nor the engineering
department inservice inspection supervisor were notified until June 3, 1993.
This is a Severity Level IV violation (supplement I)
1.
Reason For The Violation
The cause of this violation was the lack of understanding of Inservice
Test (IST) program requirements by the shift supervisor involved and his
lack of compliance with the-procedure guidance.
The procedure clearly
stated thats
a.
the valve was to be declared inoperable
b.
appropriate Technical Specification action must be taken
c.
a PIR was to be submitted
d.
the IST coordinator was to be notified
e.
a trouble report was to be sutenitted
f.
testing was to be continued or suspended as directed by the SS
only steps e and f were followed.
The shift supervisor believed these
actions were appropriate since he knew that engineering practice was to
recommend additional testing and that he believed it was within his
1
authority to retest the valves.
2.
corrective steps That save Been Taken And The Results Achieved
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The valve was declared inoperable, a PIR was initiated to document the
situation, and the IST coordinator was notified.
2.
corrective steps That will Be Taken To Avoid Further Violations
The shift supervisor received appropriate disciplinary action with
respect to the need for complete compliance with IST procedures and the
inappropriateness of his judgements.
In subsequent situations, with
similar IST requirements, the appropriate procedure guidance has. been
followed by this supervisor.
This event was reviewed with all Millstone Unit No. 2 shift supervisors.
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In addition, a memo to all shift supervisors was distributed on
August 29, 1993, that clarifies expectations with respect to evaluating
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B14605/ Attachment 1/Page 5-
September 10, 1993
IST results.
This memo stressed the need.for IST procedure coenpliance,
how to address aborted test attempts, and the need for protqpt initiation
of PIRs.
The violation also discussed a Plant.Information Report (PIR) timeliness
issue.
The Millstone Unit No. 2 Directer has established, as a result
a task force to evaluate the PIR process with the
of separate concerns,
goal of producing a significant inprovement
in,
and consistency
throughout the process.
The PIR task force will shape and fona the
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process by which individuals perform the investigation, evaluation and
root cause of PIR's thereby ensuring that all investigations are timely
and meet established schedules. In addition, the task force will ensure
all investigations are in-depth and concise, that the appropriate
that
root causes and contributing causes are identified, that the corrective
actions and actions to prevent recurrence are appropriate and effective.
the task force will ensure that the issues learned are
Finally,
appropriately shared throughout the Northeast Utilities organization.
4.
Date M aa Full Compliance Will Be' Achieved
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Full compliance was achieved on June 3, 1993, when the actions specified
in the procedure were acconplished.
5.
^=^ric Immlications
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This violation will be evaluated at the Haddam Neck Plant and Millstone
Unit Nos. 1 and 3 for potential applicability.
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B14605/ Attachment 1/Page 6
September 10, 1993
RSSTATeM7MT OF VIOLATION C
Millstone Unit 2 Technical specification 6.8.1
requires that procedures
covering
station activities
be
established and
implemented.
Station
Administrative Control Procedures (ACP) ACP-QA-3.02E, ' Procedure Compliance,'
and
ACP-QA-2.06A,
" Station
Tagging,"
Chemistry
Procedure
" Containment Purge,' and Operatione Procedure OP-2383A, ' Process Radiation
Monitors Operation,' were established pursuant to the above.
Procedure ACP-QA-3.02E,
step
6.2, requires, in part, that the intent and
direction of procedures shall be followed, and that deviation from procedures
is not permitted.
Procedure ACP-QA-2.06A, Step 6.1.2.1, requires, in part, that the position of
valves be verified to be in the proper position when placing tags.
" Containment Purge," Step 5.2.10, and Operations
Chemistry Procedure CP-2806X," Process Radiation Monitors Operation,* Step 5.10, require
Procedure OP-2383A,
that operations personnel disconnect the temporary sample rig from connections
downstream of radiation monitor RM-8123 and restore normal valve positions
following collection of containment atmosphere samples.
Contrary to the above;
1993, valves 2-AC-122 and 2-AC-124 were not verified to be
On March 28,
1.
The
in the proper shut positions when tags were placed on the valves.
valves were actually open.
2.
On several occasions prior to March 28, 1993, following sampling of the
containment
atmosphere,
chemistry
personnel
conducted
activities
required to be performed by operations,
i.e.,
disconnecting the sample
rig and repositioning valves.
This is a Severity I,evel IV Violation (Supplement 1)
1.
Reason for the Violation
l
The cauce of this event was personnel error:
Work Practice Procedures
not followed and Verification not performed.
Following CP 2383A,
' Process Radiation Monitors Operation," steps for RM-8123 containment
sampling would have restored the Radiation Monitor to a normal operating
Verifying the red tag required position for 2-AC-124 and
configuration.
2-AC-122 against the actual valve position would have ensured that the
valves were closed after the tags were rehung.
The chemistry personnel error was caused by the chemistry procedure not
clearly stating that Operations must perform the manipulation of the
valves.
Corrective steps That Have Been Taken And The Results Achieved
2.
When the day shift PEO reported the incorrect lineup on radiation
monitor RM-8123, he was directed to take the following actions:
Close
the inlet and outlet drain valves (2-AC-124 and 2-AC-122), disconnect
the sample tubing, and replace the pipe caps on 2-AC-124 and 2-AC-122.
These actions were completed.
shift briefings were conducted for the operating shifts shortly af ter
the incident occurred.
These briefingc discussed the incident and
_
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B14605/ Attachment 1/Page 7
September 10, 1993
reviewed Operations Department roles and procedural requirements for
containment sampling using RM-8123 and PE-8162.
The PEO involved was counseled by his supervision regarding the
importance of procedure compliance during evolutions.
Verification
during tagging activities was also emphasized.
3.
Corrective Stepa__That Will Be Taken to Avoid Further Violation
Operator
training
will
be
conducted
to
incorporate
knowledge
requirements associated with containment air sampling into the classroom
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portion of the Non-Licensed operator Initial Training (NLIT) Auxiliary
Building PE0 course.
In addition, additional training on containment
air sampling has also .been included in the Non-Licensed Operator
Continuing Training (NLCT) Auxiliary Building PEO cource. This training
is in progress and will be completed in October 1993.
Finally, in-plant
walk throughs will be performed as part of the next cycle of NLCT.
This
cycle of training will reemphasize which valves may be manipulated by
chemistry and which valves may be manipulated by operations. This cycle
of NLCT will be completed by January 1994.
The chemistry procedure concerning the operation of the valves (CP
2006X, ' Containment Purge") is being rewritten to include only Chemistry
Department personnel responsibilities.
In addition, the feasibility of a design change is being evaluated. The
modification involves installation of permanent connection points for
the RM-8123 and RM-8262 external sample equipment.
If implemented, the
)
modification will remove the requirement for Operations personnel to
maintain red tags and temporary sample hoses on the Radiation Monitor
inlet and outlet drain valves.
4.
Date when Full _ Compliance Will Be Achieved
Full coqpliance was achieved on March 28, 1993 when the PE0 notified the
control room of the
condition,
shut
the
isolation valves,
and
disconnected the rig.
The initial training enhancements have been made and will be given
~
during the normal initial training modules.
NLCT will be completed by
January 1994.
The chemistry procedure revision will be completed by
f
September 30, 1993.
5.
Generic Implications
The corrective actions made and being proposed to training and
procedures are specific to Millstone Unit No. 2.
Plf nt and at
This violation will be evaluated at the Haddam Neck
A
Millstone Unit Nos. 1 and 3 for potential applicability.
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FACSIMILE FROM MILLST0hE RESIDEE OFFICE
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MESSAGE TO:
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MILLSTONE FAX NO.
(203) 443-5893
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MILLSTONE RESIDENT OFFICE
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APP 12 CATION FOR A REPLY LETTER
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Paragraph No.
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'Ihank you for informing us of the corrective and preventive actions
documented in your letter. These actions will be examined during a
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future inWh of your licensed program.
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Your cocf=edon'with us is appreciated.
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- Thank you for informing us of the corrective and preventive actions documented
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LEC-10-1993 11:18
MILLSTOE RESIDENT OFFICE
203 443 5893
P.03
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General Offices * Selden Street, Berlin. Connecticut
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P.O. BOX 270
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HARTFORD. CONNECTICUT 06141-0270
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(203) 665 s000
.an.wi .umn . cow.
June 7, 1993
Docket Nos. & ?di
50 #3E
50_423
B14486
Re:
U.S. Nuclear Regulatory Commission
Attention: Document control Desk
Washington, DC 20555
Gentlemen:
'
Millstone Nuclear Power Station, Unit Nos.1, 2, and 3
Reply to Notice of Violations
Combined insoection 50-245/93-10: 50-336/93-06t 50-423/93-07.
In a letter dated April 30, 1993,"' the NRC Staff transmitted its Notice of
Violation (NOV) relating to NRC Combined Inspection '..eport Nos. 50-245/93-10;
50-336/93-06; and 50-423/93-07. . The report discussed the results of safety
inspections conducted between March 3, 1993, and April 3, 1993.
Based on the
results
of the
Staff's
inspection,
three
violations were
identified.
Attachment 1 to this letter provides Northeast Nuclear Energy Company's
,
(NNECO) response to the first violation, on behalf of Millstone Unit No.1
pursuant to the provisions of 10CFR2.201.
Attachment 2 provides NNECO's
response to the second and third violations on behalf of Millstone Unit No. 2
pursuant to the provisions of 10CFR2.201.
In a telephone conference with the
NRC Staff on May 24, 1993, it was mutually agreed that this response would be
submitted within 30 days from May 6,1993, the date of receipt.
The NRC letter also involved a detailed review of the activities of groups
which contributed to the overall self-assessment functions at the Millstone
Station.
While NNECO does not dis)ute the inspection findings, we have
included a brief discussion relat'ng to
self-assessment activities
in
Attachment 3.
(1)
A.
R.
Blough letter to J.
F.
Opeka, " Millstone Combined Inspection
50-245/93-10; 50-336/93-06; 50-423/93-07,' dated April 30, 1993.
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DEC-10-1993 11819
t11LLSTONE RESIDENT OFFICE
203 443 5893
P.04
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U.S. Nuclear Regulatory Commission
B14486/Page 2
June 7, 1993
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If you have any questions regarding information contained herein, please
contact us.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
FOR: J. F. Opeka
Executive Vice President
BY:
"#
W. D. Romberg
P'
Vice President
cc:
T. T. Martin, Region I Administrator
1
D. H. Jaffe, NRC Project Manager, Millstone Station
J. W. Andersen, NRC Project Manager, Millstone Unit No. 1
G. S. Vissing, NRC Project Manager, Millstone Unit No. 2
V. L. Rooney, NRC Project Manager, Millstone Unit No. 3
P. D. $ wetland, Senior Resident Inspector, Millstone Unit Nos.1, 2,
and 3
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DEC-10-1993 lit 19
MILLSTGNE RESIDENT OFFICE
203 443 5893
P.05-
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Docket No. 50-245
B14486.
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Attachment 1
,
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Millstone Nuclear Power Station, Unit No.1
Reply to a Notice of Violation
combined Inspection 50-245/93-10; 50-336/93-06; 50-423/93-07
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June 1993
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DEC-10-1993 11:19"
MILLSTONE RESIDENT OFFICE
203 443 5893.
P.06
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- U.S. Nuclear Regulatory Commission
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B14486/ Attachment 1/Page 1
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June 7, 1993
4
Millstone Nuclear Power Station, Unit No.1
i
Reply to a Notice of Violation
Combined. Inspection 50-245/93-10; 50-336/93-06; 50-423/93-07
!
Restatement of Violation
i
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During an NRC inspection conducted on March 3,1993, through April 3, h the
1993,.
i
violations of NRC requirements were identified.
In accordance wit
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR 2
j-
Part 2, Appendix C, the violation ~ is listed below:
,
A.
10CFR Part 50, Appendix B, criterion XVI (corrective Actions) requires,
!
in part, that measures shall be. established to assure that conditions
adverse to quality, such as failures, deficiencies, and deviations be
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promptly identified and corrected.
The measures shall assure that the
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cause of the. condition is determined and corrective action is taken to
preclude recurrence.
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Contrary to the above, since 1985, fourte= safety-related auxiliary
electrical contacts have failed to operate on demand, rendering Unit 1
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equipment inoperable.
The cause of the failures was attributed to dried
i
grease / cleaner residue, a maintenance-related condition applicable to
4
many similar safety-related contacts.
The licensee did not develop
effective corrective actions to preclude recurrence of the subsequent
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failures.
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This is a Severity Level IV Violation.
(SupplementI)
1.
Reason for Violation (Violation A1
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Plant Incident Report (PIR) investigations, relating to auxiliary contact
i
failures, identified the need to perform Preventative Maintenance (PM) of
3
the auxiliary contacts in order to improve component reliability.
This
action was not completed at the time of PIR close-out and no tracking
,
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commitment was established to ensure the completion of the PM activity,
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which resulted in subsequent failures.
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,
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Although it would have been expected that this action would have been
completed, the PIR Administrative Control Procedure did not specifically
>
require action item tracking prior to close-out.
2.
Corrective
Steos That Have
Been Taken
and
the Results AcMeved
(Violation A)
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An expedited program was established to identify, inspect, clean, and
lubricate the app,icable safety related auxiliary contac;s. This program
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DEC-10-1993. 11:20
MILLSTOtG RESIDENT OFFICE
203 443 5893
~P.07
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U.S. Nuclear Regulatory Comission
B14486/ Attachment 1/Page 2
June 7, 1993
4
was completed on April 28, 1993.
Note that this program did not reveal
any contact
abnormality sufficient to
inhibit the component from
performing its safety function.
3.
The Corrective Steps That Will Be Taken to Avoid Further Violations
(Violation A)
Since the time of the 1991 PIR, there have been numerous enhancements
made to the PIR process such that the PIR Administrative Control
Procedure (ACP-QA-10.01) now requires that comitments be established for
,
all corrective actions and/or actions to prevent recurrence identified in
the PIR that are incomplete at the time of PIR close-out.
The importance and significance of comitment tracking and follow-through
will be reinforced to all personnel involved with PIR investigations and
close-outs. This will be completed by July 30, 1993.
A periodic PM program will be established to clean and lubricate all the
safety-related contacts every other refuel outage. All nonsafety-related
auxiliary contacts will be cleaned and lubricated every third refuel
outage.
. This program will be in place by December 31, 1993, to be
implemented during the 1994 refuel outage.
4.
The Date When Full como11ance Will Be Achieved (Violation A)
An expedited program was established to identify, inspect, clean, and
lubricate
the applicable safety-related auxiliary contacts.
Full
compliance was achieved when this program was completed on April 28,
1993.
5.
Generic Implications (Violation Al
This issue will be identified to Engineering Management personnel at
Millstone Unit Nos. 2 and 3 and the Haddam Neck Plant.
Actions will be
taken as appropriate.
,
Additional Information (ViolationJO
The Staff expressed concern with the timeliness of corrective actions
established following the 1992 auxiliary contact failure.
An imediate
program to clean or replace the auxiliary contacts was not considered based on
the following:
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MILLSTONE RESIDENT OFFICE
203 443 5893
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U.S. Nuclear Regulatory Commission .
B14486/ Attachment 1/Page 3
June 7, 1993
NNECO was awaiting a response to a verbal request made to GE for
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recommendations
to
improve
the
reliability
of
the
auxiliary
contacts.
Based on the number of auxiliary contacts. utilized, a failure rate
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of two safety-related contacts per year was not deemed excessive.
Performance of Technical Specification surveillance would detect
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contact failures.
Absent explicit te.a.hnical vendor information, . Millstone Unitf No.1
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personnel elected not to implement actions which had the potential
to increase the failure rate.
It should be noted that when NNECO did receive accurate information from the
vendor, the issue was addressed aggressively and resolved.
The ' Staff also expressN concern for NNEC0's lack of consideration for the
potential of common mode failure.
This historical failure rate, as reviewed
by Probabilistic Risk Assessment, is consistent with their expectations, which
are established based on industry contact failure data.
However, the Staff's~
point- regarding sensitivity to common mode- failures is. well taken.
In this
regard, NNECO will
provide to Engineering and Plant -Operations. Review
Committee members by July 30, 1993, information regarding the potential for
,
common mode failures.
Additionally
since
1991,
the
Engineering
Department
is
assigned
the
responsibility for investigation of the majority of PIRs, allowing trends and
common mode failures to be more readily recognized.
Based upon NNECO's difficulty in determining appropriate PM requirements for
auxiliary contacts from the component vendor, a Nuclear Network Notification
(OE 5909) was transmitted on April 6,1993, to inform other plants of the
vendor recommendation to clean and lubricate the auxiliary contacts on a
three-to-five year basis,
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MILLSTONE RESIDENT OFFI
203-443 5893'
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()ocket No. 50-336
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B14486
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Attachment 2
Millstone Nuclear Power Station, Unit No. 2
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Reply to Notice of Violations
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Combined Inspection 50-245/93 10; 50-336/93-06; 50-423/93-07
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June 1993
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DEC-10-1993 11:21-
MILLST0tE RESIDENT. OFFICE
203 443 5893
P 10
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U.S. Nuclear Regulatory Commission
B14486/ Attachment 2/Page1
June 7, 1993
Millstone Nuclear Power Station, Unit No. 1
Reply to Notice of Violations
Combined Inspection 60-245/93-10; 50-336/93-063 60-423/93-07
Restatement of Violations
During an NRC inspection conducted on March 3,1993, through ' April 3,1993,
violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, the violations are listed below:
B.
Millstone
Unit
2
Technical
Specification.
6.8.1.a.
requires
that
procedures be established, implemented, and maintained as recommended in
Appendix A
of
Regulatory
Guide 1.33,
Revision 2,
February
1978.
Regulatory Guide 1.33, Revision 2, February 1978.- Regulatory Guide 1.33
recommends procedures for administrative control of surveillance testing.
Surveillance Procedure SP-2401C, "RPS Turbine Loss of Load . Test," step
6.2.1
requires that certain reactor protection system (RPS)
trip
bistables be bypassed . prior to testing the turbine trip bistable.
Step 6.2.6 ~ requires alarms on the nuclear instrumentation linear ' power
range channel - drawer and the RPS- trip bistables to be reset prior to
removing the bypass keys installed in, step 6.2.1.
Contrary to the above,'on February 22, 1993, on one occasion, step 6.2.6
of SP-2401C was not performed prior to removing the bypass keys; and, on
two occasions, step 6.2.1 of SP-2401C was not performed prior to testing
the turbine. trip bistables.
This is a Severity Level IV Violation.
(SupplementI)
C.
Millstone Unit 2 Technical Specification 6.8.1.e requires that procedures
be
established,
implemented,
and
maintained- for - emergency
plan
implementation.
Emergency Plan Implementing Procedure ~4701-4, " Event
Classification," requires prompt NRC notification of any . event or
condition that results in an unplanned automatic actuation of any
engineered safety feature, including the reactor protection system (RPS).
Contrary to the above, on February 22, 1993, an unplanned automatic
!
actuation of the RPS system occurred due to excessive feeding of the
steam generators; the licensee did not report the event to the NRC until
March 11', 1993.
This is a Severity Level IV Violation.
(supplement 1)
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DEC-10-1993 11:22
MILLSTONE RESIDENT OFFICE
203 443 5893,
P.11
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U.S. Nuclear Regulatory Commission
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B14486/ Attachment 2/Page 2
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June 7, 1993
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1.
The Reason For the Violation (Violation B)
'
The reason for the violation results from a' failure to specifically
identify to the user which items were required to be reset prior to
removing the bypass keys.
The importance of this step had not
specifically been clearly stated previously.
i
2.
The Corrective Stoos Taken and The Results Achieved (Violation B).
4
3.
In response to the conditions which resulted in the Notice of Violation,
4
change #2 to Revision 6 of SP-2401C was written and approved.
This
change added a precaution which identifies the results of the failure to
i
reset the high voltage bistable as the- initiator of a power trip test
,
4
interlock (PTTI).
The actuation of the PTTI results in tripping the
'
affected channel,
i ..
The second portion of the change calls for resetting the high voltage.
.
. bistable ' and Level I bistable, rather than the general reference to
3
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resetting alarms
and. bistables.
No previous problems with this
,
!
surveillance are known to have been experienced.
hith this change, no
l
future recurrence is anticipated.
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3.
The Corrective Stoos That Will Be Taken to Avoid Further Violations
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(Violation B)
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The Instrument and Controls (I&C) Department Manager will discuss this
j
event,
the Notice of Violation,
and the lessons learned with I&C
department personnel.
This discussion is expected to occur' before
.
June 30, 1993.
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4.
Ihe_Date When Full Como11ance Will Be Achieved (Violation B)
SP-2401C was changed and approved on April 13, 1993, therefore, full
compliance has been achieved.
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5.
Generic Imolications (Violation B)
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This event will be discussed with I&C Department personnel at Millstone
Unit Nos. I and 3 and the Haddam Neck Plant.
Actions will be taken as
- -
appropriate.
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MILLSTONE RESIDEN 0;F CE
203 M3 5893
P.12
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U.S. Nuclear Regulatory Commission
B14486/ Attachment 2/Page 3
June 7, 1993
1.
The Reason For The Violation (Violation c)
In reviewing the personnel actions associated with this event, it appears
that during performance of the event recovery actions, therc was.a less-
than-sufficient level of review. More attention was given to the reasons
i
for the cooldown event than to the results of the cooldown event.
The
operating shift members, knowing the . reactor was tripped based upon
events which had occurred earlier in the morning, focused their attention
on the causes of the cooldown and the appropriate actions necessary to
respond to the changing plant conditions. Once the cause of the cooldown
'
was determined
their review refocused to the level- of attention which
,
was required to prevent recurrence. The actions required to specifically
1
identify the occurrence, or cause, of an automatic actuation of the
reactor protection system (RPS). appear not to have been taken.
Rather,
,
it appears that the actions were based .on the belief that the event was
'
understood and all parameters had been addressed.
Thus, the RPS
actuation was unreported for 18 days.
Personnel
involved
in,
or
present' during, .these
actuations
were
interviewed, with the results of these interviews accurately rep
CombinedInspectionReport.{esented-
i
in Section 2.4 of the April 30, 1993,
2.
The corrective Steos That Have- Been Taken And The Results Achieved
(Violation C)
A review of the events which occurred during February 22 and February 23,
1
1993, was performed upon our discovery of the cited failure to report an
automatic actuation of the RPS.
As a result of this review, an
additional two RPS actuations were identified.
NNECO has determined that
neither of these two actuations is reportable pursuant to 10CFR50.72 or
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100FR50.73.
,
i
The NRC reporting requirements for the automatic actuation of the RPS
'
have
been discussed
extensively with
members
of the
unit
staff
responsible for the reporting of. these events.
Additionally, the
individual who was filling the role of On-Site Director -of Station
Emergency Operations (ODSED) has been counseled on his judgment during
,
this series of events.
Discussions pertaining to these events have been
extensive within the unit and have focused on the requirement to review
the control room journal as a necessary input for determining the
'
reportability of a specific event.
(2)
A. R. Blough to J. F. Opeka, " Millstone Combined Inspection 50-245/93-10;
50-336/93-06; 50-423/93-07, dated April 30, 1993.
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MILLSTONE RESIDENT OFFICE
203 443 5893
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U.S. Nuclear Regulatory Commission
B14486/ Attachment 2/Page 4
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June 7, 1993
3.
The Corrective Actions That Will Be Taken To Avoid Further Violations
>
(ViolationC)
The unit management will prepare and distribute a memorandum to Millstone
Unit No.
2 personnel .which will
further define expectations for
performance
in
the
lower
operational
modes
and
the ' operability
requirements of the RPS -while in Mode 3.
' This discussion will not be
limited
to
the Operations
personnel,
but
will
also
define
the
-
expectations for personnel performing surveillance testing.
Discussions
,
under this memorandum or an additional memorandum will be distributed to
the Unit Senior Operator Licensed personnel, as well as those personnel
,
who fulfill the role of ODSEO and Duty Officer, to highlight expectations
'
concerning the importance of timely event assessment and- classification
-
in accordance with existing Administrative Controls Procedures.
The caution statement, contained with E0P 2526, " Reactor Trip Recovery,"
will be reviewed to determine if it would be more appropriate as an
Action step.
The most appropriate location for this guidance, as either
a Caution or as an Action step, will be determined.
'
4.
The Date When Full Como11ance Will Be Achieved (Violation C1
The corrective actions, stated in section 3 will be completed by July 31,
1993, with the exception of any revision to E0P 2526 which, if required,
,
will be completed by December 31, 1993.
.
5.
Generic Imolications (Violation C1
This issue will be discussed with Engineering Department Management
)
personnel at Millstone Unit Nos. 2 and 3,
and the Haddam Neck Plant.
Actions will be taken as appropriate.
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DEC-10-1993 11:23
MILLSTOE RESIDENT OFFICE
203 443 5893
P.14
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Docket Nos. 50 245
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50-336
50-423
B14486
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Attachment 3
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Millstone Nuclear Power Station, Unit Nos.1, 2, and 3
Reply to Notice of Violations
Combined Inspection 50-245/93-10; 50-336/93-06; 50-423/93-07
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June 1993
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MILLSTONE RESIDENT OFFICE
203 443 5893
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U.S. Nuclear Regulatory Commission
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B14486/ Attachment 3/Page 1
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June 7, 1993
l
Millstone Nuclear Power Station, Unit Nos. 1, t'and 3
Reply to Motice of Violations-
[.
Combined Inspection 50-245/93-10 50-336/93-06: 50-423/93-07
i
self Assessment Groun Activities (Section 5.4)
.
Backaround
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The combined ' inspection report" (Section 5.4) included a detailed review of
the activities of groups that contributed to the overall self-assessment -
function at the Millstone Station.
Several different types of assessment
activities were inspected and discussed. The inspection report concluded that
,
the effectiveness of the self-assessment groups at Millstone Station varied.
.
The NRC' Staff found that, .although the Quality Services Department (QSD)
'
critically assessed plant and corporate performance and clearly. communicated
findings to management, chronic weaknesses in corrective action programs .and
4
compliance with administrative procedures existed.
The NRC Staff indicated
i
that this area of the report warranted NNECO's close attention.
Further, the
report invited our response if we either had questions or disputed the
,
findings.
This - attachment provides a discussion of NNECO's 'self-assessment
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activities at Millstone Unit Nos. 1, 2, and 3.
Immediate Action
NNECO has taken and will continue to take actions to improve performance in
this area.
The inspection report discussed the Corrective Action Request
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(CAR) 93-01, which QSD issued to NNECO management on March 3, 1993, to elicit
action.
In response, the Millstone Station Vice President issued two separate
memoranda, dated April 30, 1993.
Millstone Station Vice President Neporandum to NNEC0 Department Heads:
.
The first Millstone Station Vice President memorandum was sent to NNECO
,
Department Heads and discussed causes and actions to prevent recurrence.
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Three general causes of ongoing procedure noncompliance were identified.
1
These
were
ambiguous
or
conflicting
procedure
content,
insufficient
familiarity with procedural requirements, and
>ersonnel error.
The cause
associated with an individual- QSD Surveillance finding typically fell within
one or more of these categories.
The recurring nature of deficiencies
identified by the QSD Surveillances indicated that the identification of
causal
factors was not sufficiently accurate to allow the appropriate
corrective actions to be implemented.
If the causal factors were not well
understood, then actions to prevent recurrence could not- be successful.
The
,
(3)
A. R. Blough to J. F. Opeka, " Millstone Combined Inspection 50-245/93-10;
$0-336/93-06; 50-423/93-07, dated April 30, 1993.
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DEC-10-1993 11:25
MILLSTONE RESIDENT OFFICE
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U.S. Nuclear Regulatory Commission
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B14486/ Attachment 3/Page2
June 7, 1993
underlying
cause
of
recurring
procedure
noncompliance
was
inadequate
determination of the causal factors for QSD surveillance items.
One of the factors mentioned- above as contributing to certain procedure
noncompilance occurrences was .the existence of ambiguities or errors in some
procedures, especially Administrative Control
Procedures (ACPs).
In an
attempt to minimize the impact of this factor, a review was performed of
selected ACPs to identify problems that should - be corrected immediately.
These procedure changes are being expedited,
and will make procedure
compliance hss difficult.
It is recognized,
however,
that procedure
inadequa:, es still a potential causal factor for procedure noncompliances
identifiej by QSD Surveillances and other processes. The existin
effort will continue to implement long-term corrective measures. g ACP rewrite
To address the underlying cause of recurring deficiencies identified by. QSD
Surveillances,
station
personnel
were
instructed
to
improve
their
determination of the causal factors for these deficiencies.
This would be
done in two ways:
by processing and responding to each individual QSD
Surveillance finding in a more rigorous manner (described below), and by
evaluating trends in procedure noncompliance and work performance by analyzing
QSD Surveillance findings, Work Observation Program observations, and Plant -
Incident Report (PIR) data.
Following the identification of causal factors
and corrective / preventive' measures, follow-through is -required to assure
timely and effective completion of corrective / preventive actions.
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Processino of OSD Surveillance Findinos:
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Beginning May 10, 1993 all deficiencies identified by QSD Surveillances were
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required to be responded to in writing by the cognizant department.
These
responses would address the following: cause of the deficiencies, the generic
implications of the deficiency, immediate and/or long-term actions to correct
the deficient condition, and actions to prevent recurrence, including interim
measures, if appropriate.
Five working days before the response due date,
!
each response i s required to be forwarded to the cognizant Unit Director for
review.
Responses not meeting the above requirements will be rejected and
,
returned, with comments, to the submitting unit depart::ent head.
The Station
i
Vice President will be costed on each response to QSD, ano will review quality
,
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and timeliness.
Following a brief period for everyone to understand the
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process, the adequacy of these responses will be tracked and trended, for
consideration in the annual performa":e appraisal of all personnel in the
response preparation and approval chain.
Millstone Station Work Observation Procram
The Work Observation Program was initiated in September 1992.
It was
identified as a strength by the Institute of Nuclear Power Operations (INPO)
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during a recent Millstone Station evaluation.
It functions as a management
and worker tool that:
1) Reinforces work practice expectations; 2
Evaluates
work practices; 3) Directs supervisory involvement; 4) Provides a) process to
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U.S. Nuclear Regulatory Commission
B14486/ Attachment 3/Page 3
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June 7, 1993
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promptly correct deficiencies; 5) Provides management information to-monitor
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corrective action effectiveness.
Observations are conducted by department
.
heads and first line supervisors.
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Trendina of Work Observation Proaram Observations and Deficiencies Identified
by OSD Surveillances:
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The results of QSD Surveillances, the Work Observation Program, and PIRs.will'
be categorized and trended on a monthly basis.
This process is designed to.
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identify trends-in occurrences of siellar deficiencies.
A team composed of
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QSD, Nuclear Licensing, Unit ' representatives, and Program Services evaluate
the results and provide analysis and trend plots to De sartment Heads,
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-Directors, and the Station Vice President.
The conclusions w 11 be disetwed.
by Directors at the third department head-meeting of each month.. Action items
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will be assigned as necessary, .and controlled routings (CRs) issued for
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tracking.
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Millstone Station Vice President Memorandum to All Station Personnel:
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'The second Millstone Station Vice President memorandum was sent lto all
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Millstone Station personnel
to emphasize the. Station Vice President's
expectations for procedure compliance at Millstone-Station. A previous Notice
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of Violation and the recent CAR indicated that some station personnel were not
performing to' expectations regarding compliance with station ACPs.
The
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Station Vice' President's expectations are stated below.
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All personnel performing work at Millstone Station are expected to use
and comply with applicable procedures.
When questions relating to the
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adequacy or interpretation of procedures arise, the work must stop until
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the question is resolved by first-line supervision.
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First-line supervisors are exsected to assure that personnel Working
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under their direction have sufficient knowledge and understanding of the
procedures applicable to their work assignments.
They are also expected
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to assure that personnel adhere to the provisions of these procedures.
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Training, project briefings, and field observations should
be used to
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assure this expectation is understood and is being achieved.
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Department heads and Directors are expected to assure that the above
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expectations are met by direct observation by monitoring the Work
Observation Program and QSD Surveillances, and by other appropriate
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measures.
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The memorandum expressed that everyone should understand that the issue is
4
performance of personnel to standards and expectations.
All personnel must
understand what is expected of them, examine their. own performance, and
recognize the need for improvement.
It was emphasized that the above
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expectations must be met.
Each individual is accountable for his/her ~ own
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MILLSTOtE RESIDENT OFFICE
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U.S. Nuclear Regulatory Commission
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B14486/ Attachment 3/Page 4
June 7, 1993
performance, and supervisors are also accountable for the performance of their
subordinates.
In addition to these two Station Vice President memoranda, additional short .
term and long-term actions have been initiated.
Short-Term Actions
A task force review of approximately 30 ACPs was conducted to identify
compliance problems related to the ACPs.
As a result of the task force
review, six procedures were identified as requiring a change.
The proposed
procedure changes were based on:
(1) procedure clarity; (2) procedures with
which personnel have compliance difficulty;
(3)hanges
work observation-or QSD
surveillance-identified problems.
Procedure
c
are
currently
in
progress.
.
In addition, two global issues were identified. ' Specifically, ACP training is
essentially a repeat of the procedure steps rather than focusing on process
training;
i.e., train personnel on what the process is and how they fit into
that process, and how She ACPs support that process.
The second global issue
is a lack of a matrix that ties the procedure requirements to a position.
Lona-Term Actions
A new work process improvement effort is currently in progress.
It is
!
expected to result in:
1) Integrated work teams; 2) Improved work . scope
change process; 3) Fewer interface points; 4) Improved communications; and 5)
Streamlined documentation.
The Stop Think Act Review (STAR) Program is a Self-Check Program. The program
will be applied to all working groups at Millstone Station.
Booklets have
been printed and are ready for distribution. NNECO management is treating the
Self-Check Program as a philosophy, i.e., the program itself may require only
brief initial training, while its concepts will be incorporated into-training
presented by the training department in formal training.
This would include
new employee training, annual general employee training, technical staff
management training, technical training, and operator training. . Currently,
the training department has incorporated the process into certain sessions
including Millstone Unit No. 1 Operator Training.
Department heads and
supervisors will reinforce self-checking expectations in department meetings
and tailboard sessions.
By using the weekly station meeting, newsletters from the Station Vice
President, Millstone Target Vision, and posters and -booklet distribution,
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NNECO management plans to introduce the program to all Millstone workers,
including contractors.
The depth of training for initial presentation of the
'
program is currently being detemined.
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MILLSTONE RESIDENT OFFICE
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U.S. Nuclear Regulatory Commission-
B14486/ Attachment 3/Page 5
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June 7, 1993
Conclusion
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NNECO management recognizes the need to improve self-assessment corrective
action programs and compliance with administrative arocedures.
We have taken
,
immediate action in the form of the two station Vice President memoranda to
explicitly communicate expectations.
. Additional short-term and long-term
actions are expected to reinforce these expectations. ' QSD and line management
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have recently seen improvement. The surveillance information and deficiencies:
1
have become more clear and well focused, allowing corrective actions to be
more appropriately determined.
We are optimistic that the sum of these
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actions will continue- to be instrumental in strengthening this identified
weakness.
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TOTAL P.19
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MILLSTONE RESIDENT OFFICE
203 443 5893
P. 02 -
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' APPLICATION FOR A REPLY IErlER
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go . %%to
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Docket No(s)
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F. Opc Sw
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Licensee's Name:
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Subject:
Inspection N ' ME '9 b ' 5
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Combined Inspection
so . W2 %
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(if more
than one iannetian)
Fmydot Selection:
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Use this Standard I.etter:
Paragraph No.
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This letter refers to your 9'l 0 9b+ndence, in response to
our 9 2 L '9b letter. (Enter appropriate dates)
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Thank you for informing us of the corrective and preventive actions
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documented in your letter. These actions will be examined during a
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future inspection of your licensed program.
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Your cooperation with us is aporeciated.
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Sincerely,
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Use the standard letter, but insert the following text as Paragraph
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(Please number paragmphs).
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In your verponse to the Motice of Ylolation regarding failure to restore the
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reactor building closed cooling water radiation monitor to nervice properly
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following surveillance testings you noted an apparent miscommunication between
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.the plant equipment operator and the control room operacions statf over the
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status of the radiation monitor and focused your corrective action on the
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plant equipment operator's performance. We note that the correct status of.
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the radiation monitor was' communicated to the control room statf and, on more
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than one occasion, was properly indicated in the plant equipment operator's
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rounds logs which are reviewed periodically by shift supervisory personnel.
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We are concerned regarding the apparent performance deficiencies on the part
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of operations shift supervision revealed by this evente and request that you
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inform us of any corrective actions which you may have taken to address thess
.w.
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deficiencies.
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itegion I Form 13
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(Revised October,1992)
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