ML20035F237
| ML20035F237 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/14/1993 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9304210070 | |
| Download: ML20035F237 (2) | |
See also: IR 05000245/1992022
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APR 141993
Docket No.
50-245
50-336
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50-423
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Mr. John F. Opeka
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Executive Vice President - Nuclear
Northeast Nuclear Energy Company
P. O. Box 270
Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
,
SUBJECT: COMBINED INSPECTIONS 50-245/92-22,50-336/92-25 AND 50-423/92-20
This refers to your letter dated November 25,1992, in response to our letter, dated
October 16, 1992.
,
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection cf your licensed program.
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Your cooperation with us is appreciated.
)
Sincerely,
original Signed By
A. Randolph Blough, Chief
Projects Branch No. 4
Division of Reactor Projects
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9304210070 930414
ADOCK 05000245
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APR 14 E3
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Northeast Nuclear Energy Company
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cc:
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W. D. Romberg, Vice President - Nuclear, Operations Services
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S. E. Scace, Vice President, Millstone Station
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H. F. Haynes, Nuclear Unit Director
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J. S. Keenan, Nuclear Unit Director
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F. R. Dacimo, Nuclear Unit Director
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R. M. Kacich, Director, Nuclear Licensing
G. H. Bouchard, Director of Quality Services
Gerald Garfield, Esquire
Nicholas Reynolds, Esquire
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector
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State of Connecticut SLO
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bec:
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Region I Docket Room (with concurrences)
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J. Joyner, DRSS
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R. Blough, DRP
L. Doerflein, DRP
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W. Raymond, SRI, Haddam Neck
P. Swetland, SRI, Millstone
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V. McCree, OEDO
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J. Anderson, NRR
DRS/EB SALP Coordinator
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R. Barkley, DRP
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NOV-25-92 WED 18:10'
Gen. Faei1. Lieensins
FAX NO. 20? 665 5896
P. 02
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NORTHEAST UTILITIES
c,nem ou . see , sm1. smn, connw%1
we me :n-s u.: nw :c+m.
HARTFORD. CONNECTICUT 06141-C270
emn$271,,.
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November 25, 1992
Docket Nos. 50-245
50-336
B14292
Re:
U.S. Nuclear Regulatory Commission
Attention: Document Control Oesk
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Washington, DC 20555
Gentlemen:
Millstone Nuclear Power Station, Unit Nos. I and 2
Reply to a Notice of Violation
Inspection Report Nos. 50-245/92-22;50-336/92-25;
and 50-423/92-20
,
On October 16, 1992,* the NRC Staff transmitted the results of a safety inspection
Nuclear Power Station from July 26, 1992, threugh
the Millstone
The NRC Staff identified two Severity Level IV violations for
conducted at
September 7,1992. Millstone Unit No. I and one Severity Level IV violation for Millstone Un
As required by 10CFR2.201, Attachment I describes in detail the reasons associated
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with the violations, the corrective steps that have been and will continue to be
taken to avoid further violations, and the dates when full compliance was achieved.
This reply is being forwarded 30 days from the date of receipt, as was agreed by
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Northeast Nuclear Energy Company (NNECO) and the NRC Staff during a telephone
'
conversation on November 12, 1992.
It should be noted that in addition to the attached response to violation "C",
is conducting further assessment of this situation in order to confirm that the
corrective
actions
identified will
provide
adequate
assurance
that
similar
violations will not occur.
NNECO will provide the Staff with any pertinent
information resulting from this additional review.
,
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[
A.
R.
Blough letter to J.
F.
Opeka, tillstone Combined Inspection
(1)
50-245/92-22;50-36/92-25;50-423/92-20," dated October 16, 1992.
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Gen. Facil. Licensing
FAX NO. 203 665 5896
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Document Control Desk /Page 2
November 25, 1992
If you have any questions regarding the information contained in this letter, please
contact us.
Very truly yours,
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NORTHEAST NUCLEAP ENERGY COMPANY
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FOR: J. F. Opeka
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-Executive Vice President
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BY:
4Mm
E. A. DeBarba "
Vice President
cc:
T. T. Martin, Region I Administrator
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J. W. Andersea, NRC Acting Project Manager, Millstone Unit No. I
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G. S. Vissing, NRC Project Manager, Millstone Unit No. 2
P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2 and 3
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FAX NO. 203 665 5896
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Docket Nos. 50-245
50-336
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B14292
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Attachment 1
Hillstone Nuclear Power Station, Unit Nos. I and 2
Reply to a Notice of Violation
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November 1992
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NOV-25-92 WED 18:11
Gen. Facil. Licensing
FAX NO, 203 665 5896 _
P.05
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U.S. Nuclear Regulatory Commission
B14292/ Attachment 1/Page 1
hvember 25, 1992
Millstone Nuclear Power Station, Unit No. I and 2
Reolv to a Notice of Violation
A.
Description of Violation
Criterion VII
(Control
of Purchased Material,
Equipment, and Services) drequires, in part, that measures be established
to assure that purchase
services conform to purchase requirements.
These measures shall
include provisions for source evaluation and
selection, and examination of products upon delivery.
Nuclear Engineering
and Operations
(NED)
Procedure 6.02,
" Quality
Purchase Requisitions," Section 6.5 requires, in part, that services be
procured on a quality purchase requisition when the service is applicable
to safety-related equipment. Quality Services Department (QSD) Procedure
3.02,
" Supplier
Evaluation," Section 6.1
requires,
in
part,
that
procurement vendor services personnel perform an evaluation of a supplier
when a need is established for use of a supplier not on the approved
supplier list.
Contrary to the above,
during July and August
1992,
a purchase
requisition was not issued prior to using engineering service procured
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' rom Saul Levy Incorporated (SLI) to perform analyses on safety-related
- ystems and components.
Additionally, procurement vendor services had
not performed an evaluation of SLI prior to NRC identification that SLI
was not listed on NNECO's approved supplier list.
This is a Severity Level IV Violation (Supplement I).
This violation
applies to Unit 1 only.
1.
Reason for the Viola _ tion
A root cause investigation revealed that inadequate understanding
of, and adherence to, Northeast Utilities (NU) purchase order review
and approval process requirements, which are outlined in NEO 6.02,
was the reason for the above violation.
Adherence to NEO 6.02 and
appropriate processing of the required purchase order would have
resulted in conduct of the necessary inspection / surveillance / audit
of SLI during performance of the actual work, per Section 6.1.3.
With regard to the portion of the violation which cites QSD
Procedure 3.02 as having been improperly implemented, it should be
noted that it was not NNECO's intention to place SLI on the ap3 roved
supplier list, but to utilize SLI's services on a one-time
) asis,
QSD Procedure 3.02 is only applicable when a supplier is intended to
be placed on the approved supplier list, and, therefore, was not
implemented.
As such, NE0 6.02 was the appropriate procedure to be
followed
in this
situation.
QSD-2.03
entitled,
" Performance
Reporting and Follow-up of Surveillance Activities," was employed
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FAX NO. 203 665 5896
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U.S. Nuclear Regulatory Commission
B14292/ Attachment 1/Page 2
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November 25, 1992
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prior to the start of work in order to assess the vendor's
capabilities.
Results were provided in Surveillance Report S05620,
completed on July 16,
1992 and recommended that a follow-up
inspection / surveillance / audit be conducted during the period when
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actual work was being performed.
As noted above, proper adherence
to NE0 6.02 would have assured that this activity took place.
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2.
Corrective Steos Taken and Results Achieved
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On August 10, 1992, it was discovered that the follow-up activity,
recommended per Surveillance Report 505620,
had not yet been
conducted at SLI.
Immediately following this discovery, a quality
assurance audit was arranged for and conducted by Northeast
Engineering and Quality Services
Utilities Service Company's (NUSCO)dquarters in Campbell, California
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Department personnel at the SLI hea
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on August 11 and 12, 1992.
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On August 10, 1992, directly following identification of the above-
,
mentioned situation, it became evident that there was no purchase
,
order for the ongoing SLI work.
Purchase Requisition E-59830 was
immediately
issued
and
followed
by
Purchase
Order 238359
on
August 12, 1992.
In parallel, a satisfactory audit was completed at
SL1 to verify the necessary requirements.
It should be noted that
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no modifications to operable plant equipment were made and no credit
was taken for work performed by SLI prior to satisfactory completion
of this audit.
3.
Corrective Steos Taken to Prevent Future Violations
This violation was discussed at the Nuclear Engineering Services
Division staff meeting and at the monthly Engineering Department
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meeting, with the
intention of notifying
individuals
of the
importance of strict adherence to procedures.
Corrective Action
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Request 92-08 was initiated on August 12, 1992 by the Director of
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the Quality Services Department to investigate the circumstances
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surrounding this situation.
The Corrective Action Request was
completed on October 20, 1992.
A root cause investigation was also
completed by NUSCO Electrical, and Instrumentation and Control
Engineering Departments on September 30,
1992.
Based on the
information and conclusions derived from the Corrective Action
Request 92-08 and the Root Cause Investigation Report, a Procedure
,
Action Request has been initiated to revise NEO 6.02 to help
alleviate any possible misunderstanding of the
provisions of
NEO 6.02. This is targeted to be completed by the end of June 1993.
Additionally, the Nuclear Training Department has been made aware of
this situation and will determine whether changes to existing
procurement process training are appropriate.
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Gen. Facil, l.icensin
FAX NO. 203 665 5896
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November 25, 1992
4.
Date When Full Comoliance will be Achieved
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Full compliance with existing NU purchase order requiremeats was
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achieved on August 12, 1992, upon completion of the supplier audit
of Saul Levy Incorporated and subsequent issuance of Purchase Order
238359.
5.
Generic Imo11 cations
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A memorandum from the Executive Vice President will be distributed
to all Nuclear Engineering and Operations personnel stressing the
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importance of adherence to purchasing requirements.
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Description of Violation
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B.
The Millstone Nuclear Power Station Physical Security Plan, Revision 16,
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dated March 1992, Section 11.5,
" General Construction Activities,"
requires,
in
aart, that when large equipment movement and other
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construction-related activities take- place within protected- or aital
areas, compensatory measures are to be taken to assure security is not
diminished. These con:pensatory measures include the use of watchmen for
surveillance, closed circuit television, escorts, and other temporary
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cordons.
Contrary to the above, for a period of about 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> between August 8
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and August 11, 1992, the licensee failed to establish and maintain
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adequate compensatory measures for the extended vital area boundary in
Unit 2.
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This is a Severity level IV Violation (Supplement III).
This violation
applies to Unit 2 only.
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1.
Reason for Violation
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The reason appropriate compensatory security measures were not
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adequately maintained around the extended vital area boundary at
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Millstone Unit No. 2 is attributed to the failure of the security
officers and field supervision to effectively monitor and respond to
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the changing
events
associated with the
unusual
vital
area
configuration.
Post orders given by security supervision in the
above scenario did not specifically identify the field of view for
each compensatory post, so that when equipment movement obstructed
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the view, individual officers assumed the area in question was
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visible from another location.
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2.
Corrective Steos Taken and Results Achieved
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An
additional
security
officer
was
immediately
posted,
as
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appropriate, when the violation was identified.
The expanded vital
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B14292/ Attachment 1/Page4
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November 25, 1992
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area boundary was in the process of being restored to the normal
configuration at the time of discovery.
The restoration was
,
completed within an hour.
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A joint search of all non-contaminated areas in the Millstone Unit
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No. 2 containment building was conducted by Security and Operations
Department personnel. No unauthorized activities were detected. At
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the time of this event, the unit was in Mode 6 with the core off-
loaded, and there was no equipment in the containment building that
could be considered vital for protection of the plant or public
health and safety.
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3.
Corrective Actions Taken to Prevent Future Violation 1
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Security post orders were rewritten to include specific details to
eliminate any potential inadequacies prior to expanding the vital
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area boundary for the Unit No. 2 steam generator replacement
activities.
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Memoranda were issued to all licensee and contractor security
supervisory personnel involved in the violation.
A review of the
event
and
a
restatement
of their performance
standards
and
.
expectations was included. This was completed on August 26, 1992.
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An instructional guide was issued to all
security contractor
supervisory
personnel
delineating
the
requirements
and
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responsibilities associated with conducting security officer post
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inspections. This was completed on August 26, 1992.
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A revision to contractor security supervisory personnel rotation
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schedule was implemented.
This revision created a dedicated field
supervisor to conduct post / officer inspections for the entire
duration of each shift.
Prior to this change, the field supervisor
position rotated four (4) times a shift.
This change was initiated
on August 26, 1992.
The process for creating and changing security post orders was
modified.
Security Department Instruction Ill, " Post Orders tog,"
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has been modified to delineate the specific actions required for
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post order creation / changes.
This instruction requires a review by
the Security Department Administrative Review Committee prior to
implementing changes, except in exigent circumstances.
Emergency
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changes require the security shift supervisor and security shift
commanding officer, at a minimum, to approve changes, with a follow-
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up review by the Administrative Review Committee.
This change was
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completed on October 15, 1992.
A memorandum was issued to all security personnel, detailing the
event
and reemphasizing the need
to maintain vigilance
and
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November 25, 1992
attentiveness while on duty and to maintain a questioning attitude
This was completed on
about the effectiveness of security measures.
November 6, 1992.
Date When Full Como11ance Will Be Achieved
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4.
Full compliance to Hillstone Nuclear Power Station Physical Security
Plan, Revision 16, was achieved on August 11,
1992, upon the
imediate posting of additional security officers at the expanded
vital area boundary,
5.
Generic Inclications
NNECO will convey the lessons learned from this violation to the
Security Department at the Haddam Neck Plant.
C.
Description of Violation
10CFR50 Appendix B, Criterion III (Design Control) requires that measures
be
established for the
selection and
review for
suitability of
application of materials, parts, and equipment that are essential to the
safety-related functions of the structures, systems, and components.
The Northeast Utilities Quality Assurance Program, Paragraph 3.2.1,
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requires that standard "off the shelf" commercial or previously approved
items essential to the quality functions be selected and reviewed for
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suitability of application.
Administrative Control Procedure (ACP) QA-4.03A, " Upgrading Spare Parts
for Use in QA Application - Commercial Grade Item Procurement and
Dedication," implements the above and delineates the requirements for the
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specification, procurement, acceptance, and handling of the procurement
and dedication of commercial grade items for safety-related applications.
ACP-QA-4.03A requires that Standard Form 1417 be completed documenting
the dedication evaluation, including identifying critical characteristics
and acceptance methods for verifying critical characteristics.
Contrary to the above,
The new commercial grade motor and gearbox, installed on the 'A'
emergency service water strainer (ESW) in September 1991, were not
dedicated,
as
required by
procedure ACP QA-4.03A,
prior
to
installation.
The replacement strainer body, installed in the "A" train of ESW in
August 1991, was accepted based on an inadequate dedication in that
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the commercial grade pressure boundary materials and weld wire used
in fabricating the strainer body were accepted without verifying the
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FAX NO. 203 665 5896-
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validity of the commercial grade certified material test reports as
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required by procedure ACP-QA-4.03A.
This violation
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This is a. Severity Level IV violation (Supplement I).
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applies to Unit I only.
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1.
Reason for the Violation
The reason for the lack of proper dedication of the ESW
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strainer motor and gearbox prior to installation, was failure
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of the personnel
involved
in the
dedicated process
to
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adequately follow the requirements of procedure ACP QA-4.03A.
NU's program addressed the direct procurement of Nuclear
,
items, however, it did
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Operation Defective Items List (N0DIL)for NODIL items being
not provide any specific guidance
As a result of
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provided by a second or tnird tier supplier.this inspecti
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(although minor) path for unacceptable materials intrusion into
!
the nuclear plants.
NU's source inspection and receipt
,
>
procedures
require
inspection
for
signs
of
,
fraudulent items and provide guidelines for the identification
inspection
of fraudulent items established by the NUMARC Procurement
.
Initiative.
to material dedication inadequacies identified
With respect
during the inspection, NNECO believes that the actual measures
suitability 'of application met ANSI N18.7
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provisions
and,
therefore,
satisfied
10CFRSO
Appendix
B
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taken to assure
<
Specifically, from July 19 - 27, 1991, NUSCO
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104787
requirements.
Procurement Vendor Services conducted Source Inspection
at S. P. Kinney of Carnegie, Pennsylvania, per the provisions
,
of Purchase Order 936538.
The scope of this activity was to
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that the
items
being procured were
supplied
in
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An inspection plan
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ensure
accordance with the specified requirements.
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was
generated
utilizing
the
purchase
order,
referenced
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This
standards, and Commercial Grade Dedication Form MPI-0740.
method of vendor control is governed by 10CFR50 Appendix B,
through the NU Quality Assurance Program Topical Report and
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1mplementing Procedure QSDI-PR-1.02, as well as ACP QA-4.03A.
As specified in the dedication plan, material was identified as
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a critical characteristic.
Verification of this attribute was
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based on a review of certified material test reports against
the material specification combined with a programmatic review
This
to assure that the vendor controlled his sub-suppliers.
P. Kinney
was done through an evaluation of applicable S.
audits, material control, and inspection practices to ensure
all materials associated with the manufacturer of the strai
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November 25, 1992
were acceptable. No unsatisfactory conditions were identified.
Consaquently, reasonable assurance was attained, and no further
validation was deemed necessary.
2.
Corrective Steps Taken and Results Achieved
NCR 1-92-156 documents the acceptable commercial upgrade of the
replacement motor and gear box.
The NCR verified that the
analysis
and
inspection
previously
performed
during
the
installation of the new motor and gear box, per PDCR l-240-91,
satisfied the key elements of the commercial grade dedication
process.
NCR l-92-157 was initiated to provide further assurance of the
ESW strainer flange material because this was the only material
identified as being supplied by a NODIL vendor.
3.
Corrective Steps Taken to Avoid Future Violations
NEO 6.11 entitled, " Commercial Grade Items" was revised and
beca~ effective on July 1,1992.
This procedure now requires
ti,
il dedication activities be controlled by the Procurement
Ers.neering Department. The Procurement Engineering Department
is fully cognizant of the requirement of ACP QA-4.03A.
Implementing procedures governing both source inspections and
receipt inspection have been revised to provide guidance for
NUSCO inspectors to investigate / evaluate materials from third
party sources with respect to the N0DIL.
4.
Date When Full Compliance Was Achieved
Full compliance was achieved when NCR l-92-156 and NCR 1-92-157 were
dispositioned
on
September 22,
1992,
and
Septenber
4,
1992,
respectively.
5.
Generic Imolications
Ongoing assessments of this incident will address any associated
generic implications.