ML20134M759
| ML20134M759 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/20/1996 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9611260033 | |
| Download: ML20134M759 (3) | |
See also: IR 05000245/1996005
Text
-
-
-
.
.
.
.-
.
..
s,.
.
4'
November 20, 1996
Mr. Bruce D. Kenyon
President and Chief Executive Officer
Northeast Nuclear Energy Company
c/o Terry Harpster
P. O. Box 128
)
. Waterford, Connecticut 06385-0128
SUBJECT:
MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3, INSPECTION
REPORT NOS. 50-245/96-05; 50-336/96-05; 50-423/96-05
i
Dear Mr. Kenyon:
l
This letter refers to your September 16,1996 correspondence, in response to our August
15,1996 letter.
'
Thank you for informing us of the corrective and preventive actions documented in your
i
letter.- These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
ORIGINAL SIGNED BY:
Jacque P. Durr, Chief
Special Projects Office, RI
Docket Nos. 50 245; 50-336;50-423
cc:
T. C._Feigenbaum, Executive Vice President - Chief Nuclear Officer
J. McElwain, Unit 1 Recovery Officer
M. Bowling, Jr., Unit 2 Recovery Officer
J. Cowan, Unit 3 Recovery Officer
D. M. Goebel, Vice President, Nuclear Oversight
J. K. Thayer, Recovery Officer, Nuclear Engineering and Support
P. D. Hinnenkamp, Director, Unit Operations
H. F. Haynes, Director, Nuclear Training
P. M. Richardson, Nuclear Unit Director, Unit 2
M. H. Brothers, Nuclear Unit Director, Unit 3
J. F. Smith, Manager, Operator Training
F. C. Rothen, Vice President, Work Services
2,'
L. M. Cuoco, Esquire
i
2, G d. R. Egan, Esquire
'-
O28
\\
\\
9611260033 961120
ADOCK 05000245
G
e
-
.- .-
.
. . - . _ _ .
- . . . - - - . - . . . . . . .
. . - . - . . - . . . -
- - . . . . . . -
_ _ .
i
.
r
.
M.
~
i
..
.
]
Mr. Bruce D. Kenyon
2
j
- cc w/cv of Licensee's Resoonse Letter:
State of Connecticut SLO Designee
i
l.
V. Juliano, Waterford Library
,
{
S. B. Comley, We The People
-
J.' Buckingham, Department of Public Utility Control
1
,
!
4
I-
l
t
lt
t
i
i
.a
!
4
,
a
)
4
j
!
,
1
)
., .< .
l
.
Mr. Bruce D. Kenyon
3
Distribution w/cv of Licensee's Response Letter:
Region i Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
PUBLIC
NRC Resident inspector
M. Kalamon, SPO, RI
D. Screnci, PAO, RI
N. Sheehan, Field-PAO, RI
W. Dean, OEDO
P. McKee, Director, Deputy Director of Licensing, SPO, NRR
G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR
L. Plisco, Chief, SPO, NRR
l
D. Mcdonald, SPM, SPO, NRR
inspection Program Branch (IPAS)
<
l
1
DOCUMENT NAME: G:\\ BRANCH 6\\REPLYLTR\\96-05.RPY
To receive a copy of this document, indicate in the box: "C" = Copy without
attachment / enclosure
"E" = Copy with attachment / enclosure
"N" = No copy
OFFICE
Rl/SPO
Rl/SPO
/
/
NAME
Blumberg W
Durr FM-
DATE
11(M96 g
11#496
V
OFFICIAL RECORD COPY
T1m
_ _ . ~ - .~
..- .- -
--
- - - - - - - - - -
-
- - - -
-
.-
.
-
- *
~
~
1
.,
.
.
.
..
L
i 7 s.ta.o ser c, s nio, cT 06037
>
'
- NdM
, .
- Utilities System
vonbe utaicie.s.rm. comp.oy
>
P.O. Box 270
,
H rtford, CT 061410270
(203) 665-5000
4
,
SEP161996
Docket No. 50-423
i
B15884
i
i
!
Re:10CFR2.201
!
'
,
U.S. Nuclear Regulatory Commission
)
i
Attention: Document Control Desk
Washington, D.C. 20555
e
J
Millstone Nuclear Power Station, Unit No. 3
4
h
. Reply to a Notice of Violation
insoection 50-245/96-05: 50-336/96-05: 50-423/96-05
- .
In a letter dated August 15,1996,' the NRC transmitted the results of a safety
l
Inspection conducted at Millstone Station on May 7,1996 through June 26,1996. The
1
j
inspection concluded that certain of our activities appeared to be in violation of NRC
j
requirements. Specifically, Millstone Unit No 3 was cited for one violation for failure to
j
j
audit- Technical
Specification
(TS)
Section
6.8.4.e,
" Accident
Monitoring
j
instrumentation", within a five year period. This should have been performed during
Audit A223063, dated October 1994.
i
On behalf of Millstone Unit No. 3, Attachment 1 of this submittal provides Northeast
Nuclear Energy Company's (NNECO's) reply to the violation, pursuant to the provisions
of 10CFR2.201.
.l
J
j -
The following summarizes NNECO's commitments made within this letter:
.
4
4
B15884-01: Technical Specification section 6.8.4 ((a) through (e]) has been added to
j
the scope of the next scheduled Technical Specification Audit (A21073) to ensure that
j
this item is properly evaluated. The audit is scheduled to start on September 30,1996
i
and will be completed on October 31,1996.
i
3
B15884-02:
An evaluation of the audits of the Millstone Unit No. 3 Technical
Specifications since 1991 will be conducted to determine if all required sections have
been adequately audited. Audits will be performed of TS sections as required. This
review and follow-up corrective actions will be completed by October 31 for Millstone
l
'
Unit No. 3. A similar review of the audit program will be completed for Millstone Unit
Nos.1 and 2, and Connecticut Yankee. The reviews for Unit Nos.1 and 2 will be
a
5
I
NRC letter dated August 15,1996, "NRC Combined Inspection 50-245/96-05;
'
50-336/96-05; 50-423/96-05 and Notice of Violation," W. D. Lanning to T. C.
Feigenbaum,.
,_
WY2 i c lW'
t
- . --
- - - -
.- - .
. - - - .-
- - . _ .
..
-
-
.-
.-
i
-
-
.
.
.
.
U.S. Nuclaar Regulatory Commission
B15884\\Page 2
.
- completed prior to December 31, 1996.
The Connecticut Yankee review will be
completed prior to re-start from their current outage.
B15884-03: The process for the indeper. dent review of "The TS Audit Matrix" will be
revised to require a review of what "has been done" versus "what has been scheduled".
J
In the future, personnel will enter information into the tracking database after the audit
has been cumpleted and after the independent reviewer has checked "what has been
done". Procedure QAS 2.13 will be revised by October 31,1996.
j
- B15884-04: A root cause evaluation will be performed to address this violation, and
related deficiencies identified in the audit program. This root cause evaluation will be
completed by. October 31,1996.
Should you have any questions regarchig this, please contact Mr. William J. Temple at
(860)437-5904.
Very truly yours
NORTHEAST NUCLEAR ENERGY COMPANY
FOR: T. C. Felgenbaum
Executive Vice President and
Chief Nuclear Officer
BY:
(h
& E.Scae6
Vice President- Nuclear
l
cc:
H. J. Miller , Region 1 Administrator
V.L. Rooney, NRC Project Manager,' Millstone Unit No. 3
W. D. Lanning, Director Millstone Assessment Team
T. A. Eastick, Senior Resident inspector, Millstone Unit No.1
P. D. Swetland, Senior Resident inspector, Millstone Unit No. 2
A. C. Cerne, Senior Resident Inspector, Millstone Unit No. 3
'
W. J. Raymond, Senior Resident inspector, Connecticut Yankee
o
,
h
t
a
_
.
_
o
.
-
-
.
,,
,
,
--
-
,
.
Docket No. 50-423
B15884
Attachment 1
Millstone Nuclear Power Station, Unit No. 3
Reply to a Notice of Violation
Inspection 50-245/96-05; 50-336/96-05; 50-423/96-05
i
l
y
1
]
September 1996
j
c(
<
_ _ .
_ _ _
_
_ _ -.._ __ _ _
._ _ _ _.___ ._ . . _ _. _ . _ -
t
..
.-
_
-
-
.
,
,
.
U.S. Nuclear Regulatory Commission
'
B15884\\ Attachment 1\\Page 1
1
-
i
f
Restatement of Violation
i
Unit No. 3 Technical Specification (TS) 6.5.3.7, requires, in part, that Nuclear Safety
L
Assessment Board audits shall be performed at least once per 24 months in
[
accordance with Nuclear Group Procedures (NGP) snd shall encompass the
l
conformance of unit operation to provisions contained within the techaical
specifications and applicable license conditions. Procedure NGP 2.02, " Nuclear Safety
'
j
Assessment Board", requires that over a five year period, all items contained within TS
sections will be audited.
Contrary to the above, TS section 6.8.4.e, " Accident
.
Monitoring Instrumentation," was not audited within a five year period.
'
This is a Severity Level IV Violation (Supplement I)
!
![
Reason for the Violation
j
NNECO agrees with this violation which was identified by the NRC in that section
6.8.4.e of the Millstone Unit No. 3 TS was not audited during the past five years. In
j
addition, our investigation of the violation identified that none of the sections of 6.8.4.
l
((a) through (e]) were audited during the past five years.
!
The investigation determined that the following causes contributed to this violati-on:
c
l
1.
Ineffective Communication
The Audit Team Leader (ATL) did not clearly communicate that the Technical
3
Specialist was responsible for evaluating all sections of TS 6.8.4.
The
1
i
investigation determined that the ATL was properly trained and understood the
i
!
requirements of the audit process (QAS procedure 2.13, " Planning, Scheduling,
.
l'
Performance, Reporting, and Follow-up.of Assessment Services Audits"), but
)
!
failed to advise the Technical Specialist of his responsibility.
j
'i
2.
Inadeauste Review of the Audit Packaae/ inattention to Detail
The Audit Team Leader did not ensure completion of the audit checklist
.
!
performed by the Technical Specialist. The ATL is responsible for ensuring that
all portions of the checklist are completed and that justification is provided for
.
i
those portions of the checklist which were not evaluated. The checklist item for
TS 6.8.4 was not completed and no justification was provided for the lack of
objective evidence as required by the audit procedure. The investigation verified'
[(
,
l
that the ATL was knowledgeable of his responsibilities.
!
$
'
j
3.
Ineffective Audit Trackina Process
,
i
The TS Audit Tracking process is used to schedule required areas for TS audits.
1
TS sections required to be audited are entered in a tracking program with the
audit number and audit schedule start date prior to the actual start of the audit.
,
This information is not updated with actual audit information. The output from
.-
- . - .
.
_
.
.
.
--
-
i
.,
.
p;.,'
-
-
U.S. Nuclear Regulatory Commission
'
.;
..~
B15884\\ Attachment 1\\Page 2
the program, "The TS Audit Matrix," does not provide the actual start date of the -
audit or what was actually audited.
o
4.
Inadeauate Corrective Action From Unresolved item (URI 423/94-01-05.
Adeauacy of Technical Specification Audits - Unit No. 3)
To prevent recurrence of missing'TS sections required to be audited, NU
committed to having a technical reviewer independently review "The TS Audit
Matrix" to ensure TS sections are audited on the required frequency. This
. review verifies that all TS sections are being appropriately scheduled for audit.
However, as discussed above this process does not provide assurance that the
]
TS sections are actually audited. The investigation determined this corrective
action to be ineffective in preventing recurrence of the problem since it did not
properly address the causal factors associated with the violation (i.e., problems
with implementation of the TS Audit Matrix and personnel error)
Corrective Steps Taken and Results Achieved:
,
l
Technical Specification section 6.8.4 has been added to the schedule of the next
.
Technical Specification Audit (A21073) to ensure that .this item is properly
evaluated. The audit is scheduled to start on September 30, 1996 and will be
completed by October 31,1996.
The Audit Team Leader was counseled on the importance of effective
.
communication of audit assignments to the Technical Specialist during the
1
performance of an audit. In addition, the lessons learned from this event were
i
shared with the audit group regarding the audit procedure, management
expectations, their responsibilities and authority, and the importance of adhering to
procedural and regulatory commitments.
Corrective Steps That Will Be Taken to Avoid Further Violations:
An evaluation of the audits of the Millstone Unit No. 3 Technical Specifications
.
,
since 1991 will be conducted to determine if all required sections have been
adequately audited. Audits will be performed of TS sections as required. This
review and audit will be completed prior to the re-start of Millstone Unit No. 3. A
similar review of the audit program will be completed for Millstone Unit Nos.1 and 2
and Connecticut Yankee. The reviews for Units 1 and 2 will be completed prior to
'
December 31,1996. The Connecticut Yankee review will be completed prior to re-
start from their current outage.
The process for the independent review of "The TS Audit Matrix" will be revised to
require a review of what "has been done" versus "what has been scheduled." In the
future, personnel will enter information into the tracking database after the audit has
.--
-
-.
. ,
.
, ,
.
-
. .
-
U.S. Nucinar Regulatory Commission
.
B15884\\ Attachment 1\\Page 3
'
been completed and after the independent reviewer has checked "what has been
done". Procedure QAS 2.13 will be revised by October 31,1996.
Initiatives are underway to improve Millstone's corrective action program which will
.
result in improved root cause determinations and corrective actions to prevent
recurrence of the issue.
Of specific note, root cause evaluations are being
performed for notices of violation. A root cause evaluation was added to the
requirements for follow-up of this violation. The evaluation will address the violation
and related deficiencies identified in the audit program. This will be completed by
October 31,1996.
Northeast Utilities is performing an evaluation of the current method of performing
Technical Specification audits to determine the value of a performance based
auditing approach versus the current line item compliance based approach. It is
expected that this evaluation will be completed by December 31,1996.
'
}
Date When Full Compliance Will Be Achieved:
- .
Millstone Unit No. 3 will be in full compliance by October 31,1996 after TS section
j
6.8.4 is audited during the next Technical Specification Audit.
h
4
i
Y
g
.
?