ML20151P168

SALP Rept 50-423/85-99 for Sept 1984 - Aug 1985

ML20151P168
Person / Time
Site:	Millstone
Issue date:	11/04/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151P154	List: ML20151P149 ML20151P168
References
50-423-85-99, NUDOCS 8601030319
Download: ML20151P168 (48)

See also: IR 05000423/1985099

Text

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-U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-423/85-99

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NORTHEAST NUCLEAR ENERGY COMPANY (NNECo)

MILLSTONE NUCLEAR POWER STATION, UNIT 3

ASSESSMENT PERIOD: SEPTEMBER 1, 1984 - AUGUST 31, 1985

BOARD MEETING DATE: NOVEMBER 4, 1985

8601030319 851227

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TABLE OF CONTENTS

PAGE

I. INTRODUCTION.......................................................... 1

A. Purpose and 0verview.....................'........................ 1

B. SALP Review Board and Attendees.................................. 1

C. Background....................................................... 1

II. CRITERIA.............................................................. 4

.III. SUMMARY OF RESULTS.................................................... 5

IV. PERFORMANCE ANALYSIS...... ............................... ........... 7

A. Operations Support............................................... 7

B. Radiological Controls............................................ 10

~C. Maintenance............................. ......... .............. 12

D. Surveillance............ ........................................ 14

E. Preoperational Testing........................................... 16

F. Fire Protection and Housekeeping................................. 19

G. Emergency Preparedness........................................... 21

H. Security......................................................... 22

I. Construction..................................................... 24

J. -Licensing Activities.... ........................................ 28

V. SUPPORTING DATA AND SUMMARIES......................................... 30

A. Construction Deficiency Reports.. ............................... 30

B. Investigation Activities......................................... 30

C. Escalated Enforcement Actions.................................... 30

0. Management Meetings.............................................. 30

TABLES

. TABLE 1 - Construction Deficiency Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

TABLE 2 - Inspection-Hours Summary......................................... 4

TABLE 3 - Inspector Activities (Tabulation of Inspection Reports).......... 5

TABLE 4 - Enforcement Data................................................. 13

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I. INTRODUCTION

A. Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an

integrated NRC staff effort to periodically collect observations

and evaluate licensee performance. SALP objectives are to improve

the NRC Regulatory Program and licensee performance.

This SALP differs substantially in emphasis from previous Millstone 3

SALPs. Most construction activities are now combined into one

functional area. Functional areas were added to address aspects

related to future plant operations. The puroose was to focus this

one year SALP (9/1/84 - 8/31/85) heavily on operational readiness and

operational performance, with post-SALP period observations included

where pertinent.

The SALP evaluation criteria are discussed in Section II and were

applied using the " Attributes for Assessment of Licensee Performance"

of NRC Manual Chapter 0516.

B. SALP Review Board and Attendees

SALP Review Board Members

R. Starostecki, Director, Division of Reactor Projects (DRP), Chairman

S. Ebneter, Director, Division of Reactor Safety (DRS)

E. Wenzinger, Chief, Projects Branch No. 3, DRP

L. Bettenhausen, Chief, Operations Branch, DRS

R. Bellamy, Chief, Emergency Preparedness and Rad.ation Protection

Branch, Division of Radiation Safety and Safeguards (DRSS)

E. McCabe, Chief, Reactor Projects Section 3B, DRP

T. Rebelowski, Senior Resident Inspector, Millstone 3

E. Doolittle, Licensing Project Manager, NRR

Other Attendees

K. Ferlic, Project Engineer, DRP

R. Summers, Project Engineer, DRP

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. C. Background

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1. Licensee Activities

During this SALP period, the thrust of activities shifted from

construction towards preoperational activities. One hundred

nine systems were " turned over" from construction to operations

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for test performance, and 237 of the 238 systems had been turned

over by the end of the SALP period. Also, eight major mile-

stones were completed (plant on permanent power, Reactor Coolant

System hydrostatic test, Steam Generator hydrostatic test, fuel

receipt, emergency drill, Containment Structural Integrity and

Integrated Leak Rate Test, Turbine Building Hot Functional Test

to the capacity of the boiler, and Engineered Safety Features

Tests). The craft staffing decreased from approximately 3200 to

about 1400.

The licensee considered Millstone 3 to be approximately 98%

complete as compared with 88'; at the end of the previous SALP

period. (No NRC estimate of completion status was made.)

Northeast Utilities' current estimate for fuel loading is

November 1985. The Integrated Hot Functional Testing which is

scheduled for September / October 1985 is critical to achieving

this date. Equally important is generation and implementation

of plant procedures and qualification of the operating staff.

After the SALP period, the integrated hot functional test (IHFT)

was begun on September 27.

2. Inspection Activities

One NRC Senior Resident Inspector was assigned throughout the

SALP period. Resident Inspector assistance was provided by the

Millstone 1/2 Resident Inspector until a full time Resident

Inspector was assigned to Millstone 3 in August 1985. Team

inspections were conducted by a Headquarters Construction

Assessment Team (CAT), a Technical Specifications Review Team,

an NDE Independent Measurements Team, a Fire Protection Team

(including safe shutdown capability), an allegations Review

Team,and an as-built review team (at the end of the assess-

ment period). There was also an Environmental Qualification

inspection and numerous NRR visits to evaluate SER concerns.

The NRC inspection effort during the period totalled 7723 hour0.0894 days <br />2.145 hours <br />0.0128 weeks <br />0.00294 months <br />s:

5523 hours0.0639 days <br />1.534 hours <br />0.00913 weeks <br />0.0021 months <br /> were by resident and region-based inspectors; and

2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> were for the CAT inspection. The distribution of

inspection hours is shown in Table 2. Inspection activities and

enforcement data are summarized in Tables 3 and 4, respectively.

Quality assurance was an integral element of all inspections

performed during the assessment period. In addition, two

inspections were devoted specifically to the QA/QC program.

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3. Other Activities

On September 10, 1984 the ACRS reported to the NRC Chairman

that, subject to resolution of open NRC items and to the

satisfactory completion of construction, staffing, and

preoperational testing, the ACRS believes that there is

reasonable assurance that Millstone 3 can be operated up to 3411

Mwt without undue risk to public health and safety.

The Millstone 3 simulator is operational and has been used for

the initial operator licensing process.

Public officials in Waterford, Connecticut have been routinely

informed of major Millstone 3 evolutions by utility officials

and separately by the senior resident inspector.

The Safety Evaluation Report (SER), NUREG-1031 was issued by NRR

during July 1984. Supplements 1 and 2 were issued in March 1985

and September 1985. Supplement 3 was in draft form at the end

of the assessment period.

On March 22, 1985, the applicant established a more formal and

comprehensive allegation program after discussions of the need

for this with Region I.

On June 5, 1985, an exemption was granted to General Design

Criterion 4, allowing NNECo to forgo the installation of pipe

whip restraints for primary loop piping.

The 29 Construction Deficiency Reports (CDRs) for this

assessment period are summarized in Table 1. Three of these

have currently been determined not to be reportable by the

licensee.

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II. CRITERIA

Licensee performance is assessed in prescribed functional areas based on

whether the facility is in a construction, preoperational, or operational

phase. Other areas may be added as appropriate. Each area normally repre-

sents aspects significant to. nuclear safety and the environment. One or more

of the following criteria were applied in each area:

1. Management involvement and control in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Reporting and analysis of reportable events.

6. Staffing (including management).

7. Training effectiveness and qualification.

Each area was classified into one of the following three categories.

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Category 1. Reduced NRC attention may be appropriate. Licensee management

attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used so that there is a high

level of performance wi+3h respect to construction and operational safety.

Category 2. Normal NRCtattention should be maintained. Licensee management

attention and involvemeht are evident and are concerned with nuclear safety;

licensee resources are adequate and reasonably effective so that there is

satisfactory performance with respect to construction and operational safety.

Category 3. Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear safety,

but weaknesses are evident; licensee resources appear to be strained or not

effectively used so that there is minimally satisfactory performance with re-

spect to construction and operational safety.

The SALP Board also as~sessed each functional area to compare the licensee's

performance for the last quarter of the assessment period to that during the

entire SALP period in order to determine the recent trend for each functional

area. The trend categories are:

Improving. Licensee performance has generally improved over the last

quarter of the current SALP ass.:ssment period.

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Consistent. Licessee performance has remained essentially constant over

the last quarter f the current SALP assessment period.

Dy: lining. Licendae performance has generally declined over the last

quarter pf the current SALP assessment period.

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III. SUMMARY OF RESULTS

Category Last Category This

Period Period Recent

Functional Area (9/1/83-8/31/84) (9/1/84-8/31/85) Trend

A. Operations Support N/A 2 Consistent

B. Radiological Controls N/A 2 Consistent

C. Maintenance N/A 2 Consistent

D. Surveillance N/A 3 Consistent

E. Preoperational Testing 1 1 Consistent

F. Fire Protection & Housekeeping N/A 1 Consistent

G. Emergency Preparedness N/A 2 Consistent

H. Security N/A 1 Consistent

I. Construction 1 1 Consistent

J. Licensing 2 2 Consistent

Overview

During this transitional period, licensee performance has generally been

characterized by management involvement in facility activities, strong QA/QC

presence, commitment to training, appropriate corrective action, responsive-

ness to NRC concerns, and technical competence. Construction quality and

preoperational testing has been good. The licensee has been effective at

maintaining control over contractor activities. Construction and preopera-

tional testing program development and staffing kept pace with activities

and the licensee generally anticipated changes in manning requirements.

Transitions to operating phase programs generally progressed smoothly, with

carryover from Millstone 1.and 2 being a substantive aid in the development

of Unit 3 programs. Resolution of fire protection issues was particularly

well done.

Problems identified included nondestructive examination inadequacies, minor

flooding incidents, failures on initial operator licensing examinations, and

slow development of procedures to support plant startup and operation. How-

ever, it was evident that, while the construction completion schedule was very

important to the applicant, safety considerations were resolved without sub-

ordination of quality to schedule.

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This assessment has not evaluated the licensee's organization as it will exist

during ascension to full power. Shift staffing and organizational changes

are expected to occur as Unit 3 becomes operational. Continued management

attention is needed to ensure a smooth transition.

Training Overview

The applicant's commitment to training has been high. As noted in the Mill-

stone 1/2 SALP (9/1/83 - 2/28/85), organizational training initiatives have

been notable and included an upgrading through training staff expansion in

size and authority. The licensee is providing simulators for all four

facilities and the Millstone 3 simulator is operational.

There was a high failure rate on-the initial licensed operator examinations

which can be attributed to the use of the simulator in the examination process

and'some lapses in the operations / training interface. After meetings with

the NRC and program revisions to resolve these lapses and increase simulator

usage, significant improvement in candidate performance was noted on the

second set of examinations.

Overall observation of work performance in all phases of plant activities in-

dicated a well trained and qualified work force. Few problems arose as a re-

sult of unqualified personnel or lack of training. Review of training records

to verify qualifications and receipt of training and retraining found the

records were complete and met program requirements. The effectiveness of

training will continue to be monitored after INP0 accreditation.

Quality Assurance Programs and Controls Overview

Management of Millstone-3 made an initial strong commitment to assure quality

and has maintained that commitment throughout the design, procurement, con-

struction, and preoperational phases. The training and knowledge of QA/QC

personnel was found acceptable during all phases. Staffing was generally

sufficient and adequate to conduct the QA/QC programs during the transition

from construction to operations. Management involvment has been clearly

evident in knowledge of QA/QC programs and their status, in onsite presence,

and in emphasis on corrective actions.

QA coverage for operations is to be based on acceptable programs in place at

Millstone 1 and 2. QA programs for operations, surveillance, and maintenance

have not been completed for Millstone 3. Their completion is dependent upon

completion of the procedures governing these activities.

QA violations which have occurred during this assessment period relate to the

broad spectrum of~ construction and preoperational activities involved in the

latter stages of facility construction. They do not indicate a breakdown in

quality programs or serious individual quality problems.

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IV. PERFORMANCE ANALYSIS

A. Operations Support (552 Hours, 7%)

This area addresses compliance with commitments and procedural re-

quirements, " turned-over" systems, reporting, staffing, engineering

support, design change and modification control, operator training,

and safety review committee activities. Fuel receipt, core load pre-

parations, operational aspects of testing, and onsite management of

j facility evolutions are also included.

l This area was under routine review by resident and region-based

inspectors throughout the assessment period. The analysis is based

! in part on review of operations-related aspects of inspections of

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other Functional Areas and therefore involves a larger inspection .

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basis than was allocated.  !

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Observation of control room activities found personnel knowledgeable

of their current assigned duties and responsibilities (e.g., response

to facility emergencies [ containment fire], manipulation of controls

during preoperational testing, hanging and removal of tags and

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jumpers).

A formal method of processing design changes and written administra-

! tive controls for controlling temporary modifications, jumpers, and ,

bypasses, including controls for maintaining logs, was in place

, throughout the assessment period. These are the framework for con-

trol during operations and were effective during testing. Improve-

i ments have been made as deficiencies were found (e.g., changes to

jumper controls to establish a one time, unique tag number.) How-

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ever, review of recent plant incident reports found multiple' tagging

problems, and administrative procedural controls should be reviewed

by the licensee to assure their adequacy for operations. Similarly,

licensee reviews should be performed to assure log keeping require-

4 ments and shift turnover protocols provide the mcre rigorous controls

needed for operation.

j Although no violations were cited in the operations area, several

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aspects of three flooding events which occurred are related to opera-

tional controls. In a Service Building flooding event, the elapsed

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time between the Shift Supervisor's release for test performance

(signifying the plant systems had been verified and ready for test)

, and the actual performance of the test was nine months with no re-

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verification, and changed system status resulted in the event. In a i

flooding event in the Control Building, failure to follow pro- i'

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cedural controls resulted in isolating a section of service water

! pipe without emptying the pipe, which then was drained to the Control

Building. In an Engineered Safety Features Building flooding event,

. failure of to fol. low the automated work order tag requirements caused

flooding. Corrective action was initiated for each of these events.

i No similar events have occurred recently. However, operational

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controls and staff training in these areas should be re-reviewed by the

licensee prior to power operations to further safeguard against such

occurrences.

New fuel receipt occurred during the SALP period. Few problems were

encountered with fuel receipt, transfer, cleaning, storage, and docu-

mentation of these activities. Personnel involved were knowledgeable

of their responsibilities and of program and NRC license require-

ments. The licensee was cognizant of IE Information Notices concern-

ing fuel handling and had incorporated the recommended actions into

procedural, alarm, and interlock provisions. Personnel training was

found adequate in associated areas (fire protection, health physics,

security, preoperational testing). QA/QC coverage was provided.

Initial cold license operator examinations were conducted during May.

A second set of examinations in September immediately followed the

close of the SALP period. The simulator was used during the exami-

nations. The initial set of examinations resulted in an approxi-

mately 50% failure rate. The failures tended to be concentrated in

the simulator portion of the operating test. A meeting with the

candidates who failed the test was held by hRC supervisors to both

further understand what transpired and to explain how examiners ex-

pect the candidates to perform for upccming tests. Some of the

failures can be attributed to the fact that the simulator was very

recently placed in service and a comprehensive training program in-

tegrating the simulator was not in place for the candidates. Con-

sequently, the candidates may not have been sufficiently familiar

with both the simulator and the newly developed emergency operating

procedures. Further analysis of the operator training program indi-

cated that another weakness may be poor communications between the

training organization and the operations department in that there was

not a mutual understanding regarding operating philosophy and train-

ing needs, and the technical feedback required to assure that the

training desired is being achieved was lacking. An example was the

confusion generated regarding the role of the shift supervisor (SS)

and the supervising control room operator (SCRO) which caused some

problems in examining the senior reactor operator (SR0) candidates

since the two positions had divided responsibilities. The licensee

didn't anticipate that the SS may in fact not be in the control room

or readily available at all times and that the SCR0 may have to per-

form both functions. Consequently, emphasizing the duties of the

SCR0 as being a subset of SS duties resulted in confusion. This,

coupled with the problems between operations and training, resulted

in the high failure rate. A management meeting was held to discuss

these problems and, subsequently, the examinations conducted in Sep-

tember and the retake examinations given in October reflected an im-

provement in training and performance on the simulator. Meetings

were held between the NRC examiners and the candidates before the

second set of examinations to explain scope and conduct of the test.

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Two events near the end of the assessment period are potentially

! significant. These were a condenser chloride intrusion and a diesel

fuel oil spill. The chloride intrusion was caused by corrosion of

bolts fastening the air reduction pipe to the condenser tube sheet.

[ During the recovery, examination revealed that additional bracing was

needed. This was a major task. Management response was extremely

l thorough, technically sound, and provided long term corrective action

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to both corrosion and bracing problems. Inspector review found that

licensee actions exceeded those required to fix the " broken part" and

demonstrated an aggressive " correct the root cause" approach. The

l second event was a fuel oil spill caused by over-filling the 'B' fuel

l storage tank while transferring from the 'A' fuel storage tank via

l the day tank. Procedural inadequacies appeared to be involved.

, Licensee investigation was in progress at the end of the SALP period.

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However, concern for the fuel spill did not appear to be approached

with as thorough a " correct the root cause" approach as the chloride

intrusion. Although the fuel spill was much less important than the

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chloride intrusion, it indicates that correcting root causes could

be more thoroughly ingrained in plant personnel.

Conclusion

Category 2, consistent.

Board Recommendation

l Licensee:

l 1. Review control of and training for jumpers and lifted leads,

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tagging, log keeping, and shift turnover requirements to assure

controls are adequate for power operation.

2. Assess whether formal metheds and personnel orientation on

correcting root causes are sufficient.

NRC:

Conduct a special team inspection to assess the functional opera-

tional performance of the plant operating staff during the power

ascension program and/or early during operation at high power.

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B. Radiation Control (181 Hours, 2*4)

Preoperational inspections of radiological controls were initiated in

th's SALP period. Programs reviewed were radiation protection, radio-

active waste management, radioactive material transportation, effluent

control and monitoring, and radiochemistry. These programs have been

used at of Unit 1 and 2 and are being applied to Unit 3. Radiological

controls for Units 1 and 2 were Category 2 for the last assessment

period (9/1/83 - 2/28/85), and the programs are well established and

operationally sound.

Procedures for Unit 1 and 2 radiation protection are generally well

stated and provide explicit directions for controlling radiological

activities. All of the procedures applied to Unit 3 were subject to

management review before incorporation to assure that radiological

control was not over generalized. Minor examples of procedural deft-

ciencies have been identified in NRC reviews but programmatic weak-

ness is not indicated. However, detailed radiological controls for

handling of contaminated individuals exiting the Unit 3 containment

and their transfer to a decontamination area have not been established.

The radiation protection program was not fully implemented for fuel

receipt. Nevertheless, the licensee's fuel receipt efforts demon-

strated good planning and effective procedure development. The per-

sonnel involved were adequately trained and able to establish

thorough and complete radiological controls. Records of this activ-

ity were complete, well maintained, and available for review.

Personnel who implement the radiation protection program at Unit 3

undergo the same formal training as at Units 1 and 2. Additionally,

all personnel received special unit specific training in plant systems

and layouts. The training program is well defined and implemented

for the entire staff.

The licensee's chemistry / radiochemistry program is based on proven

procedures adopted from the program for the operating units. Personnel

are trained and qualified. A consistently good performance has been

noted in this area at Millstone 1 and 2.

The radioactive waste management program, common for the site, has

not yet been implemented for Unit 3. All radwaste systems have been

turned over to the utility. Preoperational testing is in progress.

Liquid waste, gaseous waste, and boron recovery systems remain to be

tested. The test program appears technically sound and sufficient.

Several operational deficiencies have been identified, but there is a

concerted effort to resolve and correct them. Waste system operating

and surveillance procedures h<ve not been finalized and, consequently,

were not reviewed.

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Support activities such as external dosimetry, whole body counting,

maintenance and calibration of radiation instrumentation are common

to the site. The respiratory protection program, although also

common, has not been reviewed for how the Unit 3 subatmospheric

containment and associated changes in controls, if any, will be

addressed.

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The Radiological Environmental Monitoring Program for the operating

units will also apply to Unit 3. This program has been effectively

implemented and is technically sound. Only minor discrepancies have

been noted. These have received immediate attention.

Immediately after the SALP period, NRC inspectors identified a

radwaste program concern. The FSAR solid radwaste system description

and the SER did not refect the installed system. Differences included

(1) the binder system used to supplement solidification as described

in the FSAR was essentially eliminated in 1983, (2) several system

components have been eliminated during startup testing, and (3)

the FSAR failed to describe resin dewatering by the primary waste

process and how much volume could be handled. Changes to the FSAR

had not been submitted. Upon identification, the applicant was quick

to draft an FSAR revision.

Conclusion

Category 2, consistent.

Board Recommendation

Licensee:

1. Assure the FSAR accurately describes the solid radwaste system.

NRC: None

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C. Maintenance (169 Hours, 2%)

Resident and region-based inspectors observed corrective and pre-

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ventive maintenance and reviewed the programs for maintenance support

planned for use during power operations. Pre-turnover and post-

turnover maintenance activities were observed in the areas of me-

chanical, electrical, and instrumentation'and control systems. The

inspection effort consisted of one program inspection by a region-

based inspector and review of maintenance activities during other

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inspection efforts.

Both the Maintenance Department (mechanical and electrical) and the

Instrument and Controls (I&C) Department were fully staffed based on

current manning projections. Training programs were established

for I&C personnel and a comprehensive written test was given to all

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I&C contract technicians prior to performance of activities (instead

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of relying on vendor certification programs). Maintenance Department

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training procedures were in existence at the time of the program

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inspection, but the training program was still being developed.

The mair.tenance organizations are established. Programs for cor-

rective maintenance, preventive maintenance, and instrumentation and-

control maintenance were functioning in support of pre-operational

] testing and system turnovers. Procedures have been in place for ini-

l tiating, approving, reviewing, and scheduling of plant and preventive

maintenance for equipment protection. Administrative controls were

established for preparation and retention of maintenance records.

Weaknesses identified during the CAT inspection in the corrective

action taken to control preventive maintenance after components had

been turned ove- for testing / operations were promptly addressed by

the applicant. Never, a large backlog in the generation of main-

tenance, prevent e maintenance, and plant instrument calibration

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procedures existed at the end of the SALP period.

Maintenance is controlled by a computerized system in use at all

Northeast Utilities Companies and accessible throughout the company.

This system is called the Production Maintenance Management System

(PMMS). Each department has a PMMS planner trained to make entries

to the system. PMMS information includes the frequency of preventive

maintenance and the maintenance history files. The system can review

maintenance records for generic failure implications and identify

periodic replacement of plant components based on environmental qual-

ification service time limits. Work orders are issued by the system,

including preventive maintenance and calibration activities. Manual

backup is used if the computer is down and for emergency maintenance.

As of June, a backlog existed on

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computer input activities for the PMMS of Unit 3 mechanical equip-

ment. Much of the work in this area was being performed on manually

prepared work orders to give the PMMS time to catch up. Adequacy of

the automated aspects of pMMS therefore remains to be proven.

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Observation of maintenance (e.g., component cooling water pump coup-

ling and thrust bearing repairs, service water pump disassembly and

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inspection, steam generator "J" tube replacement, service water inlet

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elbow repairs on CCW heat exchanger) found the program effective.

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Controls were sufficient to assure preoperational test results were

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not invalidated and that retesting was conducted on equipment for

which work orders were issued.

Conclusion

Category 2, consistent.

1 Board Recommendation

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i Licensee: Establish a schedule for the completion and implementation

of maintenance related procedures and training programs.

j NRC: None

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D. Surveillance (195 Hours, 2*4)

Surveillance activities necessary to support plant operations were

reviewed. Particular attention was given to development and imple-

mentation of the surveillance program for Technical Specification

requirements, availability and development of surveillance proce-

dures, availability and retention of equipment baseline data, and the

pre-service and inservice inspection programs. Inspections in this

area involved a program review in May, as-built review for conform-

ance to Technical Specifications in July, and examination of parts

of the surveillance program during other inspections.

For the most part, surveillance programs have been developed. Staf-

fing was in progress or complete and personnel were knowledgeable of

their responsibilities. Development of a master surveillance index,

a computerized production and implementation schedule, and inter-

departmental coordination methods had not been completed.

In July 1985, a special team inspection found that surveillance pro-

cedures were largely in draft form, varied substantially in quality,

and were generally not ready for inspection. That condition per-

sisted beyond the SALP period. (I&C surveillance procedures were

significantly ahead of the others.) The license pointed out that

delays in final Technical Specification issuance was a significant

factor in delaying the facility procedures. NRC review concluded that

the lack of procedure readiness included work that either did not

depend on Technical Specifications or could have been put in near

final form with provisions made for required validation upon Tech-

nical Specification issuance (a feature also needed for future TS

changes). Development of facility procedures was therefore evaluated

as a tardy effort which did not properly support operations on the

licensee's planned schedule. (As recently as early November 1985, the

NRC postponed inspections in this area because procedures were not

ready.)

The applicant has provided a satisfactory program to obtain baseline

information on plant equipment. In addition to obtaining field data

(e.g., steam generator eddy current base line data), procedures and

programs are being developed to maintain equipment history as

discussed under the maintenance section.

Conclusion

Category 3, consistent.

-

.

o

15

Board Recommendation

Licensee:

Assure surveillance procedures support future planned testing

and operations. Particular emphasis should be placed on orderly

development and review of procedures. -

NRC:

Conduct special follow-up inspection of surveillance program

and procedure adequacy.

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

.

.

'

.

"

16

-

E. Preoperational Testing (1835 Hours, 23%)

Preoperational Testing was rated Category 1 during the last SALP. It

was characterized as a well-defined program with an adequate staff

-

and experienced senior managers. Adequate controls existed for plant

maintenance, preventive maintenance, training, and documentation.

'

i The QA/QC program was evaluated as well-cbnceived. The supporting

organizational elements, NUSCo-QA and NNECo-QA/QC, were staffed with

experienced personnel.

'

During this SALP period, there were fifteen region-based inspections

i plus routine observations by the resident inspector. In addition to

test program adequacy, test witnessing, and test results evaluation,

NRC independent measurements were performed. Preoperational proce-

dures were generally consistent with regulatory requirements, gui-

dance, and commitments. An exception was the Chemical Tank drawdown

test, which did not reflect all FSAR commitments. The applicant ini-

1 tiated prompt corrective action.

Management involvement has been evident in planning, procedure de-

velopment, staffing, training, and results review. Also, the startup

program was modified to improve performance. Three notable examples

l were (1) assignment of an auxiliary system test coordinator to accept

I

selected responsibilities from the nuclear system balance-of plant

test coordinators during high activity, (2) requiring the NNECo

Operations Department to review system test results as well as the

Startup Department, and (3) reorganization from a discipline-

orientated to a task-orientated organization.

Several tests have had a great number of changes (exceptions). These

included the Chemical Addition Tank test, Engineered Safety Features

test, RCS hydrostatic test, and Steam Generator hydrostatic test.

Based on the changes reviewed, exceptions did not affect test results

or change basic test objectives. Changes were found to be properly

reviewed, approved, and documented. Throughout the SALP period, the

NRC has had to review draft procedures. However, only approved pro-

cedures have been found in use during testing. Based on the test

results reviewed by the NRC inspectors, no problems have occurred

'

because of late procedure generation.

Technical solutions to problems have been well defined and executed

except for a few isolated examples where resolution was incomplete or

4 slow. An example is valve indication on manual and motor-operated

valves (slip of butterfly valve indication arrows, reverse installa-

tion of indicators, reverse raised letter indication, no labelling

'

for position indicator, and handwheel operation contrary to normal

convention). The containment sump flooding in May was in part a

'

result of failure to establish the position in the Containment Sump /

Containment Recirculation Pump suction isolation valve. The valve

stop for the butterfly valve had not been installed and the operator

positioned the butterfly valve past the closed position by following

the position indication (arrow).

i

_ ,. , . - . , - . . ,.

. . ._ ._ _ ._-

,

, .

,

17

During this SALP' period, the containment Local Leak Rate Testing

(LLRT), Integrated Leak Rate Testing (ILRT), and Structural Integrity

"; Test (SIT) were completed. Test procedures and results get require-

ments. Personnel were knowledgeable of the procedures and equipment.

Staffing was adequate. Test personnel made tours to look for leaks.

The applicant exercised good engineering judgement. Only one Con-

j struction Deficiency was identified: two 3/4 inch leakage monitoring

lines were improperly installed and left open to the atmosphere.

That Deficiency was corrected.

Test personnel and management involved with the SIT were committed to

4

assuring an accurate, high quality test. Comparison to the predicted

analytical deflections was done by crack mapping and crack width .

<

measurements in accessible unpainted areas. The applicant also

measured exterior containment deflections across seismic (" rattle

space") separations between the containment and adjacent structures.

Preliminary. indications were that actual ~ deflections agreed with

predicted ones. Overall, SIT efforts exceeded the provisions of SIT

Regulatory Guide 1.18.

During the SALP period, preoperational testing proceeded without

serious delay. The only safety-related system encountering signif-

icant difficulties was the Emergency Diesel Generators (EDGs), which

experienced repeated seizing of the fuel injection pumps. Subsequent

fuel system cleaning and flushing, and modifications to the fuel

,

'

filters, appeared to resolve this problem. An EDG delay resulted

when Stone and Webster Engineering review of Colt Industries QA/QC

activities found it was necessary to replace numerous crimps in EDG

panels. The rework proceeded in a thorough manner without sacri-

ficing quality for time.

QA/QC involvement was observed during preoperational testing. QC

hold points are not included in preoperational test procedures.

Rather, the QA/QC program consists of surveillances timed to give

broad QA coverage of the preoperational test program. This moni-

I

toring program includes in process verifications, test witnessing,

checks on instrument calibration, receiving and storage of test

equipment, etc. No significant problems were noted.

A trending / tracking program was established during preopeational

testing for outstanding items, QA audit reports, completed actions,

and other similar items. This program was found effective.

Conclusion

Category 1, consistent.

'

Board Reccmmendations

-- . - . - _ _ _ _ .

-. -. __ , . _ - -

_, .-. ..

-. . . _ . . . -~ . . . . . . . . , - _ - - . - -

.

,- .

.:

4 18

!

'

Licensee:

1. Upgrade timeliness of issuance of startup and power ascension

! test procedures and of evaluation of test

results.

1 2. Assure that any as-built plant, SAR,' and Technical Specifica-

tions discrepancies revealed by preop tests are corrected.

1

,

NRC: None

i

+

t

'9

-

..

$

,

e

a

A'

e

I

!

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

- -

_ __ _ _ - _ _ . _ _ _ _ _ . _ _ - _ . . _ _ ___ . - . _ , _ . _ _ _ - . - -

._ _ __ -_ _ _ _ _ _ _ .___________________ __________

_

.

.

, =

19

F. Fire Protection and Housekeeping (172 Hours, 2%)

Fire protection and housekeeping are also routinely reviewed by most

NRC personnel who visit the site, making the actual data base greater

than is recorded in inspection hour records. During this SALP

period, there was one team inspection plus routine inspections by the

resident and region based inspectors. The inspections confirmed that

the applicant was implementing an effective program for fire preven-

tion and fire protection. Licensee coverage included control of

combustible materials, storage and use of flammable liquids, avail-

ability and maintenance of fire fighting equipment, operations in-

volving open flames or arcs and fire prevention for temporary ser-

vices and work activities. Throughout the SALP period, fire pre-

vention and fire protection was well implemented and maintained, and

housekeeping and cleanliness were satisfactory.

The NRC team inspection confirmed the ability to shutdown safely in

the event of a design basis fire. Management involvement in assuring

a safe shutdown capability was evident throughout the licensee's

effort involved in applying the NUREG 800 Guidelines. The applicant

formed a fire protection inspection team of hand picked specialists

from his staff and contractor personnel. This team addressed shutdown

concerns and capabilities, design changes, and compliance with guide-

lines. Management attention resulted in an efficient licensee team

which adequately addressed all NRC concerns. The applicant demon-

strated a clear understanding of safe shutdown issues and concerns.

Their analysis was comprehensive and well documented. Such thorough-

ness was also reflected in the supporting calculations reviewed by

the NRC. Throughout the NRC team inspection, applicant responses

were timely and technically sound.

In November 1984, a small fire in containment was caused by a short

in a temporary lighting cable, apparently due to crimping of the

cable by scaffoldin! planks. The damage was minor. No permanent

plant equipment was clamaged. The applicant's response was prompt and

well organized. A reflash watch was stationed for several hours.

Corrective action implemented after a September 1981 fire limited the

scope of this fire. This event demonstrated an effective fire re-

sponse capability.

One concern was the licensee's Hot Functional Testing approach which

waived fire protection for areas protected by carbon dioxide due to

problems with fire control panels. The licensee committed to addi-

tional patrols of the potential hazard areas to provide minimum pro-

tection. The carbon dioxide system has yet to be demonstrated. As

late as November, this system was not tested due to a problem

with the Heating, Ventilation and Air Conditioning System.

Staff responsibilities were evaluated as well defined and authorized

manning levels as ample to meet those responsibilities.

.. . .

.

. ..

_ - _ - _ _ _

-

.

. *

20

Conclusion

Category 1, consistent.

Board Recommendation

Licensee: None

NRC: Follow-up CO2

System testing and associated damper testing.

__- - - - - - - - - - _

.

. *

21

G. Emergency Preparedness (140 Hours, 2%)

This is the first SALP evaluation for Millstone 3 in this area. Unit

3 is an additional unit in the common site Emergency Plan and is in

part dependent on the program for Units 1 and 2. The site program

was rated as Category 2 (period 9/1/83 - 2/28/85) with the recommenda-

tion that the licensee evaluate measures for the timely completion of

action items. The major issue was the establishment of an integrated

emergency plan training / retraining program to ensure that lesson plans

were developed and training accomplished for each functional area of

4

emergency activity. At the end of the Unit 1/2 assessment period, the

" Emergency Preparedness Training Program" was only available in draft

form but contained the revised training lesson plan format and testing

requirements. This program, which was to be implemented by June 30,

1985, was late but acceptable in quality,

i

A Unit 3 Emergency Preparedness Implementation Appraisal was conducted

in July 1985. It covered facilities and equipment, organization,

procedures, and training. Afterwards, a meeting was held in Region I

to discuss deviations from current guidelines. During that meeting,

the applicant presented information which resolved the concerns or

4 proposed acceptable corrective action. In many cases, a more com-

plete description in the Emergency Plan or implementing procedures

would have allowed an earlier resolution.

On May 15, 1985, the NRC observed an emergency drill for Millstone 3.

!

Participation was limited to utility personnel. This drill imple-

mented selected response aspects including operator response, tech-

nical support activities, event classification and reporting, and

coordination of emergency response activities. Overall performance

was acceptable. Personnel $were appropriately trained and qualified

to perform the emergency functions observed. Areas noted as

needing improvement were coordination of emergency repair activities

between the Technical and Operational Support Centers and crowding of

some facilities in the OSC. The crowding was in part due to the

dispatching of repair crews from the OSC.

Management commitment and close involvement in assuring an adequate

level of emergency preparedness was shown during the emergency drill

and program reviews.

Conclus r3

Category 2, consistent.

Board Recommendation

4

Licensee: Increase management attention to assure corrective actions

are accomplished in a timely manner.

NRC: None.

_ - . - .

-_

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

_

-

.

.

22

,

H. Security (84 Hours, 1%)

This was the first SALP evaluation of Unit 3 Security and reviewed

'

the development of a physical protection program for Unit 3 and

preparations for integration of the Unit 3 program into a site (Units

1, 2 and 3) security program. Also assessed was the licensee's

developing and implementing of a program for receipt and storage of

l new fuel. Three announced preoperational security program reviews,

including two inspections of new fuel were performed by a

region-based physical security inspector. Continued review of the

program was conducted by NRC resident inspectors.

The development of the physical security program and its integration

into the program for Units 1 and 2 included modification of the

security management organization; the procurement, installation and

acceptance testing of new equipment and the operational interface of

the Unit 3 equipment and systems with the existing system; and the

hiring and training of additional contract security personnel.

A major rewrite of the site physical protection plan was completed

and submitted to the NRC in May 1985. NRC review identified some

, minor issues which required rework by the licensee. All of these

issues have been resolved. In addition, the licensee submitted its

Plan for Receipt of New Fuel in March 1985. It required little

rework and was approved by NRC in April 1985. The licensee is

currently reviewing its Suitability, Training and Qualification, and

. Safeguards Contingency plans to provide for the integration of Unit

i

3. It appears that only minor administrative changes will be neces-

sary. All security program plans were observed to be professionally

prepared, well organized, responsive to regulatory requirements, and

submitted in a timely manner. Minor changes necessitated as a result

of NRC review were accomplished in a timely and professional manner.

The design engineering and layout of the Unit 3 security equipment

and systems are well conceived. Practical applications and utiliza-

tion of state-of-the-art equipment are evident. Quality assurance

4

oversight of program-related activities was evident throughout the '

assessment period. Project engineers and security supervisors were

l knowledgeable of program status, turnover dates and NRC performance

criteria. Procedures were in place to assure the proper acquisition ,

i

and retention of acceptance testing documentation. Documentation was '

found easily retrievable during NRC reviews. These reviews indicated

close coordination and oversight by licensee management for all

activities. The newly constructed site security facilities were well

planned with an adequate allocation of space. Human factors con-

sideration was evident.

4

e

,-- -

,>~m - - - - - - m ~-

. _ _ _ _ _ _ _ _ _

.

..

. *

23

.

The hiring of new contract guards and watchpersons is complete. The

security organization has increased by approximately one third, to

about 280 personnel, including both proprietary and contract

staffing. The training and. qualification of new security personnel

has been in progress since March 1985 and is scheduled for completion

in September 1985. Specialized training being administered to the

new personnel was observed during Region I program reviews and was

found consistent with the licensee's NRC approved Suitability,

Training and Qualification Program. Experienced Unit 1 and 2

personnel are in line for command and access control positions.

The last two Preoperational Security Program Reviews during the

assessment period included implementation inspections of the Plan for

Receipt of New Fuel and associated control procedures. No problems

were identified.

Corporate and site management involvement in planning, procurement,

installation, hiring of employees, budgetary support, quality

assurance and audit have been evident throughout the assessment '

period. Presentations on the status of projects were professional

and technically competent. Sufficient personnel are trained,

qualified and available to compensate for unplanned system or

equipment failures.

The licensee promptly informed the NRC of occurrences in the security

area during the construction of Unit 3.

Conclusion

Category 1, consistent.

Board Recommendation

Licensee: None.

NRC: None.

_

.

., .

.

24

I. Construction (4774 Hours, 59's)

The previous SALP assessment evaluated six areas of construction

separately. These were Containment and Other Safety-Related Struc-

tures; Piping Systems and Supports; Safety-Related Components;

Support Systems; Electrical Power, Instrumentation and Controls; and

Engineering-Construction Interfaces. All areas were rated Category 1

except Piping Systems and Supports which was re.ted Category 2. All

six areas have been combined under one functional area for this SALP.

Concerns addressed in the previous SALP included: (1) assumed pipe

and fitting sizes were used in stress calculations (2) lack of

aggressive action to correct deficiencies in the control of NDE qual-

ity, (3) minor delays in correcting deficiencies in safety-related

components and (4) choice of the proper Non-Destructive Examination

(NDE) method for inspecting of containment electrical penetration and

end plate welds.

Inspection of construction involved eighteen inspections in addition

to routine review by the resident inspcclors. There was a team in-

spection from NRC Headquarters and one from the Region. Three team

inspections involved the Enoineering Assessment In-Depth Technical

Audit. Ten construction violations wer~e identified. None of these

were considered serious or indicative of a breakdown in the quality

of construction.

Most electrical systems were energized during this SALP period to

support testing. Although there were problems with control of elec-

trical and I&C equipment due to dirt, aggressive management attention

was effective in correcting this. Overall, electrical construction

has been good. Design requirements'and specifications were generally

met. Deficiencies noted included not meeting electrical separation

criteria for some raceways and cables, some Class IE cable termina-

tions not in accord with design drawings, some main control board

redundant wires in contact with each other, and random use of color

tape to identify cable channels. The applicant quickly initiated

acceptable corfective actions. Vendor wire termination problems

were , uncovered'by the licensee and resulted in an aggressive 100%

reinspection program of four vendors. The associated rework has been

completed for the main control board and the Systems Control vendors

and was in progress for the other two.

Work observation, as-built verifications, and independent measure-

ments and calculations have found the instrumentation and controls to

be in compliance with drawings and commitments.

-

.

. *

25

Containment and other safety-related structures have been constructed

with only minor problems / weaknesses found. These have included

rattle spaces smaller than committed, concrete in the rattle space

between Containment and the Main Steam Valve Room, and some steel

connections not in accordance with design drawings. Repair of con-

tainment liner damage from a September 1981 fire were acceptably com-

pleted. Overall, structural construction <was in accordance with

applicable codes, commitments, and requirements.

Engineering-construction interfaces have generally been good and have

effectively functioned during operational turnovers. Although a

large number of open items may be present on turnover, there are

controls to determine how these items will be dispositioned. Manage-

ment has been very responsive. Improvements were noted in post-turn-

over control of wiring changes and preventive maintenance deficien-

cies. The applicant has knowledgeable personnel who are aware of re-

quirements involved with turnover documentation, but some files are

incomplete and it was very time consuming to assemble the data. No

major problems were experienced as a result.

Problems associated with the vendor radiographic program, identified

by the NRC Van inspection during the last SALP period, indicated that

management was not sufficiently involved in control of non-destructive

examination (NDE) quality and that technical evaluations were not

adequate. Additional problems were identified during this SALP

period. These include drawing control, missed radiographic indica-

tions in site and vendor welds, and failure of the licensee to have

the independent authorized nuclear inspector review final re-radio-

graphs of welds. These involved 600-700 vendor (Tubeco) weld radio-

graphs. The applicant initiated corrective action. Relief from code

requirements was requested from NRR for 30 welds imbedded in con-

crete. As of this writing, no substantive rework has been required

to assure the ability to meet functional design requirements. Never-

theless, continued management attention is warranted to NDE record

quality.

In August 1985, selected results of Preservice Inspection (PSI)

ultrasonic examinations of centrifugally cast stainless steel for the

reactor coolant piping were reviewed. The review identified dis-

crepancies involving documentation of examination limitations and the

disposition of indications attributed to geometric reflectors. These

indicate a need for additional licensee management attention to the

review of Westinghouse PSI data.

,

'

.

.

... *

'

26

4

' , During the CAT inspection discrepancies were identified in pipe sup-

port / restraints and mechanical equipment foundations, and between

'

as-built drawings and piping configurations. The team also identi-

fied a need for more thorough engineering review activities, and

additionaFreinspection and/or reanalysis. In' August 1985, an ex-

tensive inspection was performed on structbral steel bolting and

welding, pipe support welding, vendor tank welding, and stress recon-

ciliation. This inspection included independent measurements and

followup of licensee activities in response'to CAT findings. Over-

all, the results indicate good onsite welding quality and an adequate

program for response to the CAT findings.

Immediately after the SdLP period a multidisciplinary team inspection

,' assessed whether selected, as-built systems substantially agreed with

the'l descriptions contained in the FSAR and the SER. It was concluded

that overall workmanship was good and that the systems generally con-

form to the F5hk and SER. Capacity and seismic mounting discrepan-

cies were, however, identified in the control room air pressurization

system.

,'

.~ \

, .The senior resident inspector and Region I managers have found.that,

in general, submitted Construction Deficiency Reports were timely,

thorough, and of good quality. Technical solutions for Construction

s0eficiencies has been sound. Corrective action has been performed

by properly trained personnel using approved procedures. However,

' '

resolution of a number of items has continued to proceed slowly

and needs, additional management attention,

s Nonconformance and Disposition reports are usually resolved in a

, timely manner, with positive corrective action being taken. Design

modifications-and modification requests were handled in accordance

, with procedures. ' Disposition of these requests were based on

engineering justification and review by members of the Joint Test

Group. Engineering and Design Coordination Reports have been

, generally effective. .

NNECo contracted Stone and Webster Engineering Corporai. ion (SWEC),

the AE for Millstone 3, to conduct an Engineering Assurance Program

Technical Audit. NRC review found the audit to be in accordance with

the approved program plan and of sufficient technical depth to

achieve the program objectives. There was a concern that reviewers

~) were not deviating from the review plan as necessary to thoroughly

p[ evaluate.both the adequacy of the design and the adequacy'of the

N desigrc process when potential problems were identif,ied. Also,

interfaces between the major disciplines of the AE audit team needed

improvement to ensure that potential discrepancies in one discipline

was reflected in others. As an outgrowth of the AE audit, NRC is

'/e reviewing the applicant's Seismic II/I program. This consideration

is included in the Licensing Functional Area.

.

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

-

.

.

27

QA/QC personnel were rountinely observed to be performing construc-

tion and preoperational testing functions. During construction,

,

" hold points" for inspection of completed work were readily apparent.

Subsequent reviews of the QA/QC involvement (quality examination,

'

procedure reviews, surveillance, and auditing) indicated logs and/or

i records were being maintained and the results reported. Nonconform-

., ing or unsatisfactory conditions were being followed for corrective

,

action,

,

Overall, the construction at Millstone 3 has been in accordance with

the applicant's commitments and applicable codes and regulations.

Conclusion

Category 1, consistent.

'

- Board Recommendation

. Licensee: Assure more timely closecut of CDRs and outstanding items.

!

l NRC: None.

1

1

i .

4

3

h'

r

d

--.._,.-_,....-..--._,-,,._,.-,..,_,--.m._.m_-_, ,.._.,-.c., , - - . . . .

,,,-,4 --

4._,,_ m.-,,_,,--- . - - ,,__, .,. , , _ . , _ . , ,-,_

. .

.

'

28

J. Licensing Activities

This area was rated Category 2 during the previous SALP, with

recommendations that the licensee continue to take the initiative to

resolve fuel load items and to provide appropriate management involve-

ment in significant review areas. During the current period, NRR

review supported issuance of Safety Evaluation Report Supplements 1

and 2 (March and September 1985) toward resolution of 19 SER open

items, 70 confirmatory items, and 7 license conditions. There were

several NRR on-site, in-depth technical audits in addition to meetings,

conference calls, and review of applicant inputs.

For those items identified as part of the staff's safety review, the

applicant demonstrated prior planning and assignment of priorities.

The applicant continues to take an aggressive approach to complete

unresoived items identified in the staff's SER. There were well-

stated and explicit applicant procedures for activity control. In

general, NNECO assigned technical people as needed to develop com-

plete high quality responses. The fire protection review effort was

a good example of this. Additionally, evidence of prior planning and

assignment of priorities was demonstrated during several on-site

technical audits. Audits were held on schedule and the appropriate

technical and management support was involved so that the NRC staff's

questions were answered with a minimum number of open items after the

audits.

Generally, the applicant exhibited conservatism in its decisions where

safety significance existed. An example of this is the Engineering

Assurance Program. The applicant, on its own initiative, took a sound

and thorough approach to the independent design review, using an

engineering assurance technical audit program performed by Stone &

Webster. Open items identified by S&W during this audit were

vigorously pursued by the utility.

In contrast to the approach taken by the applicant on many SER items,

there were a significant number of review matters for which the

applicant was unresponstve. The applicant did not come forward with

several potential review concerns early in the review process until

NRC forced the issue. In other cases, the applicant persisted in

supporting a position contrary to the staff's requirements. As a

result, several items of potentially high safety significance sur-

faced or remained unresolved late in the review process. High level

NRC management involvement was then necessary to accelerate the

review and assess potential impact on licensing. An example of this

is the Seismic Interaction Program. In this case, the applicant

failed to notify the staff of its planned approach to meet NRC

criteria until that approach was identified by the staff during the

Engineering Assurance Program Audit. It was not until after several

meetings with NRC staff to discuss and agree upon supplementary

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

.

.

.

.

29

<

information that progress was made toward resolution. Other examples

are the shift staffing / operating experience on shift issue and the

Technical Specification review. The position taken by the applicant

on both these matters was that the staff was aware of the applicant's

position early. The applicant did not pursue interaction with

1'

the staff to assure that NRC requirements were met. NRC repeatedly

attempted to work with the utility on shift staffing before the

utility began to be responsive. As a consequence, an inordinate

amount of staff involvement was necessary to complete this review.

The applicant was also unresponsive in regard to the Technical

Specification review. The applicant did not submit the justifi-

cations needed for non-Standard Technical Specifications in a timely

manner. An accelerated review schedule became necessary.

In summary, the applicant has provided satisfactory inputs to the

NRC, but too many items have not been timely.

Conclusion

Category 2, consistent

Recommendation

Licensee: Increase management involvement in the licensing review

process in order to assure more timely resolution of licensing issues.

I

NRC: None

!

t

I

. . _ _ . . _ . _ . _ _ _ - . , _ . . . - , , , _ . _ . . _ , _ . _ , _ . _ _ _ _ _ . _ . _ , _ _ _

_

.. _ _ _ _ . _ . . _ . _ _ _ _ . . . _ _ , _ _ . . - . , .

- . -. - ..- _ - - - - -- . - .. - . . __ - - . . .

-

.

'

.-

30

V. SUPPORTING DATA AND SUMMARIES

A. Construction Deficiency Reports (CORs)

4

The applicant identified 29 items of potentially significant

deficiencies during the assessment period. Subsequently, 3 were

evaluated as not to be reportable by the applicant. At the end of

'

the assessment period, 15 remain open pending resolution of the

issue. The CDRs are listed in Table 1.

{ B. Investigation Activities

One investigation of a painter qualification incident was completed.

'

The report has not been released for public distribution. Another

investigation was in progress but not completed.

C. Escalated Enforcement Action

No escalated enforcement actions were taken this SALP period.

D. Management Meetings

On September 13 and 14, 1984, NRC staff met with Northeast Nuclear

Energy Company at Millstone 3 to discuss LOCA loads and load

combinations used in design of Millstone 3 pipe and component

supports.

On December 17, 1984 at Millstone 3, Waterford, Connecticut, a

management meeting was held to present the results of the Systematic

Assessment of Licensee Performance (SALP) for the assessment period

9/1/83 - 8/31/85.

A periodic management meeting requested by Millstone 3 and Northeast

, Utilities management to discuss the project status and progress was

held on February 8, 1985 at the Region I office.

4

'

A Seismic Qualification Review Team (SQRT) and Pump and Valve

Operability (PVORT) audit was conducted during the week of March 4,

1985 by the NRC staff.

On May 21, 1985, a meeting was held at the Millstone 3 site with the

NRC Radiological Assessment Branch to discuss and verify FSAR

commitments relating to the radiation protection program.

!

On June 21, 1985, a meeting was held at NRC Headquarters to discuss

Seismic II/I design considerations for Millstone 3.

On July 2, 1985, a meeting was conducted at NRC Headquarters to ,

, discuss the Millstone 3 environmental qualification report.

, ,

1

. - - - - ,----r -

y ,, ,,,,.._..,_.-.,,_,.,_,..,_,,,.~,.y ...,._,,ym-~, - - , , . _ , _ . _ _. - , _ , , _ ,

.-.__,...-..y_,,-.,.m., --___..-.....-..-,,,,.,.,,-.,,,m,. - -

. .

.

.-

31

On July 9, 1985, a meeting was. held at the NRC Region I Office to

discuss the status of licensed operator training and of the Millstone

3 project.

On July 11, 1985, a meeting was held with Northeast Utilities to

discuss the Millstone 3 fire protection at NRC Headquarters.

On July 29 and July 30, 1985, an audit of the Millstone 3 Safety

Parameters Display System (SPDS) to perform design verification and

design validation was conducted at the Northeast Utilities General

Offices in Berlin, Connecticut.

On August 1, 1985, a working meeting was held at the NRC Region I

office to resolve emergency planning pre-licensing issues for

Millstone 3.

'A meeting was held on August 6, 1985 at NRC Headquarters to discuss

the applicant's response to questions resulting from the staff's

review of the Millstone Nuclear Power Station Emergency Plan, Draft

2, to Revision No. O, dated January 1985.

. .

, .

TA9LE I

CONSTRUCTION DEFICIENCY rep 0RTS

(September 1, 1984 - August 31, 1985)

MILLSTONE NUCLEAR p0WER STATION, UNIT 3

CAUSE

CRD NO. OEFICIENCY STATUS CODE

84-00-10 Eleven Westinghouse process control cabinets had in- Closed A

ternal wiring which should have been removed at tha

factory

84-00-11 Unqualified motors on safety-related motor-operated Closed A

valves

84-00-12 Potential leakage path in seal of Rosemont Model 1153 Closed * B

Series B pressure transmitters

84-00-13 Problems with Flakt-Bahnson air conditioning units Open* B

84-00-14 Potential failure of auxiliary feedpump wear rings Open B

84-00-15 Oil leak and broken upper bearing housing in contain- Closed B

ment recirculation spray pump motors

84-00-16 GE relays potentially operating in less time than Closed B

the set time delay

84-00-17 Potential cracking of emergency diesel generator Closed A

engine driven lube oil pump discharge nozzle due to

over-torquing

84-00-18 Improper installation of conduit seal for Rosemount Closed F

Pressure Transmitter

85-00-01 Possible material problems with Parker-Hannifin Open B

stainless steel fittings

85-00-02 Jafety grade power supplies tied to control grade Closed B

cables without appropriate isolation devices in

Westinghouse Model 7300 Process Control Cabinets

85-00-03 Potentially inoperable non-motor-operated curtain Open B

type fire damper

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

d

a

j .

o t

i

E

CAUSE

, CRD NO. OEFICIENCY STATUS CODE

4

i

85-00-04 Improper operation of the emergency generator load Closed B

sequencers

,

85-00-05 No drain holes in Foxboro Transmitter junction boxes Closed F

! 85-00-06 Failure of emergency diesel generator 1 sad sequencer Closed B

to shed required loads

,

'

85-00-07 Non-seismically qualified auxiliary. feed pump lube Open B

oil pressure switches

85-00-08 Nonconforming terminations in CVI corporation equip- Open B

ment

4

i

85-00-09 Cooper and Turner load indicating washers with preload Closed * B

out of compliance with design

.

85-00-10 Broken tack welds on feedwater check valves Open E

85-00-11 Emergency diesel generator fuel oil injection pump Open E

.

failures

85-00-12 Improper cable separation for Reactor Protection Closed B

System cables

j 85-00-13 Improper dimensioning of fillet welds on tube steel Closed F

4

connections where skewed angle is less than 45 degrees

t

85-00-14 Structural steel connections in the Main Steam Valve Closed F

Building installed to incorrect welding detail

,

! 85-00-15 Core exit thermocouple total system error exceeds Open B

. error assumed in Westinghouse Emergency Response

4

Guidelines

t

85-00-16 Improper installation of upper reactor internal core Open F

, thermocouple compretsing fitting

i

85-00-17 Seismic failure of Amphenol Triax Connector Open E  !

85-00-18 Potential seismic interaction between the Flux Open B

Mapping System and Seal Table

.

J

' ,

1

- - _ _ _ _ . . _ _ _ . _ . _ _ _ _ _ _ _ _ , , _ , , _ _ _ _ _ _ _ . - _ _ . , _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ . - - _ - , _

.

.

.

3

CAUSE

CDR NO. DEFICIENCY STATUS CAUSE

85-00-19 Potential seismic failure of GE Type PVD21 Differ- Open E

ential Relays

85-00-20 Improper Emergency Diesel generator sequencing Open B

• Licensee subsequently classified item as not reportable

CAUSE CODES

A - Personnel Error

B - Design / Fabrication Error

C - External Cause

D - Defective Procedure

E - Component Failure

F - Site Construction Error

l

1

i

,_ _ . - _ _ - ,-_ .__

. .

.

!

4

TABLE 2

INSPECTION HOURS SUMMARY (9/1/84 - 8/31/85)

MILLSTONE NUCLEAR POWER STATION, UNIT 3

Functional Area Hours % of Time

A.: Operations Supports 552 7

B. Radiological Controls 181 2

C. Maintenance 169 2

!

D. Surveillance 195 2

'

E. Preoperational Testing 1865 23

F. Fire Protection 172 2  !

G. Emergency Preparedness 140 2

H. Security 84 1 .

I. Construction 4774 59

J. Licensing Activities -- -- l

3 TOTAL 8201 100

'

NOTE: The above values are approximate.

t

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1

'

f

,

- + < mm u -m__,*.=>w~--,,+y-----w~~.--me-- ,w-e------n-w-+mv-wwm, % mvv - ~ . - %4we,--,-we-m, >----ev---+-r--- - - ,

- - _ _ . - _ _ __. - . - . -- - _ _ - - _ _ . . ~ .

.

.

_, .

5

i

TABLE 3

INSPECTION ACTIVITIES

MILLSTONE NUCLEAR POWER STATION, UNIT 3

'

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

84-14 Resident Open items; preoperational testing; incore

8/19 - 9/29/84 114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br /> thermocouples; structural settlement monitoring

program; procedures; diesel fuel storage; lic-

ensee/ contractor self audits; significant deft-

ciencies; ACRS items.

84-15 Specialist Previous SALP period.

84-16 CANCELLED

84-17 Specialists Preoperational test program review including i

9/17 - 21/84 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> program requirements, control of documents, test

procedures, engineering drawings, manuals, de-

sign changes and modifications, jumpers and by-

passes; plant maintenance, preventive mainten-

ance, and maintenance records; test procedure

, reviews and test results evaluations.

84-18 Specialists Followup on previous inspection findings; work

9/17 - 21/84 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> observation; review of QC of pipe supports.

84-19- 1984 Millstone Unit 3 SALP.

84-20 Resident Follow-up on previous inspection findings; start-

9/30 - 11/10/84 266 hours0.00308 days <br />0.0739 hours <br />4.398148e-4 weeks <br />1.01213e-4 months <br /> up test program review and observation; event

follow-up; welding electrode control; training;

i

maintenance; construction; and housekeeping.

I

84-21 Specialists Facility tour; pipe and pipe support welding;

10/15-19/84 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> copper-nickel welding; repair welding; and

follow-up on open items.

'

84-22 Specialists Follow-up on open items; preoperational test

10/15-19/84 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> program requirements and implementation; test

procedure review and witnessing emergency diesel

generator set test verification; and facility

tour.

84-23 Specialists Installation of safety-related electrical and l

10/22-26/84 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> instrumentation system components.

l

I

'

. - - - . - - - _- - _ ----__ -_ - - - -.. . - -. --- - - -

_ _ - _ _ _ _ _ _ _ _ _ _ _ __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

!

. -

.

l

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(

6 ,

r

4

INSPECTION REPORT INSPECTION /

,

NUMBER AND DATES HOURS AREAS INSPECTED

. 84-24 Specialists Preoperational test program requirements and

l 11/5-9/84 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> implementation; test results evaluation and

witnessing; auxiliary boiler repair and testing;

.

preparations for' steam generator hydrostatic

.

I

testing; quality assurance and quality control;

facility tour.

84-25 Resident Preoperational testing; follow-up on open items;

11/11/84-1/7/85 192 hours0.00222 days <br />0.0533 hours <br />3.174603e-4 weeks <br />7.3056e-5 months <br /> control room practices; plant tours; control

. rod drive fabrication review; event follow-up;  !

IE Notice review; implementation of security i

measures; audit activities; fire protection i

testing; hazards program review; changes to i

plant management; and Tubeco repairs,

i

84-26 Specialists Preoperational test program requirements and

. 11/26-12/5/84 134 hours0.00155 days <br />0.0372 hours <br />2.215608e-4 weeks <br />5.0987e-5 months <br /> implementation; test procedures and results

i

12/ 3- 5/84 results review; steam generator hydrostatic

I

12/10-12/84 testing; quality assurance and quality control;

,

and facility tours.

+ 85-01 Specialists Construction Deficiency Reports

j 1/8-10/85 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />

.85-02 Resident Preoperational testing; previous inspection ,

1/9-2/4-85 151 hours0.00175 days <br />0.0419 hours <br />2.496693e-4 weeks <br />5.74555e-5 months <br /> findings; control room practices; plant tours; '

potential significant deficiencies; flushing

'

program activities; IE Bulletins; allegations;

' valve positioning anomalies; fuel receipt pre-

parations; service water hydraulic testing;

safety injection plump test ar.o aly. '

85-03 Specialists Preoperational test program requirements and

, 1/21-?5/85 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> implementation; test procedure and results re-

i

views; test witnessing; auxiliary boiler status;

quality assurance and quality control; and

l facility tours.

} 85-04 Specialists Construction appraisal team: Electrical and in-

2/19-3/1/85 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> strumentation construction; mechanical con-

3/11-22/85 struction; welding and non-destructive examin-

' ation; civil and structural construction; mate- ,

rial traceability and control; design change  !

control; corrective action systems. i

1

l

i

l

!

!

,

- ..

-

.

. *

7

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

85-05 Resident Review of activities including refueling cavity

2/5-3/18/85 183 hours0.00212 days <br />0.0508 hours <br />3.025794e-4 weeks <br />6.96315e-5 months <br /> seal ring leak test, emergency diesel generator

EDG-A gage repair, EDG-A lubrication system

performance, system flushes, hydraulic expansion

of steam generator tubes, emergency plan train-

ing, and FSAR/ design verification maintenance

training; open items; NRC Bulletins, steam

generator field service report; construction

deficiencies; and allegation followup.

85-06 Specialists Preoperational test program requirements and

2/12-15/ 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> implementation; test procedures and results re-

2/25-3/1/85 view; test witnessing; open items; and plant

tour.

85-07 Specialists Combined report for Units 1, 2 and 3: Preopera-

2/11-15/85 31/10 hours ** tional program for operational environmental

monitoring program including management controls,

quality control of analytical measurements,

meteorological monitoring, radiological environ-

mental monitoring program.

85-08 Specialists Installation of safety-related instrumentation.

2/4-7/85 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />

85-09 . Specialists Physical security plan and implementing proce-

2/11-15/85 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> dures for security and audits program, records

and reports, testing and maintenance, locks,

keys, physical barriers, security system power

supply, lighting, assessment aids, access con-

trol, detection aids, alarm stations, communi-

cations, training and qualifications, security

contingency plans and proposed 10 CFR 73.55 and

73.67 plan commitments.

85-10 Specialists Preoperational test program requirements and

, 3/18-22/85 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> implementation; test procedure reviews; test

'

witnessing; open items; reactor coolant systen

hydrostatic test; new fuel receipt and storage;

l quality assurance and quality control; facility

tours.

85-11 Specialists Procedure review, test witnessing, and evalu-

3/25-28/85 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> ation of the preoperational Integrated Leak Rate

Test, Structural Integrity Test, and Local Leak

Rate Test; facility tour.

l

l

t

i

I.

. _ _._ _._ _ _ __ _ _ _ __ _ _ . . _ _ . _ . _ . __ _ _ _ __ __._

.

.

'

.

8 I

i

i

INSPECTION REPORT INSPECTION / '

l NUMBER AND DATES HOURS AREAS INSPECTED L

85-12 Resident Primary cold hydrostatic test and Chemical Ad-

3/18-4/22/85 222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br /> dition Tank Drawdown test witnessing; event I

followup; open items; potential significant  :

deficiencies; IE Bulletins; IE Information No-

tices; steam generator "J" tube inspection; and

preparations for initial fuel receipt.

85-13 Specialists Installation of safety-related electrical and

4/8-12/85 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> instrumentation equipment; quality control

documentation; training of personnel; status ,

of audits and findings. C

85-14 Specialists Preoperational test program review; test proce-

4/8-27/85 121 hours0.0014 days <br />0.0336 hours <br />2.000661e-4 weeks <br />4.60405e-5 months <br /> dural review, witnessing, and evaluation; open  !

items; emergency diesel generator status; reac-  !

tor coolant system cold hydrostatic test wit- i

ness; new fuel receipt inspection and storage;

l quality assurance and quality control inter- }

j faces; facility tour.

[ 85-15 Examiner Oral, written and simulator examinations for ,

i

5/14-17/85 sixteen Senior R(actor Operators and five Reac- l

l tor Operators.

!

l 85-16 Resident Observation of limited emergency exercise; event  !

l 4/23-5/27/85 268 hours0.0031 days <br />0.0744 hours <br />4.431217e-4 weeks <br />1.01974e-4 months <br /> followup; auxiliary feedwater pump flushing;

field welding; ultrasonic testing of low pres-

sure safety injection system; and eddy current '

testing of a steam generator.

l 85-17 Examiner Use of Millstone 3 simulator for NRC operator I

3/25/85 licensing examinations, i

(

'

85-18 Specialists Preoperational test program implementation;

5/6-10/85 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> engineered safety feature test status; emergency i

diesel generator status; pre-core hot functional l

test status; test procedure review and verifi-  !

cation; new fuel receipt, inspection and stor-

age; turbine building hot functional test status;

quality assurance and quality control; facility i

tours.

85-19 Specialists Preoperational status pertaining to radiation

t 5/7-10/85 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> protection and radioactive waste management, l

l

including organization, personnel training and

qualifications, facilities and equipment, and

procodure development.

I

l

l

l

_ _ _ _ _ _ - - __

,

"

, .

1

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

85-20 Specialists Safety-related pipe welding; Post Weld Heat

5/13-17/85 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> Treatment of containment shell penetrations;

reactor vessel clevis hard surfacing; review

of in progress work including welding; allega-

tion followup; and review of service water clad

l elbow leakage.

85-21 Specialists Maintenance program; I&C program; and quality

5/13-17/85 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> assurance and quality control interfaces.

85-22 Specialists NRC independent measurements inspection using

5/20-6/14/85 575 hours0.00666 days <br />0.16 hours <br />9.507275e-4 weeks <br />2.187875e-4 months <br /> the Mobile Nondestructive Examination Laboratory

on selected safety-related piping fabricated

to ASME Code Section III, Classes 1, 2, and 3.

l 85-23 Resident Open items; facility events; Type C leak rate

! 5/20-6/14/85 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> testing; and vital batteries.

!

85-24 Specialists Preoperational test program implementations;

5/20-24/85 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> emergency diesel generator status; pre-core hot

functional test status; test procedure review

and verification; new fuel receipt, inspection

i

'

and storage; quality assurance and quality con-

trol interfaces; facility tours.

85-25 Specialists Preoperational test program; test procedure re-

6/24-27/85 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> views and witnessing. Emergency diesel genera-

i 8/8-11/85 tor status; quality assurance and quality con-

trol; end identification of new EDG components.

l

85-26 Resident Steam generator "J" tube modifications; eddy

5/28-8/8/85 (31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> current testing and tube plugging; preparations

for Containment Structural Integrety Test; IE

Bulletins; Preoperational testing.

85-27 Specialists Prooperational test program; EDG status; pro-

6/3-7/85 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> posed technical specifications status and re-

view; test procedure review and verification;

! engineered safety features tests; pre-core hot

l functional tests; valve problems; turbine

l building hot functional tests; containment HVAC;

l new fuel receipt, inspection and storage; qual-

I

ity control and quality assurance interfaces;

facility tours.

85-28 Specialists Installation of safety-related instrumentation

6/3-7/85 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> and associated control circuits.

1

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

-

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10

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

85-29 Specialists Engineering Assurance In-Depth Technical Audit:

5/28-29/85 inspection of the program preparation.

85-30 Specialists Continuation of Preoperation Security Reviews;

6/17-21/85 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> review of receipt, storage, and protection of

new fuel.

85-31 Specialists Engineering Assurance Program Technical Audit

6/24-28/85 Implementation: inspection of program

85-32 Specialists Followup of violations, unresolved and construc-

8/8-12/85 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> tion deficiency reports; verification of FSAR

commitment to Reg. Guide 1.94 for exemptions

from concrete testing.

85-33 Specialists Containment leakage testing program: review,

7/5-15/85 106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> witnessing and evaluation of integrated leak

rate test, structural integrity test, and local

leak rate test, and online primary containment

leakage monitoring; facility tour.

85-34 Specialists Installation of safety-related electrical /in-

7/8-12/85 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> strumentation components and associated cir-

cuits; quality control documentation and open

items.

85-35 Resident Preoperational inspections; repairs to condenser

7/9-8/12/85 201 hours0.00233 days <br />0.0558 hours <br />3.323413e-4 weeks <br />7.64805e-5 months <br /> air piping; auxiliary feed pump endurance runs;

allegations; electrical termination for diesel

generators; event follow up; steam generator

wet layup; status of reactor water level moni-

toring; and status of Safety Paramater Display

System.

85-36 Specialists QA/QC administration; audit program; procurement

7/22-26/85 111 hours0.00128 days <br />0.0308 hours <br />1.835317e-4 weeks <br />4.22355e-5 months <br /> program; receipt, storage and handling program;

record storage program and document control

program.

85-37 Contractor inspection / evaluation of specific aspects of

l 7/8-19/85 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> licensee's Probabilistic Safety Study to assess

l

whether significant discrepancies exist between

l Technical Specifications, the Final Safety An-

l alysis Report, the Safety Evaluatien Report,

'

and the as-built configuration.

l

l

l

l

-_ - - - - _ _ _ . - - -- _. ~ _ - . ._ _ - - -

l .

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, *

[

11

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

85-38 Specialists Preoperational test program procedure review,

7/15-19/85 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> test witnessing and evaluation; ESF test status;

l

Emergency Diesel Generator status; Quality As-

surance and Quality Control; ESF valve testing.

85-39 Specialists Emergency Planning Implementation Appraisal;

1 7/22-26/85 organization, training, emergency facilities,

! equipment and emergency implementing procedures.

85-40 Examiner NRC licensee meeting to discuss operator lic-

7/8/85 ensing examinations for Millstone 3. '

85-41 Specialists Quality records and work activities related to

8/5-9/85 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> the inspection and testing of safety-related

electrical equipment and open items.

85-42 Specialists Chemistry and radioactive effluent control pro-

8/5-9/85 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> grams organization, and staffing, training and

qualification facilities, equipment, plans, and

procedures.

85-43 Specialists Preoperational test program procedure review,

8/5-9/84 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br /> test witnessing, and evaluation; review status

emergency diesel generators; engineered safe-

guards test status; quality assurance and

quality control.

85-44 Examiners Oral, written, and simulator examinations for

Senior Reactor Operators and Reactor Operators.

! 85-45 Examiners October 1985 examinations, outside the SALP

assessment period.

85-46 Specialists Open item followup; ASME Code N-5 certification

l 8/12-16/85 226 hours0.00262 days <br />0.0628 hours <br />3.736772e-4 weeks <br />8.5993e-5 months <br /> program; stress reconciliation program, struc-

tural steel bolting; welding (structural steel,

pipe support, tack weld); preservice inspection

data for RCS piping; applicants response to IE

l Bulletin 79-02.

85-47 Specialist Dosimetry program: open items, organization

8/5-9/85 75/25 hours ** personnel selection, facilities and equipment,

calibrations, dose assessment, quality assur-

ance, documentation and recordkeeping, indepen-

dent performance.

l

.

.

.

12

INSPECTION REPORT INSPECTION /

NUMBER AND DATES HOURS AREAS INSPECTED

85-48 Specialists Continuation of preoperational security reviews;

8/5-9/85 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> review of receipt, storage and protection of

new fuel, review of proposed consolidated site

'

security.

85-49 Specialists Operational Quality Assurance Program for design

8/19-23/85 107 hours0.00124 days <br />0.0297 hours <br />1.76918e-4 weeks <br />4.07135e-5 months <br /> changes and modifications, tests and experiments,

measuring and test equipment, and Safety Com-

mittee activities.

85-50 Specialists Allegation and open item followup in electrical

8/12-16/85 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> area.

85-51 Specialists Preoperational test program OIL witnessing of

8/19-9/13/85 184 hours0.00213 days <br />0.0511 hours <br />3.042328e-4 weeks <br />7.0012e-5 months <br /> Engineered Safeguards Features (ESF) tests,

reactor plant component cooling water pump per-

formance test, normal service station transfor-

mer test, and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing of Emergency

Diesel Generator EDG-3; test result evaluation;

and assessment of EDG status.

85-52 Resident Review of Main Condenser Structural

8/13-9/23/85 238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br /> Reports, diesel generator reliability, Three

Mile Island items, main steam indication

and cable repair, Safety Evaluation Report

Items, prevention of cable damage,

potentially significant deficiencies and

open items.

85-53 Specialists Capability to shutdown plant in event of design

8/19-9/23/85 172 hours0.00199 days <br />0.0478 hours <br />2.843915e-4 weeks <br />6.5446e-5 months <br /> basis fire; emergency lighting; reactor coolant

pump oil collection system.

• • - Site inspection; Millstone 3 one-third of total hours.

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TABLE 4

ENFORCEMENT DATA

(September 1, 1984 - August 31, 1985)

MILLSTONE NUCLEAR POWER STATION, UNIT 3

A. Number and Severity level of Violations and Deviations

1. Severity Level

Severity Level I 0

Severity Level II 0

Severity Level III 0

Severity Level IV 11

Severity Level V 2

Deviations _1

14

B. Violations and Deviations vs. Functional Area

Severity Level

Functional Area IV V Deviations

A. Operations 0 0 0

B. Radiological Controls 0 0 0

C. Maintenance 0 0 0

D. Surveillance 0 0 0

E. Preoperational Testing 3 0 0

F. Fire Protection 0 0 1

G. Emergency Preparedness 0 0 0

H. Security 0 0 0

I. Construction 8 2 0

J. Licensing Activities 0 0 0

TOTAL 11 2 1

. .

, .,

14

C. Listing of Violations and Deviations

SEVERITY FUNCTIONAL

REPORTS DATES SUBJECT REFERENCE LEVEL AREA

84-20 9/30-11/10/85 Failure to maintain Appendix B IV I

control of low hydrogen Crit. IX

welding electrodes

84-23 10/22-26/85 Failure to follow elec- Appendix B V I

trical installation Crit. V

procedures

85-04 2/19-3/1/85 Failure to translate Appendix B IV I

3/11-22/85 class IE wiring design Crit. III

requirements into docu-

ments

Failure to follow in- Appendix B IV I

tructions for post- Crit. V

wiring changes and

document control

Failure to establish Appendix B IV I

measures to assure pur- Crit. VII

chased equipment con-

forms to procurement

documents

Failure to establish con- Appendix B IV I

trols to prevent use of Crit. VIII

incorrect / defective

items

Inspection program did Appendix B IV I

not verify conformance Crit. X

with design documents

Failure to assure con- Appendix B IV I

ditions adverse to Crit. XVI

quality promptly identi-

fled

85-12 3/18-4/22/85 Failure to provide ade- Appendix B IV E

quate procedure for Crit. V

testing and flushing

85-16 4/23-5/27/85 Failure to provide ade- Appendix B. IV E

quate procedure for Crit. V

flushing

. _ _ . _ ._. . _ . . - - - _ _ _ _ _ _ . - - . . _ _ - . _ _ . _ _ - - _ _ _ . _ _ _ _ _ _ _ _ _ . - ~

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SEVERITY FUNCTIONAL

REPORTS DATES SUBJECT REFERENCE LEVEL AREA

l

85-22 5/20-6/14/85 Failure to properly con- Appendix B. IV I

4

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trol nondestructive ex- Crit. IX

aminations

%

Failure to properly Appendix B V I

identify welds on con- Crit. V

trol drawings *

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j 85-23 5/20-6/14 Failure to provide ade- Appendix B IV E ,

quate procedure for Crit. V 4

flushing

85-33 8/19-8/23 Failure to provide hy- Fire Protec- DEV F  !

, drogen recombiner area tion Evalu-

i

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and several floor levels ation Report

of main steam valve en-

closure with fire detec-

, tion and steel members

of ESF building walls

not fire proofed.

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September 17,1985

Docket No. 50-423

B11640

Mr. R. W. S tarostecki, Director

SALP Board Chairman

Division of Project and Resident Programs

U. S. Nuclear Regulatory Comrnission

631 Park Avenue

King of Prussia, PA 19406

Gentlemen:

Millstone Nuclear Power Station, Unit No. 3

Svstematic Appraisal of Licensee Performance (SALP)

As we have stressed in previous meetings with you regarding the SALP program,

Northeast

of Utilities (NU) places high priority on achieving excellence in all areas

performance.

performance in those The SALP ratings provide NU with one assessment of our

areas of activity evaluated by that program and

achievement of superior ratings provides an indication that our management

controls are functioning properly and that our primary corporate goal of striving

for excellence in the maintenance of nuclear safety is being realized.

In the past, we have met to discuss the SALP ratings and NRC's evaluation of our

strengths and potential areas for improvement subsequent to publication of the

initial NRC SALP report. As a result, the initial reports have at times not

considered important information that otherwise could have been strengthened

by an exchange between ourselves and NRC. To maximize the potential for full

consideration of relevant views, we are taking this opportunity to provide some

of

theour

pastperspectives

year. on our level of performance on Millstone Unit No. 3 during

We believe it necessary for us to interact positively with the Staff whenever it is

given the finite resources at the disposal of both NU and the

the interest of further improving the regulatory process and assuring that

through discussion, all aspects of a proposed action are understood and

considered by NRC and NU. A significant f actor which should be considered in

assessing licensee performance is NU's consistent atternpts to further the depth

and quality of the exchange with the regulators, both in terms of interacting

with the NRC and participating actively in efforts to disseminate needed

information to the industry. Northeast Utilities executive management is active

in numerous industry initiatives, having made presentations at public meetings

before the Commission as well as meeting with individual Commissioners where

appropriate. The NU management team is active in, and in some instances chair,

various industry groups addressing a broad range of nuclear issues. We also

.;Q +4. J dl Y

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

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2

consistently attempt to further improve the quality of the regulatory proce

taking the opportunity to provide comments on proposed rulemakings and g

letters as evidenced in the examples provided in Attachment I.

During this SALP assessment period all major construction and test milestone

have been met to support the November,1985 fuel 16ad date.

As of the end of

the management target. August, the Millstone Unit No. 3 project is 98

that have occurred during this SALP period are as follows:Some of the

o

Completed Steam Generator Hydrostatic Test

o

o Completed Reactor Coolant System Hydrostatic Test

o Completed Millstone Unit No. 3 Emergency Drill

o Completed Structural Integrity Test and integrated Leak Rate Test

o

Completed Engineering Safety Features Test

Conducting Turbine Building Hot Functional Test

In June,1985 a!! system turnovers were completed and any building turnove

thatload

fuel remain date.will be completed on a schedule that supports the November ,1985

Licensing activities during this SALP period have been at a high Thelevel.

Mllistone Unit No. 3 Safety Evaluation Report (SER) was issued in July,1934

The SER

conditions. identified 19 open items, 70 confirmatory items and 7 licensin

Most of these items have been resolved and have been or wi

documented in SER supplements. The remaining issuer, have resolution sched

which sup

meetlngs, port the November,1985 fuel load date. During this period numerous

site audits and reviews and conference calls have been held

licensing activities. to suppor

, Also, during thh period several amendments to the FSAR

and to the ER have been submitted to the NRC. NU's responses to SER iss

well as NRC questions resulting from site audits or reviews, show high-leve

and responsiveness to NRC initiatives. management involvement, clea

demonstrating this are provided in Attachment I to this letter. Examples of indivi

Regarding day-to-day licensing activities, our licensing staff is consiste

responsive to the NRC Licensing Project Manager.

As a result of a

been made to improve the interface with NRC by estab  ;

contact within the NU !! censing staff. This has centralized and helped prioritize

the many day-to-day licensing activities occurring between the NRC Lice

routinely Manager and our licensing staff. The NRC Licensing Project Mana

Project

>

j NU's licensing activity status and schedule for response to

!

remaining SER ltems and identified licensing actions to OL issuance.

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In general, we believe that this information may prove useful in your

deliberations

you when the

have any questions, SALP

please contactBoard

us. convenes for Millstone Unit No. 3.

Should

Very truly yours,

-

LE ('uk) c

J. F. Opeka 'l

_ _ .

Senior Vice President

I

_ _ _ 'e -

t)

By: E.M roczka N

Vice Pre ent

cc E. L. Doolittle, Licensing Project Manager, NRR

E. B. McCabe, Chief, Reactor Projects Section 3B, DPRP

T. E. Murley, Regional Administrator

T. Rebelowski, Senior Resident inspector, Millstone Unit No. 3

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ATTACHMENTI

Inputs to SALP Evaluation Process

The following items provide summary examples of some of the meetings, letters

and other

process activities

for Millstone Unit which

No. 3. we believe are relevant to the SALP evalu

The list is not a complete compilation of

pertinent issues and documents and is not intended to suggest that other items

not discussed herein are less important.

-

The NRC staff performed Seismic Qualification Review Team (SQRT)

and Pump

March and Valve Operability (PVORT) Audits during the week of

4,1985.

At the audit exit meeting, the Staff praised the

responsiveness and diligence of NNECO personnel in

questions

audit. raised by the Staff during the document review phase of theanswering

The Staff indicated that all questions raised during the audit

were successfully resolved. The Staff observed that NNECO has a good

qualification program and a thorough understanding of what is required

to maintain seismic qualification throughout the life of the plant.

During the Construction A n sal Team (CAT) Inspection, conducted

between February 19 and

a 22,1985, four Construction Weaknesses

were noted and nubsequeo .. ' ihntified in the Inspection Report (50-

423/85-04).

Although no specific response was required by the

inspection Report, NU provided the NRC our planned course of action

for each of these items in a letter dated July 11, 1985.

We

subsequently received a request from NRC to provide a response to

these weaknesses and to six violations that were identified separately.

Our advanced response to the Identified weaknesses is an example of

Millstone 3 management's commitment to take an aggressive attitude in

responding to NRC concerns and proposing timely corrective actions.

We subsequently responded to the

docketed iollow-up letter. violations in an appropriately

On May 21,1985, a site visit was conducted by the NRC Radiological

Assessment Branch (RAB). The purpose of the visit was to verify FSAR

staffing, radiation monitoring and plant design feature

maintain radiation exposures ALARA. Various aspects of the Radiation

Protection Program and the Health Physics Organization were discussed

with the Health Physics Supervisor and a tour of tne plant was

conducted. The NRC reviewer was very satisfied with the Radiation

Protection Program and the facilities.

The reviewer hdicated that

NNECO had qualified personnel and was well prepared to implement its

Radiation Protection Program.

On June 5,1985 NNECO was granted a schedular exemption to General

Design Criterion (GDC) 4 allowing us to forego the installation of pipe

whip restraints for primary loop piping. This exemption was granted

! based on information provided by NU, Westinghouse and other industry

and agency studies which allowed the NRC Staff to conclude that "the

placement of pipe whip restralnts and jet impingement shields degrades

plant safety, reduces the accessibility for and effectiveness of in-

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service inspection, increases in-service inspection radiation dosages,

and adversely affects construction and maintenance economics." The

NRC

Federal published the proposed modification to GDC 4 in a July 1,1985

Register notice.

-

At NU's option, since this is not a licensinj; requirement, a simulator

training and examination program was developed and implemented for

Millstone Unit No. 3. The Millstone Unit No. 3 simulator was deli

to the site in December 1984. Following installation, the simulator

l

entered

1985. a verification test phase which was completed on January 15,

From January 15, to February 11, 1985, the simulator was used

to test the training program curriculum and to validate the simulator

against this curriculum. On February 11,1985 training on the simulator

commenced. Each cold license candidate receives 5 weeks of simulato

training which includes 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of actual simulator experience, along

with 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> of classroom training. The accelerated program

cuirainated in the administering of the NRC operator licensing exams

on

on Maythe simulator

13,1985. for our first class of cold license candidates, beginning

examination program is an example of NU's proactive stan

responsiveness to NRC initiatives.

-

An a!!egations

the program was developed and implemented. It consists of

following elements:

-

A full-time administrator has been appointed for providing

overall coordination for allegation reviews. He will report

directly to our Vice President-Generation Engineering and

Construction and is located on site.

-

A visible, on-site facility designated the Quality Concern

Office (QCO) has been established where allegations

regarding project safety can be expressed with an individual

independent of Project Management with a guarantee of

anonymity.

stationed at A full-time consultant has been hired and is

the site to work with us in establishing our

allegations program. This consultant has been involved with

worker allegations in the past and is familiar with the

processes being used at other sites.

-

An Allegation Review Team (Review Team) has been

established to review safety concerns raised and to determine

whether or not there is any basis for the allegation. The

Review Team responsibilities are delineated in a specific

project procedure as well as in a specific charter which has

been established.

The Review Team is comprised of key

management personnel who have a wide range of backgrounds

and extensive experience in the nuclear industry.

-

An Independent Review Board is being assembled to conduct

an independent and detailed investigation of any a!!egation

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which has been deterrnined by the Resiew Team to

potentially have substance. This Board will be comprised of

one or more individuals who have expertise an the areas of

labor relations, law, nuclear construction, and quality

assurance / quality control.

.

NRC regulations do not require that an emergency preparedness

exercise be performed for Millstone Unit No. 3 prior to receipt of a

full-power operating license since the operating license for Millstone

Unit No. 3 will not be the first operating license for the Millstone site.

Nonetheless, an onsite emergency preparedness drill for Millstone Unit

No. 3 was conducted on May 15, 1985 to validate the Millstone Unit

No.3 specific aspects of the Millstone Nuclear Power S tation

Emergency Plan. This drill is illust ative of our efforts (beyond those

necessary to obtain an operating license) to assure ourselves that we

are ready to operate Millstone Unit No. 3 in a manner that will

adequately protect the public health and safety. The Millstene Unit

No. 3 drill was quite successful and demonstrated the readiness of our

organization to respond to an emergency at Millstone Unit No. 3.

.

The NRC 5%ff conducted an audit of the Safety Parameter Display

System (SPDS) for Millstone Unit No. 3 on July 29-30,1985. Although a

formal audit report has not yet been received, the NRC Staff indicated

at the ex t meeting that our overall program was quite good and that

they were impressed with the type of program which we ' had

implemented. On a related matter, unsolicited responses to several

NRC concerns were formally provided to the NRC two (2) menths

before the SPDS audit in an attempt to expedite resolution of; these

items during the audit.

-

In the resolution of fire protection issues we believe we have exhibited

a clear understanding of the issues and conservative, sound technical-

approaches are routinely employed. For example, the informatich

provided in support of the suppression systems in the cable spreacing

area and other areas was judged by the NRC staff to be a valid and

acceptable justification for the existing design. Other examples of our

pro-active approach to addressing issues are the ' docketed submittals

and meetings with the NRC fire protection reYiewer Well in advance of

the Fire Protection Audit. We identified potential deviations to the

NRC along with thorough technical justifications in advance to resolve

them without waiting for the audit to be conducted. The NRC Firs

.

Protection Audit for Millstone Unit No. 3 was conducted at the site

from August 19 through 23,1985. The audit was successful in that NRC

questions were promptly addressed and there were very few significant

items requiring followup af ter the audit.

The staff observed that the

engineering analysis for safe shutdown of the plant was one of the best

observed, to date.

There has been a high level of NU management involvement noted by

the auditors for all of the NRR audits conducted at the site. A high

level of management review and approval of all correspondence to the

.<>>

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NRC is procedurally required at NU, this ensures a consistently clear

licensee understanding and reponsiveness to NRC initiatives.

-

In letters dated October 26, 1984 and February 19, 1985, NU provided

documentation of our assurance that Millstone Unit No. 3 had been

designed and constructed in accordance with applicable requirements

based on Stone & Webster Engineering Corporation (SWEC) Engineering

Assurance (EA) Program, our strong Quality Assurance Program and

other verification programs. The NRC concurred on April 17,1985 that

a separate Independent Design Verification Program (IDVP) or an

Integrated Design Inspection (IDI) conducted by the Staff was not

necessary to achieve design assurance for Millstone Unit No. 3 and

approved SWEC's EA audit as an acceptable alternative to a third party

review performed at the end of design and construction efforts.

We feel the above examples serve to provide evidence of some of NU's efforts

and accomplishments in the construction, licensing, and testing of Millstone Unit

No. 3 during this SALP period.

.