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Ack Receipt of Which Responds to NRC Re Insp Repts 50-245/98-207,50-336/98-207 & 50-423/98-207. Notes That Ltr Only Addresses C/As for Violation Identified at Unit 1 & That C/As for Units 2 & 3 Addressed Separately
	ML20153F723
Person / Time
Site:	Millstone
Issue date:	09/22/1998
From:	Durr J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bowling M; NORTHEAST NUCLEAR ENERGY CO.
References
	50-245-98-207, 50-336-98-207, 50-423-98-207, NUDOCS 9809290220
	Download: ML20153F723 (3)
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September 22,.1998

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Mr. M; L. Bowling, Recovery Officer - Technical Services

. c/o Ms. P. A. Loftus, Director.- Regulatory -

Affairs for Millstone Station - )

NORTHEAST NUCLEAR ENERGY COMPANY

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PO Box 128

Waterford, CT 06385

SUBJECT: - COMBINED INSPECTION NO. 50-245,336,423/98-207

Dear Mr. Bowling:

' This letter refers to your July 27,1998 correspondence, in response to our June 19,1998

' letter. We note that this letter only addresses corrective actions for a violation identified at

Unit 1; and, that corrective actions for violations identified at Units 2 and 3 were

addressed in separate correspondence to the NRC.

Thank you for informing us of the corrective and preventive actions for Unit 1 documented

in'your letter. These actions will be examined during a future inspection of you'r licensed

. program, j

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= Your cooperation' with us is appreciated.

Sincerely,

ORIGINAL SIGNED BY:

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Jacque P. Durr, Chief 1k

inspections Branch

Millstone Inspection Directorate

Docket Nos. 50-245;50-336;50-423

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9809290220 990922 ?

PDR ADOCK 050002451

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~ Mr. M. L. - Bowling 2

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cc:

B. Kenyon, President and Chief Executive Officer- Nuclear Group

M. H. Brothers, Vice President - Operations.

l . J. McElwain, Recovery Officer - Millstone Unit 2

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-J. Streeter, Recovery Officer - Nuclear Oversight

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P. D. Hinnenkamp, Director - Unit 3

l J. A. Price, Director - Unit 2

D, Amerine, Vice President - Human Services

E. Harkness, Director, Unit 1 Operations

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J. Althouse, Manager - Nuclear Training Assessment Group

F. C. Rothen, Vice President, Work Services

'J. Cantrell, Director - Nuclear Training (CT)

.S. J. Sherman, Audits and Evaluation

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cc w/cv of licensee resoonse ltr:

L. M. Cuoco, Esquire.

'J. R. Egan, Esquire

V. Juliano, Waterford Library

J.' Buckingham, Department of Public Utility Control

- S. B. Comley, We The People

. State of Connecticut SLO Designee

D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN

J. M. Block, Attorney, CAN

S. P. Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon -

E. Woollacott, Co-Chairman, NEAC

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. Mr. M. L. Bowlin9 3

- Distribution w/cv of licensee resnonne ltr: .

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Region i Docket Room (with som of. concurrences)

-Nuclear Safety Information Center (NSIC) a

PUBLIC-

FILE CENTER, NRR (with Orlainal concurrences)

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l. Millstone inspection Directorate Secretarial File, Region i

NRC Resident inspector

H. Miller, Regional Administrator, RI

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' B. Jones, PIMB/ DISP

W. Lanning, Director, Millstone Inspection Directorate

' D. Screnci, PAO

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DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\98207U1.RPY

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy

OFFICE Rl/MID [g Rl/MID 4 / l l

NAME NJBLUMBERG JPDURM C

DATE 09pf/98 09pffp8 09/ /98 09/ /98 09/ /98

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OFFICIAL RECORD COPY

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Ndeast " Pe Ferry Rd. (Route 156), Wcterford, Cr 06385

' Nuclear Energy m. tone socie., Po.er st.uon i

Northeast Nuclear Energy Co,npany

P.O. Dos 128

Waterford, CT 06335-0123

(Im0) 447 1791

l'as (IMO) 444 4277

'n.e Nurilen t lisilitica Synicin

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JUL 2 71998 I

Docket No. 50-245

B17333

U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, D.C. 20555

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Millstone Nuclear Power Station, Unit No.1

Reply to a Notice of Violation

NRC Combined Inspection Report No. 50-245/98-207

This letter responds to a Notice of Violation (NOV) contained in the enclosure to the

NRC Combined inspection Report issued on June 19,1998.W The inspection Report

.was issued following an inspection . conducted during the period March 1,1998,

through April 27,1998. The inspection performed an evaluation of the Millstone

Nuclear Power Station Unit No.1 programs, procedures, and operations during

shutdown conditions. The response to the NOV was requested within 30 days of the

date of the letter transmitting the NOV. Northeast Nuclear Energy Company (NNECO)

requested an~ additional ton days to respond to the NOV in a letter dated July 17,

1998.*

Millstone Unit No.1 failed to ensure that measures were established to assure that

purchased material conformed to the procurement documents, and documentary

evidence that material conformed to the procurement requirements was not available

. prior to use of such material in that kerosene was delivered and used in the gas turbine

. generator instead of Jet A-1 fuel as required by applicable procurement doct;ments. In

addition, Millstone Unit No.1 failed to document in receipt inspection reports that the

fuel oil conformed to the procurement documents prior to its use in the emergency gas

turbine generator.~ Various procedural compliance issues related to procurement of the

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gas turbine fuel, as well as generic implications raised by this violation as they relate to

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- diesel generator fuel oil across all three Millstone units, are addressed in Attachment 1

which states NNECO's response to the NOV.

NRC Letter to'NNECO, hRC COMBINED INSPECTION 50-245/98-207; 50-336/98-207

' J 50-423/98-207 and NOTICE OF VIOLATION," dated June 19,1998.

! P . NNECO 1.etter to NRC," Reply to Notice of Violation - Extension of Time to Respond," dated July 17,

1998.

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U.S. Nuclear Regul: tory Commission 1

B17333 \Page 2

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Commitments associated with this letter are provided in Attachment 2.

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Should you have any questions regarding this submittal, please contact Mr. Peter J.

Miner at (860) 440-2085.

Very truly yours,

NORTHEAST NUCLEAR ENERGY COMPANY

, Martin L. Bowling, Jr. V j

Recovery Officer - Technical Services

Sworn to and subscribed before me i

) this AM ' day of !22]o .1998

Y171. I1 AL L

' potary Public' j

My Commission expires l/A//WJ2rD

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Attachments: 1) Reply to a Notice of Violation

2) List of Regulatory Commitments

cc: H. J. Miller, Region I Administrator

S. Dembek, NRC Project Manager, Millstone Unit No.1 i

T. A. Easlick, Senior Resident inspector, Millstone Unit No.1

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W. D. Travers, Ph.D, Director, Special Projects Office

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Docket No. 50-245

817333 '

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- Attachment 1

. Millstone Nuclear Station, Unit No.1

Reply to a Notice of Violation in

NRC Combined inspection Report No. 50-245/98-207

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U.S. Nucinr Regulttory Commission

B17333\ Attachment 1\Page 1

Restatement of the Violation

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Criterion Vll of 10 CFR 50, Appendix 8, " Control Of Purchased Material, Equipment, l

And Services," states in part, that measures shall be established to assure that

purchased. material conforms to the procurement documents, and documentary

evidence that material conforms to the procurement requirements shall be available

prior to use of such material.

Contrary to the above, the licensee failed to ensure that measures were established to

assure that purchased material conformed to. the procurement documents, and

documentary evidence that material conformed to the procurement requirements was

not available prior to use of such material as evidenced by the following examples:

-1. As early as May of 1992, the licensee failed to identify that kerosene was }

delivered and used in the emergency gas turbine generator instead of Jet A-1 fuel as

required by applicable procurement documents.

2. From 1995, until a gas turbine generator fuel oil delivery on May 13,1998, the

licensee failed to document in maintenance receipt inspection reports that the fuel oil

conformed to the procurement documents prior to its use in the emergency gas turbine

generator.

Reasons for the Violation

The root cause of the violation is inadequate program implementation and process

design for the procurement of bulk consumables, including gas turbine generator

(GTG) and emergency diesel generator (EDG) fuel oil, and encompasses the

purchasing, commercial dedication and receipt inspection processes. A number of

factors contributed to the root cause or made the problem worse. These included the

following: l

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Buyers at the corporate office were not adequately trained in QA requirements.

This resulted in a failure to notify Millstone Unit No.1 of the substitution of

Kerosene for Jet A-1 fuel.

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Jet A-1 fuel was requested and ordered without approved design documentation.

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The commercial grade dedication did not require a review of the Bill of Lading from

the fuel vendor to verify that the material received was the same as what was

ordered.

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. Receipt inspectors were not always contacted.to participate in receipt of fuel.

After 1995, efforts to streamline the procurement process resulted in the violation of

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10CFR50, Appendix B criteria as evidenced by removal of Procurement inspection -

Services (now known as the Nuclear Receiving Group [NRG]) from the receiving

process, revisions to the standard ordering process which allowed phone orders for

fuel to be placed, removal of commercial grade dedications from the process, and

elimination of the Material Receipt inspection Report (MRIR) from the process.

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U .S. Nucle:r R:gulItory Commission

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B17333%ttachment 1\Page 2

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. The Quality organization and Nuclear Materials Department did not provide

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effective resolution of issues associated with fuel oil procurement and receipt

inspection brought to management attention.

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The Nuclear Oversight organization did not audit procurement or receipt inspection -

of bulk consumables, including GTG and EDG fuel oil.

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Management failed to effectively resolve the condition when employees came

forward with issues adverse to quality.

Corrective Actions Taken and Results Achieved

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Condition Report (CR) M1-97-2525 identified that the fuel being supplied by the vendor

to Millstone Unit No.1 for the GTG was different than the fuel ordered on the purchase ;

i order. The corrective actions completed to assure that Millstone Station meets the 1

requirements of 10 CFR 50, Appendix B Criterion Vll, are as follows:

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NNECO has acknowledged the root cause of the Millstone shutdown was ineffective

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leadership that tolerated performance to-low standards. The specific details of

actions taken to address 16 Key issues, among them Leadership and Procedure

Quality and Adherence, are included in periodic reports submitted to the NRC, the

L most recent of which was entitled, " Progress Toward Restart Readiness at Millstone

Station," submitted on May 22,1998. It is believed the instances of failure to resolve

the fuel oil issues brought to management are indicative of those weaknesses.-

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-. Kerosene was approved for use in the GTG by Design Change Record M1-98009.

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QA purchase orders for GTG and EDG fuels are processed in accordance with ;

procedure NGP 6.02, Quality Material Requests and Quality Purchase Orders, by

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buyers at the Millstone site.

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The exception in the Northeast Utilities Quality Assurance Program (NUQAP), which ~

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allowed Chemistry instead of NRG to perform receipt inspection of bulk !

consumables, including GTG and EDG fuel oil, has been removed. The NRG has l

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the responsibility to ensure that the correct fuel is received at the site, that the I

documents pertaining to the receipt inspection activities are complete and accurate,

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that the commercial grade dedication process is complete, and that the MRIR

package is complete.

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The commercial grade dedication process applies to GTG and EDG fuel oil

purchases. The dedication requires the receipt inspectors to review the Bill of

i- Lading from the vendor and match it to the purchase order.

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The common operating procedure goveming the fuel receipt process, COP 600.5,

" Fuel Oil Delivery Sampling Requirements," has been changed to require

notification of the NRG when fuel arrives at the site.

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Fuel' vendor delivery records for diesel fuel and delivery acceptance surveillance

[ records for all three units were reviewed and show that the diesel fuel delivered for

[ the emergency diesels is what was ordered.

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I The above corrective actions apply to the EDG fuel oil receipt inspection process as i

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, well as to that for the GTG fuel. -The NUQAP and the common operating procedure,

COP 600.5, govern both diesel fuel and aviation fuel for all Millstone units. The root

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U .S.' Nucinr Regul: tory Commission

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B17333%ttachment 1\Page 3

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cause and corrective actions taken to resolve the fuel issues are generic in nature and

apply to the process of procuring diesel fuel and other bulk consumables for Millstone

Station.

The corrective actions completed to date have resulted in a return to full compliance.

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These corrective actions were in place when Millstone Unit No.1 received a delivery of

Kerosene on May 13, 1998, and the receipt inspection activity was performed

successfully.

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Corrective Actions to Prevent Recurrence

Nuclear Materials has identified other fuel driven equipment on site to determine if the

correct fuel is being used and if appropriate procurement documents are in place. The

components reviewed include the meteorology tower generator, the diesel driven fire ,

pump, the emergency operations facility diesel generator, the security diesel generator, i

the station black out emergency diesel generator, the portable tornado make-up pump !

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to the isolation condenser from the condensate storage tank, and the portable diesel air

compressors supplying air to the Millstone Unit No. 3 engineered safety features

,. building sump pumping subsystem.

j Additional corrective actions to enhance and strengthen the process will be taken and ;

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documented in the corrective action plan for CR M1-98-0386, as follows: I

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Procedure COP 600.5 will be changed to reflect the testing requirements of Design

Change Request M1-98009.

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The respective Operations Departments' ordering processes for bulk consumables,

including GTG and EDG fuel, will be modified to conform to the requirements of

NUC MPM 1.00, " Requesting items and Services." The authorization for placing

verbal orders to the fuel transporter will be removed and replaced with a process

which includes contacting the Nuclear Materials organization and sending the fuel

i supplier a written acknowledgment of the order requirements.

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Nuclear Materials will provide fuel procurement process training to key personnel in

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the units to make them aware of the fuel ordering requirements and the commercial

dedication process for emergency generator fuels.

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. Nuclear Materials will define fuel transpoder responsibilities in accordance with

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NGP 6.05, " Processing and Control of Purchased Material, Equipment, Parts and

Services," and issue a purchase order to the transporter. Special handling and

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cleanliness requirements will be defined by Procurement Engineering.

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-. The NRG will develop an instruction specific to receipt of GTG and EDG fuels.

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NRG-006, " Receipt inspection Activities," defines receipt inspection activities, but

given the unique circumstances involved with receiving fuel oil, e.g., receipt location

is remote to receiving area, a specific instructi6n will be created.

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. Purchase orders will be initiated to supply fuel to the meteorology tower generator ,

l and the diesel-driven fire pump which have augmented quality requirements for -

i their fuel.

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U.S. Nucle r Regul tory Commission 1

B17333%ttachment 1\Page 4

Nuclear Materials will request that Nuclear Oversight audit the areas of procurement

and receipt inspection of bulk consumables, including GTG and EDG fuels, during

the next audit of the procurement area.

The Root Cause and Corrective Actions taken to resolve the fuel issues are generic in

nature and apply to the process of procuring diesel fuel and other bulk consumables for

Millstone Station. The procedures and processes described above govern material

procurements and receipt inspection with the exception of nuclear fuel. The corrective

actions specified in the action plan will ensure the appropriate level of control and

oversight for ordering and receipt inspection of bulk consumables.

Date When Full Compliance will be Achieved

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NNECO is currently in compliance with respect to the cited violation. j

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- Docket No. 50-245

B17333 ,

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Attachment 2

Millstone Nuclear Power Station, Unit No.1

Regulatory Commitments

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B17333\ Attachment 2\Page 1 '

Attachment 2 1

1.ist of Regulatory Commitments

The following table identifies those actions committed to by NNECO in this document.

Any other actions discussed in the submittal represent intended or planned actions by

NNECO. The Millstone Unit No.1- Manager - Regulatory Compliance should be

notified of any questions regarding this document or any associated regulatory

commitments.

Number . Commitment Due

B17333-01 Procedure COP 600.5 will be changed to reflect the September 4,

testing requirements of Design Change Request M1- 1998

98009. ;

B17333-02 The respective Operations Departments' ordering September 4,

processes for bulk consumables, including GTG and 1998

EDG fuel, will be modified to conform to the

requirements of NUC MPM 1.00, " Requesting items

and Services." The authorization for placing verbal

orders to the fuel transporter will be removed and

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replaced with a process which includes contacting the !

Nuclear Materials organization and sending the fuel

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supplier a written acknowledgment of the order ;

requirements.

B17333-03 Nuclear Materials will provide fuel procurement September 4,

process training to key personnel in the units to make 1998

them aware of the fuel ordering requirements and the

commercial dedication process for emergency

generator fuels.

B17333-04 Nuclear Materials will define fuel transporter September 4, l

responsibilities in accordance with NGP 6.05, 1998

" Processing and Control of Purchased Material,

Equipment, Parts and Services," and issue a purchase

order to the transporter. Special handling and

cleanliness requirements will be defined by

Procurement Engineering.

B17333-05 The NRG will develop an instruction specific to receipt September 4,

of GTG and EDG fuels. 1998

B17333-06 Purchase orders will be initiated to supply fuel to the September 4,

meteorology tower generator and the diesel-driven fire 1998

pump which have augmented quality requirements for

their fuel. -

B17333-07 Nuclear Materials will request that Nuclear Oversight September 4,

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audit the areas of procurement and receipt inspection 1998

of bulk consumables, including GTG and EDG fuels,

during the next audit of the procurement area.

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ML20153F723

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