ML20153F723
| 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) | |
See also: IR 05000245/1998207
Text
. . _ . . _ __ ._
.,, :., e
_
l
)
September 22,.1998
i
Mr. M; L. Bowling, Recovery Officer - Technical Services
. c/o Ms. P. A. Loftus, Director.- Regulatory -
Affairs for Millstone Station -
)
NORTHEAST NUCLEAR ENERGY COMPANY
'
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
= Your cooperation' with us is appreciated.
Sincerely,
ORIGINAL SIGNED BY:
-]
Jacque P. Durr, Chief
1k
inspections Branch
Millstone Inspection Directorate
Docket Nos. 50-245;50-336;50-423
c, p n t 49
. v U J.1
9809290220 990922
?
ADOCK 050002451
G
PDR g
,
.
.
.
. . .
. . _ - -
-.-
- . _ -
..
. - . - - .
_ . - - -
..
m
1:
L
~ Mr. M. L. - Bowling
2
<
l
cc:
B. Kenyon, President and Chief Executive Officer- Nuclear Group
M. H. Brothers, Vice President - Operations.
l
. J. McElwain, Recovery Officer - Millstone Unit 2
l
-J. Streeter, Recovery Officer - Nuclear Oversight
.
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
.
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
,
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
<
.
. . - -
. - .
.- -
.
.
..-
- . f
. Mr. M. L. Bowlin9
3
- Distribution w/cv of licensee resnonne ltr:
.
.*
Region i Docket Room (with som of. concurrences)
-Nuclear Safety Information Center (NSIC) a
PUBLIC-
FILE CENTER, NRR (with Orlainal concurrences)
"
l. Millstone inspection Directorate Secretarial File, Region i
NRC Resident inspector
H. Miller, Regional Administrator, RI
"
' B. Jones, PIMB/ DISP
W. Lanning, Director, Millstone Inspection Directorate
' D. Screnci, PAO
.
.
4
1
-
,
.
.
..
-
,
.
!
>
t
V
-
1
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
OFFICIAL RECORD COPY
._
d
y ,
-w-
n
,
,
.e
-
.,e
.
.~-
.
- -
---
. , .
.
3
,
'*
1
Ndeast
" Pe Ferry Rd. (Route 156), Wcterford, Cr 06385
' Nuclear Energy
i
m. tone socie., Po.er st.uon
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
JUL 2 71998
I
Docket No. 50-245
B17333
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555
.
s
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
-
gas turbine fuel, as well as generic implications raised by this violation as they relate to
- diesel generator fuel oil across all three Millstone units, are addressed in Attachment 1
r
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.
, mms ur nm
b
I
_
.
.
.
_.
.
__
.._-. . ._
_
_
>
.
.
,.
~
U.S. Nuclear Regul: tory Commission
B17333 \\Page 2
.
'
Commitments associated with this letter are provided in Attachment 2.
4
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
~
-
i
!
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
l
W. D. Travers, Ph.D, Director, Special Projects Office
i
'
,
e
t
I
I
f
.- .
- _ _ - . -
- . . - . . . . - . . -
- - . . .
- .
~
. - .
-
>
. , ,
,
- ' .
.z . --
.
.-
Docket No. 50-245
817333
'
,
r
'
,
- Attachment 1
,
. Millstone Nuclear Station, Unit No.1
Reply to a Notice of Violation in
NRC Combined inspection Report No. 50-245/98-207
..
!
I
i
1
i
.
-
.
^
!
.
>
.
July 1998
)
,
s
_ _.
..
-
_
.-_-
-
. .
. _ _ _ .
_
_
_ _ _ . _ _ _ _
1.
1
.
L.
,
'
U.S. Nucinr Regulttory Commission
B17333\\ Attachment 1\\Page 1
Restatement of the Violation
Criterion Vll of 10 CFR 50, Appendix 8, " Control Of Purchased Material, Equipment,
i
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:
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.
Jet A-1 fuel was requested and ordered without approved design documentation.
.
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.
. 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
-
.
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.
-
.-.
_
_
- _ .
.
-
-
-
- . - . - - --
.- - . - - - - - - - -
. - - .
. - . -
--
-
- .
.
"
.S. Nucle:r R:gulItory Commission
.
U
B17333%ttachment 1\\Page 2
,
,
. The Quality organization and Nuclear Materials Department did not provide
.
effective resolution of issues associated with fuel oil procurement and receipt
inspection brought to management attention.
The Nuclear Oversight organization did not audit procurement or receipt inspection -
.
of bulk consumables, including GTG and EDG fuel oil.
Management failed to effectively resolve the condition when employees came
.
forward with issues adverse to quality.
Corrective Actions Taken and Results Achieved
'
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
>
order. The corrective actions completed to assure that Millstone Station meets the
1
i
requirements of 10 CFR 50, Appendix B Criterion Vll, are as follows:
NNECO has acknowledged the root cause of the Millstone shutdown was ineffective
.
leadership that tolerated performance to-low standards. The specific details of
actions taken to address 16 Key issues, among them Leadership and Procedure
4
Quality and Adherence, are included in periodic reports submitted to the NRC, the
most recent of which was entitled, " Progress Toward Restart Readiness at Millstone
L
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.-
Kerosene was approved for use in the GTG by Design Change Record M1-98009.
,
- .
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
.
buyers at the Millstone site.
The exception in the Northeast Utilities Quality Assurance Program (NUQAP), which
~
.
allowed Chemistry instead of NRG to perform receipt inspection of bulk
O
consumables, including GTG and EDG fuel oil, has been removed. The NRG has
'
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,
that the commercial grade dedication process is complete, and that the MRIR
.
package is complete.
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.
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.
l
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.
.
,
I
The above corrective actions apply to the EDG fuel oil receipt inspection process as
4
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
-
.-
- .-
-
--.
.-
, . - . --
-
-
-_.
.
.,
- l,
I
.
'
.S.' Nucinr Regul: tory Commission
..
U
B17333%ttachment 1\\Page 3
,
~
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.
These corrective actions were in place when Millstone Unit No.1 received a delivery of
3
Kerosene on May 13, 1998, and the receipt inspection activity was performed
successfully.
,
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
to the isolation condenser from the condensate storage tank, and the portable diesel air
4
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
documented in the corrective action plan for CR M1-98-0386, as follows:
,
Procedure COP 600.5 will be changed to reflect the testing requirements of Design
.
,
Change Request M1-98009.
The respective Operations Departments' ordering processes for bulk consumables,
.
t
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.
Nuclear Materials will provide fuel procurement process training to key personnel in
- .
.
the units to make them aware of the fuel ordering requirements and the commercial
J
dedication process for emergency generator fuels.
'
Nuclear Materials will define fuel transpoder responsibilities in accordance with
.
i
NGP 6.05, " 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.
.
-. The NRG will develop an instruction specific to receipt of GTG and EDG fuels.
.
'
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.
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.
l
l
.
- v
.
_.
.
_.
-
-
--
-
! ..
.
i*..
. *
,
U.S. Nucle r Regul tory Commission
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
NNECO is currently in compliance with respect to the cited violation.
j
1
-
1
'
.
..
_.
.
. . _ . .
_ . _ . . . _ . . _ _ _ . .
.
._... , _._ _ . _ . . . . . _ -
.
_ _ . . _ . . _
.
.: . ;'
-.
..
. . .
r.
...
.
- Docket No. 50-245
B17333
,
!
Attachment 2
Millstone Nuclear Power Station, Unit No.1
,
,
1
l
!
(
!
i
'
l
.!
I
1
l '
i
i
i
.
.
.
I
l
!
i
July 1998
i
.
J
i
i
-+v-
-
y
-.
v-.
.
_ ,
.
_
__
._
..
.
_
_ _
l
.
~
'
.
..
. .
-
U.S. Nucirr Regul:' tory Commission -
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
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
replaced with a process which includes contacting the
Nuclear Materials organization and sending the fuel
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,
'
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.
.
-
-