ML20154C880
| ML20154C880 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/01/1998 |
| From: | Durr J NRC |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-423-97-82, NUDOCS 9810070052 | |
| Download: ML20154C880 (2) | |
See also: IR 05000423/1997082
Text
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October 1, 1998
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: NRC INSPECTION NO. 50-423/97-82- REPLY
Dear Mr. Bowling:
4
This letter refers to your July 15,1998 correspondence, in response to our June 11,
1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, ;
ORIGINAL SIGNED BY
RICHARD J URBAN FOR
Jacque P. Durr, Chief \
Inspections Branch (
Millstone Inspection Directorate
. Docket Nos. 50-245;50-336;50-423
\
cc: 40
B. Kenyon, President and Chief Executive Officer - Nuclear Group /
M. H. Brothers, Vice President - Operations
J. McElwain, Recovery Officer - Millstone Unit 2
J. Streeter, Recovery Officer - Nuclear Oversight )
P. D. Hinnenkamp, Director - Unit 3
. J. A. Price, Director - Unit 2
D. Amerine, Vice President - Human Services j
E. Harkness, Director, Unit 1 Operations
J. Althouse,. Manager - Nuclear Training Assessment Group
F. C. Rothon, Vice President, Work Services
J. Cantrell, Director - Nuclear Training (CT)
'
S. J. Sherman, Audits and Evaluation
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9810070052 981001
PDR ADOCK 05000423
G PDR -
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Mr. M. L. Bowling 2
cc w/ cv of Licensee Response Ltr:
L. M. Cuoco, Esquire
J. R. Egan, Esquire
V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Coritrol
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
Distribution w/cv of Licensee Resoonse Ltr:
Region i Docket Room (with gopy of crancurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
FILE CENTER, NRR (with Oriainal concurrences)
Millstone inspection Directorate Secretarial File, Region i
NRC Resident inspector
H. Miller, Regional Administrator, R1
B. Jones, PIMB/ DISP
- W. Lanning, Director, Millstone inspection Directorate, R1
, D. Screnci, PAO
DOCUMENT NAME: P: 1:\ BRANCH 6\REPLYLTR\9782.RPY
To r:ceive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" =
Copy with attachment / enclosure " N" = No copy
OFFICE . MID/ ORA 3193./ y MID/ ORA gllA/ / l l l
NAME- NJBLUMBERG/db JP,DURRIT gv
DATE 09/L1/98 99/ / /98 ' ) 09/ /98 09/ /98 09/ /98
/" OFFICIAL RECORD COPY-
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N:rthenst R pe Feny RddRouw 1%), Watedord, CT 06385
Nuclear Energy Malstone Nuclear Power Station
Northeast Nuclear Energy Cornpany
P.O. Ilox 128
Waterford, CT 06385-0128
(860) 447 1791
Fax (860) 444-4277
The Northeast Ifailities Sptern
Docket No. 50-423
B17225
July 15,1998
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Millstone Nuclear Power Station, Unit No. 3
NRC 40500 Inspection Report No. 50-423/97-82
Repiv to a Notice of Violation
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By letter dated June 11, 1998, the Nuclear Regulatory Commission transmitted the
results of the above referenced inspection. The letter included a Notice of Violation
citing six areas where Northeast Nuclear Energy Company's (NNECO) activities were
not in compliance with Nuclear Regulatory Commission regulations. NNECO
recognizes that the Corrective Action Program is still maturing and requires continued
management attention to sustain continuous improvements.
Attachment 1 provides a summary of NNECO's commitments contained in this
submittal. Attachment 2 provides NNECO's response to the Notice of Violation items.
Should you have any questions regarding the information contained herein, please
contact Mr. David A. Smith at (860) 437-5840.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
Yk0
Martin L. Bowling, Jr. j
Recovery Officer - Technical Services
Attachments (2)
cc: H. J. Miller, Region i Administrator #
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W. D. Lanning, Deputy Director, inspections, Special Projects Office
J. W. Andersen, NRC Project Manager, Millstone Unit No. 3
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A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3
W. D. Travers, Ph.D., Director, Special Projects Office
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Docket No. 50-423
B17225
Attachment 1
Millstone Nuclear Power Station, Unit No. 3
NRC 40500 Inspection Report No. 50-423/97-82
Summary of Commitments
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U.S. Nuciser Regulttory Commission
B17225\ Attachment 1\Page 1
List of Regulatory Commitments
The following table identifies those actions committed to by NNECO in this document.
Please notify the Manager, Millstone Unit No. 3 Regulatory Compliance at the Millstone
Nuclear Power Station Unit No. 3 of any questions regarding this document or any
associated regulatory commitments. "
Commitment Description Committed Date
Number or Outage
B17225-1 Chemistry Procedure SP 3851, " BAST /RWST Complete
Boron Concentration" has been revised to direct
Chemistry technicians to obtain boron samples
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from the discharge side of the pump at the '
instrumentation root block valve.
B17225-2 A special procedure (SPROC EN98-3-07) was Complete
implemented to demonstrate the effectiveness
of the changes in the preclusion of air being
entrained into the system during the batching
process. This was successfully completed and
appropriate modifications have been
incorporated into Operating Procedure (OP)
3304C.
B17225-3 OP 3260E will be revised to clarify the July 27,1998
requirements for closeout of Operator
Workarounds.
B17225-4 OP 3260E will be revised to require that July 27,1998
Operator Workarounds will result in the initiation
of a Condition Report in accordance with RP 4,
" Corrective Action Program".
B17225-5 initiate a Condition Report for each existing July 24,1998
Operator Workaround.
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B17225-6 NOQP 3.04 has been revised to identify the Complete
requirement that the procedure requires SORC
review.
B17225-7 NOQP 1.02, " Nuclear Oversight Department Complete
arid Quality Program implementing Procedures"
has been revised to include performing a review
of new procedures or scope changes'for
existing procedures to determine if SORC
review is required.
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B17.225\ Attachment 1\Page 1 I
Commitment Description Committed Date
Number or Outage !
B17225-8 Procedure OA 10 " Millstone Station Complete
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Maintenance Rule Program" was revised to add
the requirement for the Maintenance Rule
Group to notify the owner of the DBS when '
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there is a change to the Group 1 and Group 2 j
lists. '
B17225-9 NNECO has determined that thirteen MP3 February 28,1999 I
systems, or portions of systems, associated with
Maintenance Rule Group 1 and Group 2
systems do not have DBSs. Among these <
thirteen systems are Emergency Lighting and
portions of the Chemical and Volume and {
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Control System. DBSs will be developed for
these systems.
B17225-10 The Design Control Manual (DCM) will be September 30,1998
revised to incorporate U3 Pl 29 to transfer the
development and maintenance of DBSs from
Configuration Management Program (CMP)
activities to the permanent design process. This
revision will include clarification and procedural
requirements for work practices concerning
Maintenance Rule Group 1 and 2 systems
without DBSs. This revision will include l
guidance on actions required in the interim I
period between when a new or revised DBS is
required and when it is finally issued. '
B17225-11 The Design Control Manual (DCM) has been Complete
revised to incorporate instructions on updating ;
and handling the SFR Manual.
B17225-12 Perform coaching for Nuclear Engineering August 31,1998
personnel, including management, to
communicate the expectations for procedural
compliance per DC-4, processing of DBDP -
SFR Manuals per NGP 5.28, processing of the
SFR Manual per DCM Chapter 12, and the use
of the DCM in general.
B17225-13 Perform a sample review of Nuclear December 1,1998
Engineering design change products issued
after June 30,1997 to verify that they have
been administratively processed and controlled .
in accordance with appropriate procedures.
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B17225%ttachment 1\Page 3
Commitment Description Committed Date
Number or Outage
B17225-14 On December 18,1997, NNECO implemented a Complete
new station procedure RAC 13, " Organizational
Changes." This procedure describes the
process to evaluate and implement
organizational changes to ensure changes are
made in compliance with all regulatory
requirements. The use of this procedure will
avoid implementing organizational changes that
are contrary to the Licensing Basis.
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Docket No. 50-423
B17225
Attachment 2
Millstone Nuclear Power Station, Unit No. 3
NRC 40500 Inspection Report No. 50-423/97-82
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Response to a Notice of Violation
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B17225\ Attachment 2\Page 1 l
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Nuclear Reaulatory Commission Violation "A.1" (50-423/97-82-06) l
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Restatement of the Violation
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Criterion XVI of 10 CFR 50, Appendix B, requires, in part, that measures'must be
established to assure that conditions adverse to quality, such as failures, malfunctions, l
deficiencies, deviations, defective material and equipment, and nonconformances are
promptly identified and corrected. For significant conditions adverse to quality,
measures shall assure that the cause of the condition is determined and corrective
action taken to preclude repetition.
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Contrary to the above, between 1992 and 1998, appropriate corrective actions were not
taken to prevent a recurring air binding problem for the boric acid transfer pumps. The
boric acid transfer pumps are part of Technical Specification required reactivity control ;
systems and provide a boron injection flow path to the Reactor Coolant System. There
has been a chronic air binding problem with the pumps that periodically rendered the
, sub-system inoperable. The condition had been identified six times, but had not been
corrected.
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NNECO's Resoonse
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NNECO agrees with this violation.
Reason for the Violation
- Root cause investigations were not procedurally required to be completed for events
prior to 1997 and, therefore, were not consistently performed. Condition Report (CR)
M3-98-0975 was initiated to re-evaluate the initial root cause investigation performed
under CR M3-97-0954. This subsequent investigation was more detailed, and involved
testing to confirm the sources of air into the Boric Acid piping (SPROC EN98-3-07).
The final root cause investigation determined that the air binding of the Boric Acid
transfer pumps was due to an inadequate initial design of the Boric Acid system piping
configuration which allowed air to be introduced during the Boric Acid batching
process. This design inadequacy was compensated for by procedural and work
practice barriers which were ineffective in preventing air intrusion into the system.
This violation was addressed by NNECO in Millstone Unit No. 3 Licensee Event Report
(LER) 98-016-01, dated May 18,1998. (Reference NNECO letter to USNRC, B17173).
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U.S. Nuclear Regulatory Commission
B17225\ Attachment 2\Page 2
- Corrective Actions That Have Been Taken and Results Achieved
Vent valves have been installed in the gravity boration piping to preclude a build up of '
air / gas in the system following maintenance activities.
Chemistry Procedure SP 3851, " BAST /RWST Boron Concentration" has been revised
to direct Chemistry technicians to obtain boron samples from the discharge side of the
pump at the instrumentation root block valve.
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A briefing sheet was provided to Unit 3 Operations, Maintenance and Chemistry
personnel to communicate the findings of the root cause investigatio.i.
A special procedure (SPROC EN98-3-07) was implemented to demonstrate the
effectiveness of the changes in the preclusion of air being entrained into the system
during . the batching process. This was successfully completed and appropriate
modifications have been incorporated into Operating Procedure (OP) 3304C. The
, revision to OP 3304C has reduced the potential to entrain air in the boric acid piping
during the batching process. In addition, OP 3304C directs operators to start the
transfer pump on mini-flow recirculation, and to flush any gas bubbles that may have
become entrained out of the system.
Root cause evaluations are required to be performed on significant conditions adverse
to quality in accordance with the RP 4, " Corrective Action Program." RP 6, " Root
Cause Analysis," provides guidance on the performance of root cause analysis.
Corrective Actions That Will Be Taken to Avoid Further Violations
No further corrective actions will be taken. -
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Date When Full Compliance Will Be Achieved
NNECO is in full compliance.
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U.S. Nuclear Regulatory Commission
B17225\ Attachment 2\Page 3
Nuclear Reaulatory Commission Violation "A.2" (50-423/97-82-08)
Restatement of the Violation !
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Criterion XVI of 10 CFR 50, Appendix B, requires, in part that measures must be
established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, defective material and equipment, and nonconformances are
promptly identified and corrected. For significant conditions adverse to quality,
measures shall assure that the cause of the condition is determined and corrective
action taken to preclude repetition.
Contrary to the above, appropriate corrective actions were not completed prior to
closing an automated work order (AWO) associated with a modification to correct flow
indication anomalies on service water instrumentation. Specifically, final setpoint '
calibrations for flow indicators 3SWP-F1-059 A, B and C had not been accomplished
, prior to closing the AWO.
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NNECO's Response
NNECO agrees with the violation.
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Reason for the Violation
NNECO has reviewed the Automated Work Orders (AWO) associated with the
modification to correct flow anomalies in the service water inst'umentation r and has
determined that the work orders were closed in accordance with program implementing
procedures. However, NNECO agrees that the Operator Workaround (OWA)96-003,
associated with this modification was not closed in accordance with the program
implementing procedures. At the time of occurrence, the Operator Workaround
process was not included in the Corrective Action Program (RP 4).
The inappropriate closure of Operator Workarourid 96-003 was caused by human error
through procedural non-compliance due to a lack of knowledge of requirements and
insufficient procedural guidance. The Unit Supervisor directed the Shift Technician to
close Operator Workaround (OWA)96-003 without the proper procedural steps of
- Operating Procedure (OP) 3260E being performed.
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U.S. Nuclect R:gulatory Commission
B17225\ Attachment 2\Page 4
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Corrective Actions That Have Been Taken and Results Achieved !
Operator Work Around 96-003 was reinstated and then closed on April 4,1998, in I
accordance with program implementing procedure OP 3260E.
A briefing sheet was provided to the Unit 3 Operations department personnel, including
the Unit Supervisor, to provide clearer direction on closure of OWAs in reference to
OP 3260E.
Corrective Actions That Will Be Taken to Avoid Further Violations 1
OP 3260E will be revised to clarify the requirements for closeout of Operator
Workarounds. This will be completed by July 27,1998.
OP 3260E will be revised to require that all Operator Workarounds will result in the ;
, initiation of a Condition Report in accordance with RP 4,' Corrective Action Program". '
This will be completed by July 27,1998.
Initiate a Condition Report for each existing Operator Workaround. This will be
completed by July 24,1998.
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Date When Full Compliance will be Achieved
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Full compliance has been t tieved. i
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U.S. Nucl=r Regulatory Commission
B17225\ Attachment 2\Page 5
fJnclear Reaulatory Commission Violation "B" (50-423/97-82-05)
Restatement of the Violation
Technical Specifications 6.2.3.1 and 6.5.2.6 require the Site Operations Review
Committee (SORC) to review Independent Safety Engineering Group (ISEG)
procedures.
Contrary to the above, some ISEG procedures were not reviewed by the SORC. For
example, on November 11,1997, Condition Report M3-97-3974 documented an audit
finding that NOQP 3.04, Nuclear Safety Engineering Group Functions and
Responsibilities - ISEG and OE Assessment, had not been reviewed by the SORC.
NNECO's Response
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, NNECO agrees with the violation.
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Reason for the Violation
A decision was made (human error), during the revision of ISEG procedures in 1997, to
obtain SORC review of NSE-1 to be in compliance with Technical Specifications 6.2.3.1
and 6.5.2.6. This was a new site procedure for the Operating Experience Program. It
was not recognized, at the time, that approval of NSE-1 only partially covered the
functions requiring SORC review, and that NOQP 3.04 still included some functions of
ISEG that required SORC review per Technical Specification requirements.
Corrective Actions That Have Been Taken and Results Achieved
NOQP 3.04, Revision 2, " Nuclear Safety Engineering Group Functions and
Responsibilities-ISEG and OE Assessment", was reviewed and approved by SORC on
March 25,1998.
As a result of several Technical Specification Section 6 deficiencies being identified,
Level 1 Condition Report, M3-97-4644, was generated. As a result of the root cause
investigation, an assessment of compliance to Section 6 of the Technical Specifications
was performed. This assessment, ESAR 3CMT-98-001 identified other procedures
requiring SORC approval. Corrective actions have been completed to address the
deficiencies. ,
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B17225%ttachment 2\Page 6
NOQP 3.04 has been revised to identify the requirement that the procedure requires
SORC review.
NOQP 1.02, " Nuclear Oversight Department and Quality Program implementing
Procedures" has been revised to include performing a review of new procedures or
scope changes for existing procedures to determine if SORC review is required.
Corrective Actions That Will Be Taken to Avoid Further Violations
No further corrective actions will be taken.
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Date When Full Compliance Will Be Achieved
NNECO is in full compliance.
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B17225%ttachment 2\Page 7 1
Nuclear Reaulatory Commission Violation "C.1.A" (50-423/97-82-10)
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Restatement of the Violation
Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality
, be prescribed by instructions or procedures of a type appropriate to the circumstances.
l Further, it requires that these activities be accomplished in accordance with these
! instructions or procedures,
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Contrary to the above, written procedures for design bases documents were not
adhered to in the following instances:
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Pl 29, Development of Millstone Unit 3 Design Bases Summary Documents, requires
! Design Basis Summaries (DBS) for Maintenance Rule (MR) Group 1 and 2 systems.
However, in the summer of 1997 when the Emergency Lighting System was moved
from MR Group 3 to 2, a DBS was not developed. Additionally the Chemical and
, Volume Control System, a MR Group 1/2 system, was 'not completely included in a
! DBS.
NNECO's Response
l NNECO agrees with the violation.
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Reason for the Violation
The root cause investigation concluded that the reason for the violation was human
error, specifically classified as " inadequate Work Practice". Although the owner of the
Design Bases Summaries (DBSs) was aware of the MR Group 2 systems that did not
L have DBSs, the owner's interpretation of U3 PI 29 was that these systems could be
l completed at a later date.
DBS development was a defined scope, one time project, that processed a large
- volume of data under an aggressive schedule. The U3 PI 29 procedure was
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inadequate in th't there was vagueness in the procedure that allowed interpretation. '
L Specifically, there was an attachment to the procedure that defined the scope of the
i project that conflicted with the guidance in the body of the procedure. There was
inadequate feedback to revise the procedure to account for this gap. This was
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evidenced by not updating the attachment to include the new scope of MR Group 2
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B17225\ Attachment 2\Page 8
Corrective Actions That Have Been Taken and Results Achieved
l Procedure OA 10 " Millstone Station Maintenance Rule Program" was revised to add the
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requirement for the Meintenance Rule Group to notify the owner of the DBS when there
'is a change to the Group 1 and Group 2 lists.
Corrective Actions That Will Be Taken to Avoid Further Violations
NNECO has determined that thirteen MP3 systems, or portions of systems associated
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' with Maintenance Rule Group 1 and Group 2 systems, do not have DBSs. Among
these thirteen systems are Emergency Lighting and portions of the Chemical and
Volume and Control System. DBSs for the thirteen systems will be developed. This'
will be completed by February 28,1999.
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The Design Control Manual (DCM) will be revised to incorporate U3 PI 29 to transfer
I
the development and maintenance of DBSs from Configuration Management Program
, (CMP) activities to the permanent design process. This revision will include
clarification and procedural requirements for work practices concerning Maintenance
Rule Group 1 and 2 systems without DBSs. This revision will include guidance on
actions required in the interim period between when a new or revised DBS is required
and when it is finally issued. This will be completed by September 30,1998.
l Date When Full Compliance Will Be Achieved
NNECO will be in compliance upon the revision to the DCM that provides guidance for
- actions required from the time it is determined that a DBS is required and currently
l- does not exist until the DBS is finalized. This will be completed by September 30,
( 1998. This schedule is acceptable based on the fact that the DBS is not in itself a
source of design basis information. This tool serves as a " Road Map" to aid the
engineer to locating information. This information is readily available through other
means which the engineer can review for design changes.
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B17225\ Attachment 2\Page 9
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Nuclear Reaulatory Commission Violation "C.1.B" (50-423/97-82-10)
Restatement of the Violation
Criterion V of 10 CFR 50. Appendix B, requires, in part, that activities affecting quality
be prescribed by instructions or procedures of a type appropriate to the circumstances.
Further, it requires that these activities be accomplished in accordance with these
instructions or procedures.
Contrary to the above, written procedures for design bases documents were not
adhered to in the following instance: NGP 5.28, Design Basis Documentation
Packages, Rev 3,10/15/97, Step 1.1.2, requires documenting changes to the Safety I
Functional Requiremerits (SFR) Manual as Design Change Notices (DCN) and then
entering the DCN numbers into the Generation Records Information and Tracking
System (GRITS). As of February 1998, two revisions to the SFR Manual were issued
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without issuing DCNs or updating the GRITS.
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NNECO's Response
NNECO agrees with the violation.
Reason for the Violation
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A root cause investigatica concluded the reason for the violation was human error,
specifically classified as " inadequate Written Communication". An Engineering Record
Correspondence (ERC) with the SFR Manual attached was sent to Design Engineering
and Nuclear Document Services (NDS) with no specific instructions other than stating a
DCN was required to update GRITS in accordance with NGP 5.28. This was
inadequate to convey the message that an additional task was also required to revise
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the SFR Manual. The ERC stipulated that it was processed in accordance with NGP '
5.31, " Engineering Record Correspondence and Technical Specifications," and made
no reference to NGP 5.28. As a result, Design Engineering assumed the task was
completed and distributed for use without having the latest revision number posted in
GRITS.
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Corrective Actions That Have Been Taken and Results Achieved:
The Design Control Manual (DCM) has been revised to incorporate instructions on
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updating and handling the SFR Manual.
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B17225%ttachment 2\Page 10
GRITS has been updated to reflect the. current revision of the SFR Manual per DCM
Chapter 12.
Corrective Actions That Will Be Taken to Avoid Further Violations:
Perform coaching for Nuclear Engineering personnel, including management, to
communicate the expectations for procedural compliance per DC-4, processing of
DBDP - SFR Manuals per NGP 5.28, processing of the SFR Manual per DCM Chapter
12, and the use of the DCM in general. This item will be completed by August 31,
1998.
Perform a sample review cf Nuclear Engineering design change products issued after
June 30,1997 to verify that they have been administratively processed and controlled
in accordance with appropriate procedures. This item will be completed by
Decemoer 1,1998.
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Date When Full Compliance Will Be Achieved
NNECO is in full compliance.
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B17225\ Attachment 2\Page 11
Nuclear Roaulatory Commission Vic!ation "C.2" (50-423/97-82-07)
Restatement of the Violation
Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality
be prescribed by instructions or procedures of a type appropriate to the circumstances.
Further, it requires that these activities be accomplished in accordance with these
instructions or procedures.
RP4, Rev 5, Attachment 3, Condition Report (CR) Initiation and Classification
Guidelines, includes in the Level 2 guidelines, an extemal station commitment not
adhered to: or a deficiency in material that, if left uncorrected, could affect safe reliable
plant operation.
Contrary to the above, in 1997, CR M3-97-4672, which is related to an extemal station
commitment not adhered to (NRC Generic Letter GL 89-13), and CR M3-97-4346,
' which is related to a material deficiency that, if left uncorrected, could affect safe
reliable plant operation (inadequate corrosion control), were inappropriately classified
as Level 3 CRs.
NNECO's Response
NNECO agrees with the violation.
Reason for the Violation
CR M3-97-4346 and M3-97-4672 were each categorized improperly as significance
level 3 CRs, due to a failure to recognize that external commitments were involved and
had not been adhered to. The Unit 3 Management Review Team (MRT) assigned a
level 3 to these CRs, based on the initiator's description of the events. The connection
to a regulatory commitment for GL 89-13 was not made apparent in either Condition
Report. A root cause determined that the cause of this was human error resulting from
a lack of sufficient procedural guidance.
Corrective Actions That Have Been Taken and Results Achieved
CRs M3-97-4346 and M3-97-4672 were upgraded to level 2 significance on March 9,
1998. *
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B17225\ Attachment 2\Page 12
NRC commitments associated with GL 89-13 were reviewed to determine if deferral
dispositions were appropriate and if any reporting to the NRC was required. It was
determined that no regulatory commitments were missed. This review verified the
dispositions and determined that no further reporting was necessary.
RP 4, " Corrective Action Program", was revised to clarify the conditions which warrant a
level 2 or level 3 significance, to include guidance on upgrading a level 3 CR if an
adverse condition is identified during the investigation of the CR, and to have
Regulatory Affairs and Compliance department involved in the dispositioning of items
that may impact the Licensing or Design Basis of the unit, and regulatory commitments.
Corrective Actions That Will Be Taken to Avoid Further Violations
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No further actions are required.
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Date When Full Comollance will be Achieved
NNECO is in full compliance.
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B17225\ Attachment 2\Page 13
Nuclear Reaulatory Commission Violation "D" (50-423/97-82-02)
Restatement of the Violation
Technical Specification 6.2.1.d requires, in part, that those who carry out health physics
functions have sufficient organizational freedom to ensure their independence from
operating pressures.
Contrary to the above, the Radiation Protection Manager reports to the Maintenance
Manager, which does not ensure independence from operating pressures. Also, ;
Regulatory Guide 8.8, Section C.1.b(3), states in part, that: The Radiation Protection
Manager (RPM) (onsite) has a safety function and responsibility to both employees and
management that can best be fulfilled if the individual is independent of station
divisions, such as operations, maintenance, or technical support, whose prime
responsibility is continuity or improvement of station operability.
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NNECO's Response
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NNECO agrees with the violation. l
Reason for the Violation
Technical Specification 6.2.1d requires the following:
"The individuals who train the operating staff and those who carry out health
physics and quality assurance functions may report to the appropriate onsite
manager; however, they shall have sufficient organizational freedom to ensure
their independence from operating pressures."
Regulatory Guide 8.8, Section C.1.b(3), states in part, that:
"The Radiation Protection Manager (RPM) (onsite) has a safety function and ,
responsibility to both employees and mana~gement that can best be fulfilled if the l
individual is independent of station divisions, such as operations, maintenance, .I
or technical support, whose prime responsibility is continuity or improvement of
station operability."
The violation occurred because an inadequate review of the Licensing Basis for the
reporting requirements was performed and procedural requirements to evaluate l
organizational changes were not formalized. In addition, Technical Specification i
verbiage does not specifically state which onsite manager is appropriate. At the time of
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B1722E\ Attachment 2\Page 14
the NRC inspection, the Millstone Unit No. 3 Radiation Protection Manager carried out '
the health physics function while reporting to the Millstone Unit No. 3 Maintenance
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Manager. NNECO believed that this arrangement was in concert with the Technical l
Specifications. However, it was not in concert with Regulatory Guide 8.8, Section l
C.1.b(3). It is important to note that radiological decisions were made by the Radiation
Protection Manager and not by the Maintenance Manager.
Corrective Actions That Have Been Taken and Results Achieved
NNECO re-assigned the Unit 3 Radiation Protection Manager to report to the Unit
Director. This action was completed on March 12,1998.
Corrective Actions That Will Be Taken to Avoid Further Violations
On December 18, 1997, NNECO implemented a new station procedure RAC 13,
" Organizational Changes." This procedure describes the process to evaluate and l
implement organizational changes to ensure changes are made in compliance with all
regulatory requirements. The use of this procedure will avoid implementing ;
organizational changes that are contrary to the Licensing Basis.
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Date When Full Compliance Will Be Achieved l
NNECO is in full compliance.
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