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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/98-208, 50-336/98-208 & 50-423/98-208.Actions Will Be Examined During Future Insp
	ML20154C934
Person / Time
Site:	Millstone
Issue date:	10/01/1998
From:	Durr J; NRC
To:	Bowling M, Loftus P; NORTHEAST NUCLEAR ENERGY CO.
References
	50-245-98-208, 50-336-98-208, 50-423-98-208, NUDOCS 9810070071
	Download: ML20154C934 (2)
	v • d • e

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October 1, 1998

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

C/o Ms. P. A. Loftus, Director - Regulatory i

Affairs for Millstone Station l

NORTHEAST NUCLEAR ENERGY COMPANY

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PO Box 128 i

Waterford, CT 06385

SUBJECT: COMBINED INSPECTION 50-245,336,423/98-208- REPLY I

.

Dear Mr. Bowling:

This letter refers to your September 14,1998 correspondence, in response to our August

12,1998 letter. ,

Thank you for informing us of the corrective and preventive actions documented in your

letter concerning a violation cited at Millstone Unit 3. These actions will be examined

during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

y ORIGINAL SIGNED BY

RICilARD J URBAN FOR

.

Jacque P. Durr, Chief

Inspections Branch

Mittstone Inspection Directorate

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

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cc: }

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

M. H. Brothers, Vice President - Operations

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J. McElwain, Recovery Officer - Millstone Unit 2

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J. Streeter, Recovery Officer - Nuclear Oversight /

P. D. Hinnenkamp, Director - Unit 3

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

9810070071 981001

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PDR ADOCK 05000245

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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 l

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 l

J. M. Block, Attorney, CAN !

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

Renrasentative T. Concannon {

E. Wooilacott, Co-Chairman, NEAC

Distribution w/cv of Licensee Resoonse Ltr: !

Region i Docket Room (with coov of concurrences)

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, Milf; tone inspection Directorate, R1

D. Screnci, PAO

DOCUMENT NAME: P: I:\ BRANCH 6\REPLYLTR\98208.RPY

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

C:py with attachment / enclosure "N" = No copy

OFFICE MID/ORAg / MID/ ORA , // / l

NAME NJBLUMBE'RG/db JP,DURR /Q

DATE 0987/98 99// /98 T 09/ /98 09/ /98 09/ /98

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Northeast nare Ferry Rd. (Route 156), Waterford, CT 06385

Nuclear Energy Mal tone Nuclear Power Station

Northeast Nuclear Energy Company

P.o. Ilox 128

Waterford, CF 06385-0128

(860) 447-1791

Fax (860) 444-4277 l

'Ihe Northeast Utilities System

SEP I 41998

Docket No. 50-423

B17424

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U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, DC 20555

Millstone Nuclear Power Station Unit No. 3

Response to Notice of Violation

Nuclear Reaulatorv Commission inspection Report 50-423/98-208

By letter dated August 12, 1998, the Nuclear Regulatory Commission (NRC) 1

transmitted the results of the above referenced inspection. The letter included a Notice

of Violation (NOV) citing one-instance where Northeast Nuclear Energy Company

(NNECo) activities were not in compliance with NRC regulations.

NNECo's response to the citation is provided as Attachrnent 1 of this submittal. ,

Attachment 2 provides a summary of NNECo's commitments made in response to the

citation. 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 ENER'GY COMPANY

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Martin L. Bowling, Jr. d ;

Recovery Officer - Technical Services I

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U.S. Nuclear Regulatory Commission

B17424\Page 2

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cc: H. J. Miller, Region i Administrator l

J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 ;

A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3

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E. V. Imbro, Director, Millstone ICAVP inspections l

J. P. Durr, Chief, Office of the Regional Administrator

W. D. Lanning, Director, Millstone inspections

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Docket No. 50-423

B17424

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Attachment 1

Millstone Nuclear Power Station, Unit No. 3

Response to Notice of Violation

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Nuclear Reaulatory Commission Insoection Report 50-423/98-208 l

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September 1998

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U.S. Nuclear Regulatory Commission i

B17424\ Attachment 1\Page 2

Response to Notice of Violation

Nuclear Regulatory Commission inspection Report 50-423/98-208

Nuclear Reaulatory Commission Citation (50-423/98-208-04)

l

l Restatement of the Violation

Technical Specification 6.8.1.a. requires, in part, that written procedures shall be

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implemented covering the activities referenced in Appendix A of Regulatory Guide 1.33,

February 1978, item 2.a., General Plant Operating Procedures, " Cold Shutdown to Hot ,

Standby." Step 4.2.34.g.2 of OP 3201, " Plant Heatup," states, IF any RCS hot or cold

leg WR temperature increases to greater than 195*F, DIRECT test personnel to close 1

and lock the applicable RHR outboard drain valve (3RHS*V26).

Contrary to the above, on June 2,1998, the licensee failed to direct test personnel to

close and lock RHR outboard drain valve,3RHS*V26, when RCS WR temperature

increased to greater than 195*F. Valve 3RHS*V26 was subsequently closed when

reactor coolant system wide range temperature approached 197*F during performance

of SP 3601F.4, "RCS Pressure Isolation Valve Test."

NNECo's Response

NNECo agrees with the violation.

Reason for the Violation

- The cause of the conditior is attributed to human error resulting in required actions not

being carried out as d' .. i by the cited Operating Procedure (OP). While the

_

decision to delay the clost af the affected valve was made on the basis that the intent

of the procedural requirement would continue to'be satisfied, the operating crew failed

to process the required temporary change to the procedure to support their decision.

Corrective Actions Taken and Results Achieved

' The lessons l' earned from this event were addressed by the Operations Manager in a

staff briefing memorandum dated June 13,1998. (AR 98010857-01)

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At the time this violation occurred, NNECo had in place ongoing activities directed at

improving human performance in the control room. These actions were undertaken as

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a result of performance deficiencies identified during the initial plant heat-up conducted

y in preparation. for unit restart from the extended outage. The cause of these

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deficiencies was attributed to skill deficits which had developed during the extended

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B17424\ Attachment 1\Page 3

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! outage. As a consequence, NNECo reevaluated the approach to unit restart and

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instituted additional measures to ensure an event free startup.

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l These measures included; 1) augmentation of the regular shift compliment with

additional operations department management personnel to reinforce performance

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standards by facilitating the p!anning and execution of startup evolutions,2) providing !

3

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additional startup training to the Operations staff in advance of scheduled startup l

' evolutions and remedial training to address lessons learned from the specific events

noted during initial plant heatup, and 3) the assignment of additional management

oversight to the control room on an around-the-clock basis throughout the unit restart

and power ascension process. The result of these actions was a safe and event free j

unit startup and power ascension program. NNECo's Nuclear Oversight organization

subsequently concluded in its report related to the Millstone Unit 3 startup and power

ascension, that line performance had improved significantly since the Mode 4 transition

and that reduction in round-the-clock oversight coverage of control room activities was

justified.

Corrective Actions to Prevent Future Violations

The Millstone Unit 3 Operations Department currently monitors human performance

and procedure compliance related deficiencies through the Performance Anruaciator

Pane 1 Reporting System. Within this system, key activities are monitored and

appropriate performance ' criteria are established to define corrective action thresholds.

The annunciator panels are reviewed by management to ensure that adverse

performance trends are appropriately addressed through the corrective action program.

Dah When Full Compliance Will Be Achieved

Full compliance has been achieved with respect to the condition described in this

citation.

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Docket No. 50-423

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B17424

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Attachment 2

Millstone Nuclear Power Station, Unit No. 3

Summary of Commitments-

Nuclear Reaulatorv Commission inspection Report 50-423/98-208

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B17424\ Attachment 2\Page 2

List of Regulatory Commitments

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

Please notify the Manager Regulatory Compliance at the Millstone Nuclear Power

,

Station of any_ questions regarding this document or any associated regulatory

commitments.

Commitment Commitment Committed Date or

No. Outage

None

ML20154C934

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