ML20154C934
| 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) | |
See also: IR 05000245/1998208
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October 1,
1998
Mr. M. L. Bowling, Recovery Officer - Technical Services
C/o Ms. P. A. Loftus, Director - Regulatory
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Affairs for Millstone Station
NORTHEAST NUCLEAR ENERGY COMPANY
PO Box 128
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Waterford, CT 06385
SUBJECT:
COMBINED INSPECTION 50-245,336,423/98-208- REPLY
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Dear Mr. Bowling:
This letter refers to your September 14,1998 correspondence, in response to our August
12,1998 letter.
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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
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Jacque P. Durr, Chief
Inspections Branch
Mittstone Inspection Directorate
Docket Nos. 50-245;50-336;50-423
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cc:
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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
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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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ADOCK 05000245
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Mr. M. L. Bowling
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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 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)
Renrasentative T. Concannon
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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
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DATE
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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
'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)
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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
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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
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cc: H. J. Miller, Region i Administrator
J. W. Andersen, NRC Project Manager, Millstone Unit No. 3
A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3
E. V. Imbro, Director, Millstone ICAVP inspections
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
Nuclear Reaulatory Commission Insoection Report 50-423/98-208
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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)
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Restatement of the Violation
Technical Specification 6.8.1.a. requires, in part, that written procedures shall be
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
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Standby." Step 4.2.34.g.2 of OP 3201, " Plant Heatup," states, IF any RCS hot or cold
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leg WR temperature increases to greater than 195*F, DIRECT test personnel to close
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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'
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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
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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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U.S. Nuclear Regulatory Commission
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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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
additional startup training to the Operations staff in advance of scheduled startup
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evolutions and remedial training to address lessons learned from the specific events
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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
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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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September 1998
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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
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commitments.
Commitment
Commitment
Committed Date or
No.
Outage
None