ML20154G298

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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.Violation Cited Plant,Unit 3 50-423/98-208
ML20154G298
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 10/01/1998
From: Durr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Bowling M, Loftus P
NORTHEAST NUCLEAR ENERGY CO.
References
50-245-98-208, 50-336-98-208, 50-423-98-208, NUDOCS 9810130116
Download: ML20154G298 (2)


See also: IR 05000245/1998208

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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KING oF PRusslA, PENNSYLVANIA 19406-1415

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October 1,

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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

PO Box 128

Waterford, CT 06385

SUBJECT:

COMBINED INSPECTION 50-245,336,423/08 208- REPLY

Dear Mr. Bowling:

,

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

12,1998 letter.

Thank you foi 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,

.

Jacque P. Durr, Chief

Inspections Branch

Millstone inspection Directorate

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

cc:

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

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M. H. Brothers, Vice President - Operations

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' . 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

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9810130116 981001

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Mr. M. L. Bowling

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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

Distribution w/cv of Licensee Resoonse Ltr:

Region i Docket Room (with copy of concurrences)

Nuclear Safety Inforrnation Center (NSIC)

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NRC Resident inspector

H. Miller, Regional Administrator, R1

B. Jones, PIMB/ DISP

W. Lanning, Director, Millstone Inspection Directorate, R1

D. Screnci, PAO

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Northeast

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Northeast Nuclear Energy Company

P.o. Box 128

Waterford, Ur 06385 0128

(860) 447 1791

Fax (860) 444 4277

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'ne Northeast Utihties System

SEP l 41998

Docket No. 50-423

B17424

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 Reaulatory Commission inspection Report 50-423/98-208

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

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 Attachment 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 ENERGY COMPANY

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Marti- L. Bowling, Jr. d

Recovery Officer - Technical Services

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cc: H. J. Miller, Ragion i Administrator

' J. W. Andersen, NRC Project Manager, Milistone Unit No. 3

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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

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Response to Notice of Violation

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Nuclear Reoulatory Commission inspection 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)

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

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

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

Contrary to the above, on June 2,1998, the licensea 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 condition is attributed to human error resulting in required actions not

being carried out as directed by the cited Operating Procedure (OP).

While the

decision to delay the closure of 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 Action _s Taken and Results Achieved

The lessons learned from this event were addressed by the Operations Manager in a

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

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

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

in preparation for unit restart from the extended outage.

The cause of these

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

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U.S. Nuclear Regulatory Commission

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B17424\\ Attachment 1\\Page 3

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

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

standards by facilitating the planning and execution of startup evolutions,2) providing

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

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

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unit startup and power ascension program.

NNECo's Nuclear Oversight organization

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

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

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

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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 Annunciator

Panej 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

Date 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. 50423

B17424

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Attachment 2

Millstone Nuclear Power Station, Unit No. 3

Summary of Commitments

Nuclear Reaulatory Commission Inspection Report 50-423/98-208

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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

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