ML20198A338
| ML20198A338 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/09/1998 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9812160233 | |
| Download: ML20198A338 (17) | |
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UNITED STATES I'
g NUCt. EAR REGULATORY COMMISSION 5
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- o, 475 ALLENDALE ROAD
%.....,o*s KING OF PRUSSIA, PENNSYLVANIA 19406-1415 December 9, 1998 Mr. M. L. Bowling, Recovery Officer, Technical Services C/o Patricia Lof tus, Director - Regulatory Affairs for Millstone Station
. Northeast Nuclear Energy Company P.O. Box 128 Waterford, Connecticut 06385
Dear Mr. Bowling:
SUBJECT:
MID-YEAR INSPECTION RESOURCE PLANNING MEETING - MILLSTONE 3 On November 10,1998, the NRC staff held an inspection resource planning meeting (IRPM). The IRPM provided a coordinated mechanism for Region I to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in May 1999. contains a historicallisting of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this IRPM process to arrive at an integrated view of licensee performance trends. The PIM includes only items from inspection reports or other docketed correspondence between the NRC and Northeast Nuclear Energy Company.
The ' RPM may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full
- review and consideration. This material will be placed in the PDR as part of the normal issuance of NRC inspection reports and other correspondence.
This letter advises you of our planned inspection effort resulting from the Millstone 3 IRPM review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 2 details our inspection plan for Millstone 3 for the next 6 months.. For planning purposes, Enclosuse 2 also includes core inspection activities for Millstone 2.
Since most of the inspection activities for Millstone 2 are being tracked separately under NRC Inspection Manual Chapter 0350," Staff Guidelines For Restart Approval," those inspections do not appear in Enclosure 2. Resident inspections are not listed due to their ongoing and continuous nature.
We willinform you of any changes to the inspection plan. If you have any questions, please contact Mr. Jacque P. Durr at 610-337-5224.
Sincerel c' Mi /
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Millstone Inspection Directnrate i
Region I
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4 Docket No. 50-423
Enclosures:
- 1) Plant Issues Matrix
- 2) Inspection Plan 9812160233 981209 PDR ADOCK 05000423 I-h f
2 cc w/ encl:
B. Kenyon, President and Chief Executive Officer - Nuclear Group L. Olivier, Senior Vice President & Chief Nuclear Officer M. H. Brothers, Vice President - Operations J. McElwain, Recovery Officer - Millstone Unit 2 R. Necci, Vice President - Nuclear Oversight and Regulatory Affairs 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
- 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 l
I i
i
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3 Distribution w/ encl:
Region i Docket Room (with s.ggy of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC FILE CENTER, NRR (with Oriainal concurrences)
Millstone inspection Directorate Secretarial File, Region 1 NRC Resident Irispector H. Miller, Regional Administrator, R1 W. Axelson, Deputy Regional Administrator, R1(inspection Reports)
B. Jones, PIMB/ DISP W. Lanning, Director, Millstone inspection Directorate, R1
< D. Screnci, PAO R. Urban, Millstone inspection Directorate, R1 Distribution w/ encl (VIA E MAIL):
M. Callahan, OCA < MSC>
R. Correia, NRR < RPC>
B. McCabe, OEDO <BCM>
E. Imbro, Director, Millstone ICAVP inspections, NRR < EXI>
W. Dean, Director, Millstone Project Directorate, NRR <WMD>
P. Koltay, Chief, ICAVP Oversight, NRR < PSK>
Inspection Program Branch <lPAS>
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OFFICIAL RECORD COPY
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 9/25/98 Positive IR 98-212 N
OPS 1A The licensee performed the Unit 3 startup in a controlled and conservative manner following a shutdown which lasted in excess of two years. Improved operator performance since the NRC operational safety team inspection (OSTI) inspection (IR 50-423/97-83)was noted. Appropriate l
actions were taken in response to equipment, environmental, performance and procedural problems, j
Overall, the NRC around-the-clock shift coverage noted good licensee performance consistent with that of a plant returning from an outage over two years in duration.
9/25/98 Positive IR 98-212 L
OPS 2B The corrective actions taken by the licensee for the Containment Manual (Outside Containment)
NCV NCV 98-212-03 SC Valve Checklist, which did not contain the complete list of manually operated CIVs that require LER 97-34 monthly closure verification are deemed to be adequate. LER 423'/97-034-OOis considered closed.
The failure to perform the required Technical Specification surveillances is a non-cited violation.
l l
9/25/98 Negative IR 98-212 N
MAINT 2B The preventive maintenance instructions for the Unit 3 station blackout ( SBO) uninterruptable power supply (UPS) did not include any acceptance criteria; the licensee did not follow the written directions of AWO M3 96-18284;and the results had not been evaluated in a timely manner. This l
appears to be a weakness in translating the requirement for preventive maintenance on the station i
blackout diesel to an AWO.
9/25/98 Positive IR 98-212 N
ENG SC The licensee's corrective actions for the missed medium voltage breaker overhauls were prudent and timely following their discovery of the missed overhaul recommendation. The inspector concluded that sufficient justification existed for breaker operability based on the GE letter that stated that no l
potential problems were found as a result of the completed overhauts performed to date which found no common mode failure mechanism that would interfere with plant safety.
i 9/25/98 Negative IR %-212 L
ENG SC The actions taken by the licensee to resolve the inability of Power Operated Relief Valves (PORVr) l NCV NCV C 112-05 3RCS*MV8000 A/B to perform their intended function to close and reopen under design basis LER 96-19-00 accident conditions are deemed adequate. New Anchor Darling valves have been tested, and LER 96-19-01 insta!!ed. This licensee-identified and corrected violation is being treated as a non-cited violation.
9/25/98 Negative IR 98-212 L
ENG 4C The summary table of the Design Basis Differential Pressure Calculation for all four Main Steam NCV NCV 98-212-06 Atmospheric Relief Valves (3 MSS *MOV74A/B/C/D)did not include the throttle /close direction safety LER 96-20 function stroke which was described in the body of the valve calculation for the referenced valves.
The calculations have been revised and the valve settings changed to meet design basis requirements. The actions taken by the licensee are deemed to be adequate. This licensee-identified and corrected violation is being treated as a non-cited violation.
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FROM: 4/1/98 TO 10/30/98 Page 1 of 13 30 November 1998 l
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Descrip6on 9/25/98 Negative IR 98-212 L
ENG 5A An evaluation of all Motor Operated Valves (MOVs) within the scope of Generic Letter (GL) 89-10 NCV NCV 98-212-07 SC was performed by the licensee to determine if the referenced MOVs would have stroked under LER 96-35 28 design basis conditions. This review identified 27 MOVs that potentially may not have strokeo fully under design basis conditions. The revisions to the calculations, the valve modifications and the static testing have been completed adequately. This licensee-identified and corrected deficiency is being treated as a non-cited violation.
9/25/98 Positive IR 98-212 N
PS 2A The licensee established, implemented, and maintained an effective radiation monitoring system program with respect to electronic and radiological calibrations. As a result of self-assessment initiatives, the licensee implemented efforts to improve radiation monitoring system reliability.
Licensee tracking and trending efforts provided sufficient information to assess radiation monitoring system performance.
9/25/98 Positive IR 98-212 N
PS 5B The licensee established, implemented, and maintained an effective quality assurance program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings. The licensee implemented an effective quality control program to validate measurement results for radioactive effluent samples.
9/25/98 Positive IR 98-212 N
PS 1C A!I but two of the inspected fire seals were satisfactory with regard to physical damage, shrinkage, 2A and separation. The licensee took appropriate corrective actions upon the discovery of the two faulty fire seats.
9/25/98 Negative IR 98-212 N
PS 1C The licensee conducted a detailed silicone RTV foam fire barrier penetration seal audit at Unit 3 for 2A expired materials and found no evidence of expired material usage. The inspector identified one minor violation, with two examples, which resulted from the failure to follow fire barrier seats installation procedures.
8/12/98 Positive IR 98-208 N
OPS SC The inspector reviewed the licensee's root cause evaluations and corrective actions for the IR 97-83 1A operational events documented in the Unit 3 Operatione8 Safety Team inspection, NRC Inspection Report 50-423/97-83, dated June 12,1998. The corrective actions were comprehensive and appropriately addressed the deficiencies identified in the root cause evaluations, as we!! as the operator performance issues.
8/12/98 Positive IR 98-208 N
OPS SC The licensee's corrective actions for an OSTI concem related to the valve and system alignment IR 97-83 1A program was reviewed. The licensee demonstrated that tN valve and system alignment program was effectively implemented.
8/12/98 Negative IR 98-208 N
OPS 1A Although the licensee's performance during several Unit 3 plant heatups and cooldowns was VIO VIO 98-208-04 generally acceptable, the licensee violated their plant heatup procedure during one plant heat up and transition into Mode 4.
FROM: 4/1/98 TO 10/30/98 Page 2 of 13 30 November 1998
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 8/12/98 Positive IR S8-208 N
MAINT 2B The Unit 3 material, equipment, and parts lists (MEPL) program was reviewed in several inspections IR 98-207 over the past year. The licensee has invested substantial effort into improving the program and has IR 97-203 significantly upgraded both the progra'n end the evaluations for many components and parts in Unit IR 97-202
- 3. A number of issues were identif'1.'uring the review and the licensee has been responsive in URI 95-07-10 addressing the concems. The program 3 currently deemed acceptable and meets regulatory requirements.
8/12/98 Positive.
IR 98-208 N
ENG SC The licensee's corrective actions regard:ng the Unit 3 MOV thrust calculation violation were l
IR 98-82 comprehensive.
l VIO 98-82-10 8/12/98 Negative IR 98-208 N
ENG 4A At Unit 3, the RSS cubicle initial sump pump system design and the pump qualification were URI 98-208-07 inadequate. Significant corrective action, including system and pump design changes, were required LER 98-36 to ensure the system would perform its design function.
LER 97-46 8/12/98 Positive IR 98-208 N
PS 1C Appropriate work planning for maintaining occupational exposures ALARA was also observed at Unit 3 for work on the 3RCS*V132 valve and for industrial radiography taking place in the containment.
8/12/98 Positive IR 98-208 N
PS 28 The licensea made significant improvements to the post accident sampling system (PASS).
IR 98-01 SC Procedures were rewritten, technicians retrained and the system was repeatedly tested. Also, as l
VIO 98-01-01 equipment deficiencies were identified, they were corrected. With the exception of the dissolved l
gas sample results, the licensee met the appropriate acceptance criterion. Corrective actions are i
selficient to provide reasonable assurance that the PASS system would be able to assist in the assessment of core damage, given a significant transient or accident. The licensee is continuing to assess their method for retrieving and analyzing a dissolved gas sample.
I 8/12/98 Positive IR 98-208 N
PS 1C The licensee conducted security and safeguards activities thoroughly and in a manner that ensured I
safe operations. Inspections were conducted in the areas of access authorization, alarm stations, communications, protected area access control of personnel and packages, and protected area access control of vehicles.
i 6/19/98 Positive IR 98-207 N
OPS SC The licensee's actions following the failure to comply with a Unit 3 technical specification (TS) upon initial entry into Mode 4 were appropriately scoped and performed. They ensured current compliance with Mode 4 TS and reviewed those TS which would be applicable in Mode 3. Through independent control board walkdowns and surveillance reviews, the inspector independently verified licensee compliance with selected Mode 3 TS.
6/19/98 Negative IR 98-207 N
MAINT SC The licensee failed to ensure that degraded or noncontorming parts were promptly identified and VIO VIO 98-207-15 corrected in the area of nonsafety-related parts upgrade as part of the MEPL program. Specifically, although previous industry information had been issued in this regard 29 safety related Unit 3 components had nonsafety related parts procured and installed in the past two years.
FROM: 4/1/98 TO 10/30/98 Page 3 of 13 30 November 1998
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MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code stern DescripHon 6/19/98 Positive IR 98-207 N
ENG 4B Based on an NRR review of documentation for modifications made to the Unit 3 RSS system, field walkdown of the system, and discussions with the licensee, the NRC determined that modifications made to the RSS during the current outage appear to be in compliance with the requirements of 10CFR50.59.
6/18/98 LER LER 98-32 L
OPS Technical specification-required fuel handling crane limit switch surveillance test was not performed.
The cause of the condition was human error.
6/12/98 Negative IR 97-83 L
MAINT 2B The adherence to plant schedules has been poor. On average, only 60% of work orders on the 3-day look ahead schedule were started and 54% were completed on schedule. The scheduled dates for achieving major milestones, such as mode changes, were rarely met. The difficulty in meeting i
schedules was attributed to several factors including emergent issues, inability to identify work scope, and lack of accountability to meet schedules. The OSTI team did not find any examples where inefficiencies in planning and scheduling resulted in degradation of safety system performance.
6/12/98 Positive IR 97-83 N
MAINT 2B The Fix-It-Now (FIN) team had a positive impact on handling emergent work and reducing the automated work order (AWO) backlog.
[
6/12/98 Positive IR 97-83 N
MAINT 2B Procedure adherence by the maintenance staff was good. The team observed severalinstances where work was stopped to clarify or revise maintenance procedures.
6/12/98 Positive IR 97-83 N
MAINT 2A The plant material condition was generally good. The housekeeping practices and equ.pment storage 2B were obsurved to be good. The team determined that processes were in place to maintain a satisfactory level of plant material condition. The backlog of open maintenance work activities was trending down, had been prioritized, and the overall impact on operations was assessed and found to be acceptable.
6/12/98 Positive IR 97-83 N
ENG 4A The design control process provided a detailed and comprehensive method for implementing plant 4B design change activities. Modification package content, including the screening and safety reviews, were generally appropriate. Post-modification testing erv:ompassed verification of important design change attributes.
6/12/98 Positive IR 97-83 N
OPS 1A The team found the quality of command and control to be generally good with a few occasional lapses. Shift turnovers were typically comprehensive. The quality of prebriefs was comprehensive with some variations. Operators were generally cognizant of plant conditions and control room annunciator status. Operators appropriately contro!!ed access to the control room.
[
FROM: 4/1/98 TO 10/30/98 Page 4 of 13 30 November 1998
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 6/12/98 Negative IR 97-83 N
OPS 1A The team found that the licensee's corrective actions for past equipment alignment problems have SC not been fully effective. The team identified several problems with the administration and control of the plant equipment alignment program. These problems included components not properly aligned, inadequacies in the valve and breaker lineup process, and deficiencies in the locked valve program.
The team concluded that corrective actions to address these deficiencies were necessary prior to plant restart.
6/12/98 Negative IR 97-83 S
OPS 1A While the team found that operators generally adhered to procedures, the team identified a few VIO VIO 97-83-03 exceptions where procedures were not precisely followed. In one case, the failure to follow the procedure resulted in the inadvertent opening of the pressurizer power operated relief valve (PORV).
6/12/98 Negative IR 97-83 L
OPS 1A The OSTI team identified two instances where the administrative control of procedures was not in VIO VIO 97-83-02 accordance with technical specifications (TS). In one case, a procedural deficiency was a LER 98-22 contributing cause to missing the TS requirement to have two operable reactor coolant system loops in Mode 4. The licensee took effective corrective action to address these issues prior to the conclusion of the OSTI.
6/12/98 Positive IR 97-83 N
OPS The NRC OSTI team concluded that the quality of plant o;>erating precedures was generally good.
With a few exceptions, the procedures reviewed by the team were technically accurate and provided an appropriate level of detail. Risk significant operator actions were adequately procedura!ized.
6/12/98 Positive IR 97-83 N
OPS 3B The NRC OSTI team conducted an independent evaluation of operational events which occurred 3A during initial plant heatup after an outage in excess of two years. The team and the licensee determined that these events indicated weaknesses in several areas. These areas include a lack of specific operator knowledge, attention to detail, procedural adherence and control board awareness.
6/12/98 Negative IR 97-83 S
OPS 1A Two operational events occurred during the initial plant heatup to mode 3. The events were an 1B inadvertent opening of a pressurizer power operator relief valve and an automatic initiation of the auxiliary feedwater system caused by a low-low steam generator level. There were also three failures to meet Technical Specification requirements including: (1) not having the required number of operable reactor coolant system loops while in Mode 4: (2) the, failure to record pressurizer temperature data during a plant heatup; and (3) the failure to complete a conditional surveillance l
requiring a diletion path valve alignment check with one shutdown margin monitoring channel out-of-service. While there were no safety consequences as a result of these events, the performance by some plant operators during the initial plant heatups was weak.
6/12/98 Positive IR 97-83 N
OPS 3B The overall implementation of the systems approach to training for the technical training programs has improved and is adequate to ensure continued qualification of technical and non-licensed personnel.
FROM: 4/1/98 TO 10/30/98 Page 5 of 13 30 November 1998
j MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 6/12/98 Positive IR 97-83 N
OPS SA The Nuclear Oversight Organization's reporting mechanisms to line management provided an effective means of capturing conditions adverse to quality and ensuring that those conditions were corrected. The reports were critical assessments and adequately provided senior management with a useful " snapshot" of plant performance and areas requiring additional attention.
6/12/98 Positive IR 97-83 N
OPS 5A The OSTI team concluded that the self-assessment programs are functioning well and are identifying 5B and dispositioning issues which affect plant and personne! performance. The self-assessments were timely and self-critical. Management oversight ensured corrective actions initiated by the self-assessments were taken in a timely manner.
6/12/98 Positive IR 97-83 N
OPS SA The overall corrective action program was adequate to support plant restart. The threshold for SB including identified plant deficiencies in the corrective action program was low and a timely SC resolution of safety significant issues is genera!!y being met. The team concluded that the root cause evaluations reviewed by the OSTIidentified appropriate causes. Issues that should be addressed prior to restart were identified and being tracked for completion.
6/12/98 Negative IR 97-83 N
MAINT 28 The application of probabilistic risk assessment (PRA) insights to design and operation of the plant was adequate with one exception being the lack of risk assessments for removal of equipment from service during transitional modes of operation. This deficiency was adequately addressed by the licensee during the OSTI.
6/11/98 Positive IR 97-82 N
OPS 1A The plant staff's clear understanding of management's expectations was considered a management strength.
6/11/98 Positive IR 97-82 N
OPS 1A Organizational communications and team work were adequate, with vertical communications 3A between plant organizations considered a strength. Communications between groups and departments in formal meeting settings, such as the daily moming meetings, showed a questioning attitude and command and control by senior managers.
6/11/98 Negative IR 97-82 L
OPS 3A Good team work initiatives had been introduced through the first line supervisor level, but not to the overall work force. The NRC corrective action inspection team noted ineffective communications occurred between certain elements of the maintenance and oversight organizations.
6/11/98 Positive IR 97-82 N
OFS SA Plant management was effective in its efforts to encourage plant personnel to identify problems and the plant staff feels that management is receptive to problems brought forward. Individuals generally characterized the environment as improved and currently receptive to problem identification. There is no reluctance or reservation expressed by individuals to identify problems.
6/11/98 Positive IR 97-82 N
OPS 3C The licensee is adequately responsive to specific harassment, intimidation, retaliation or discrimination (HIRD) case needs. The Employee Concems Program, the Employee Concems t
Oversight Panel and the Safety Conscious Work Environment programs are positive contributions to the overall process.
FROM: 4/1/98 TO 10/30/98 Page 6 of 13 30 November 1998
l MILLSTONE 3 PLANT ISSUES MATRIX l
Date Type Source ID SFA Code item Description
[
6/11/98 Negative IR 97-82 N
OPS 3C NU management has not been fully effective in dealing with trends and common causes for HIRD i
a!!egations generated organization-wide to Employee Concerns Program. The Safety Conscious l
Work Environment processes have nct yet been formalized.
6/11/98 Negative IR 97-82 L
OPS 1C The performance monitoring program was good. The high number of human errors was a weakness that the licensee needs to examine further.
6/11/98 Positive IR 97-82 N
OPS 5A The team's general conclusions regarding the adequacy of the licensee's corrective action program 5B were that the program elements conceming identification, Condition Report (CR) initiation, and CR
(
SC processing were performing well. The threshold for identification of issues, reportability reviews, j
and the assignment of severity level and corrective actions were timely and appropriate. The CR l
program elements conceming root cause, corrective actions, and failure recurrence were considered to be operating at an acceptable level, but with room for improvement.
i 6/11/98 Weakness IR 97-82 N
OPS SB The NRC corrective action inspection team found a notable number of process discrepancies, l
including the boric acid transfer pump air binding issue, in a relatively small samp'e size of CRs, after NU had completed their own extensive self-assessment preparing for this team inspection. For example, the Corrective Actions Program lacked controls over combining similar Condition Reports such that it was not effective in retaining issue descriptions and significance level. This is considered a program weakness.
6/11/98 Negative IR 97-82 N
OPS SB Several CRs were inappropriately classified at a lower Significance Level. There were examples of f
root cause analyses that were narrowly focused. The analysis quality has improved through 1997, but overall performance is still mixed.
6/11/98 Negative IR 97-82 N
OPS SC Some corrective actions were also narrowly focused which missed the opportunity for the process to detect additional existent problems.
l 2
6/11/98 Negative IR 97-82 N
OPS 5B Root cause determinations and corrective actions for recurrent boric acid transfer pump problems l
VIO V10 97-82-06 SC were inadequate. The reportability evaluations were incomplete. Operating experience was not i
LER 98-16 4B considered. A potential unreviewed safety question resulting from non-conservative boric acid tank level technical specification was not identified. The failure to correct the air binding of the boric acid transfer pumps is a violation.
j 6/11/98 Positive IR 97-82 N
OPS 5A The self-assessment program was being adequately implemented and the associated 58 recommendations were beneficial in identifying areas for enhancement and improved performance.
6/11/98 Negative IR 97-82 N
OPS 1A A Condition Report Action Request conceming review of Design Change Notices was closed without VIO VIO 97-82-08 accomplishing the specified corrective actions. This is a violation.
FROM: 4/1/98 TO 10/30/98 Page 7 of 13 30 November 1998
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 6/11/98 Positive IR 97-82 N
OPS 5A Nuclear Oversight was effective in performing audits, general plant oversight, and work survei!!ance activities. Considerable improvement was noted since independent assessments identified weaknesses two years ago in the performance of QA activities 6/11/98 Positive IR 97-82 N
OPS SC Nuclear Oversight procedures and audits have improved and there is good control in the follow up of audit findings.
6/11/98 Positive iR 97-82 N
OPS 3A Quality Control was generally effective in performing the required in-plant inspections. The QC 4C support group was effective in establishing and standardizing the use of QC hold points in work packages.
5/26/98 Negative IR 98-206 N
OPS 4A NRC review of the Unit 3 implementation of NUREG-0737 TMI Action Plan Requirements continued 4C to identify FSAR compliance issues and other licensing basis questions. Similar problems have been documented in previous NRC inspection reports.
5/26/98 Negative IR 98-206 N
OPS SC At Unit 3 a violation was identified for the failure to take prompt corrective actions regarding a VIO VIO 98-206-04 nonconformance with assumed operator performance time required to isolate a steam generator upon a tube rupture.
5/26/98 Negative IR 98-206 N
ENG 4C The inspectors identified several iteras that were inappropriately included on the deferred issues list, including two that may have cha!!enged system operability. Additional licensee actions appear to be necessary to ensure all deferred items are appropriate.
5/26/98 Negative IR 98-212 N
ENG 5C Unit 3 Corrective action for an ACR was determined to be inadequate because 21 solenoid operated VIO IR 98-206 valves important to safety and related cables located in a harsh environment were not included in the VIO 98-206-06 EEQ Program. This could have resulted in improper future maintenance activities. Resulting failure of these components in an unsafe position would result in diversion of ECCS flow to nonsafety related piping and is identified as a violation of 10 CFR 50.49.
5/26/98 Positive IR 98-206 N
PS 1C Effective programs for radiation protection during extended outages have been established at all three units. Additionally, Units 2 and 3 have prepared plans for restart as they related to changing radiological conditions.
5/22/98 Negative IR 98-81 N
PS 1C The licensee failed to provide an adequate fire barrier between the cable spreading room and control VIO VIO 98-81-01 2A room due to inadequately protected structural steel. This is a violation of License Condition 2.H. Fire Protection.
5/22/98 Negative IR 98-81 N
PS 1C The licensee did not initially take appropriate corrective actions to resolve multiple high impedance VIO VIO 98-81-02 2A fault problems on the 120 VAC vital power panels. This is a violation of License Condition 2.H, Fire Protection.
FROM: 4/1/98 TO 10/30/98 Page 8 of 13 30 November 1998
I MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 5/22/98 Negative IR 98-81 L
PS 1C On October 6,1997, the licensee identified that the overcurrent protection design for 4.16kV feeder NCV NCV 98-81-04 2A circuits (class 1E and non-class 1E) would not clear a short circuit in sufficient time to provide LER 97-051 4A adequate cable protection for short circuit conditions. The inspectors concluded that, prior to the relay replacements recently performed, the facility did not conform to the approved design documented in the Fire Protection Evaluation Report. The licensee reported and corrected this deficiency in an acceptable manner.
5/22/98 Negative IR 98-81 L
PS 1C One September 10,1997,the licensee identified the spurious operation of auxiliary feedwater pump NCV NCV 98-81-05 2A turbine exhaust condensate drain line isolation valve during certain fire scenarios which may impact LER 97-059 4A safe shutdown capability. The inspector concluded that prior to the recent tie-in of the exhaust drain line to the drain header, the f acility was not in conformance to the approved design as documented in the Fire Protection Evaluation Report. The licensee reported and corrected this deficiency in an acceptable manner.
5/22/98 Negative IR 98-81 N
PS 1B The licensee took the following actiorss to disposition inadequate implementation of fire protection NCV NCV 98-81-03 1C program controls; (1) The licensee took appropriate actions to verify operability of post-fire safe 28 shutdown equipment. (2) Appropriate measures have been taken to ensure effective evalue' ions of temporary modification impact on the fire protection program. (3) The licensee had adequately implemented the licensing commitment to proceduralize that manual actions identified in the fire hazards analysis as being necessary to achieve safe shutdown after a fire. (4) Corrective actions taken by the licerisee to disposition fire protection issues documented in condition report M3 3373 were acceptable. These issues violated Branch Technical Position (BTP) 9.5-1, Section 4(e).
Section 6, the license condition, and Section 4(h).
5/19/98 LER LER 98-31 L
MAINT Historical performance of the P-4 interlock functional test failed to verify the functionality of specific reactor trip breaker and bypass breaker's contacts and associated cell switch contacts for an at-power breaker alignment. Therefore, the requirements of technical specifications were not satisfied.
Condition existed since the original development of the procedure. In addition, since procedure reviews conducted in response to NRC Generic Letter 96-01 failed'to identify this deficiency, the cause is attributed to inadequate procedure development and human error.
5/8/98 Positive IR 98-205 N
OPS SA Overall, the team found that the implementation of corrective action during the CMP to be SB acceptable in that in the majority of the instances, conditions adverse to quality were identified and SC corrected, in accordance with 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action."
l 1
l FROM: 4/1/98 TO 10/30/98 Page 9 of 13 30 November 1998 O
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 5/6/98 Weakness IR 98-01 N
PS SB A programmatic breakdown was identified with the Post Accident Sampling System (PASS).
VIO VIO 98-01-01 SC Examples of this include: 1) Since 1988, the licensee has not been in compliance with the 2A requirements of the Unit 3 Technical Specification, Updated Final Safety Analysis Report (UFSAR) commitments, and the Emergency Plan. 2) PASS maintenance was found to be ineffective, resu! ting in continual system problems and 31 condition reports generated during the period of 1995-1997.
- 3) Emergency and chemistry surveillance test procedures were found to be inadequate. The failure to maintain an adequate PASS, is a violation.
4/1/98 Positive IR 97-209 N
ENG The ICAVP team determined that the licensee's instrumentation arid contruts engineers demonstrated a good focus on safety and sound engineering practices. The team concluded that the design, installation, and testing of instrumentation and controls used to mitigate the consequences of a LOCA and SGTR accident were adequate. Instrumentation used during the SGTR accident and LOCA were reliable and properly calibrated.
4/1/98 Weakness IR C7-209 N
ENG 2B A problem was identified in the licensee's implementation of their TS 6.8.4 program to reduce leakage from systems outside containment that carry reactor coolant fo!!owing a LOCA. The ICAVP team found that the licensee did not implement an adequate recirculation spray system heat exchanger test program. The licensee's review of this program failed to identify and correct this program weakness during their CMP effort.
4/1/98 Negative IR 97-209 N
ENG 4A In the area of control room and offsite dose consequences, numerous errors and inconsistences SA between the design and licensing bases were identified. Several calculations with different input assumptions covering the same aspects of the analyses were indicative of poor calculation control in this area. Additionally, the licensee's organization responsible for maintaining these analyses failed to recognize the importance of maintaining the design and licensing bases consistent with one another. The licensee was responsive to the issues and indicated a commitment to combine the design and licensing bases into stand alorn calculations, provide additional oversight of the dose analysis group, and verify that the plant operation was consistent with the new design and licensing bases.
4/1/98 Negative IR 97-209 N
ENG 2A The licensee's procedures for conducting design changes met the requirements of 10 CFR Part 50, LER 97-57 4C Appendix B, and licensee personnel adhered to those procedures. Minor weaknesses were identified in the design control manual. Additionally, temporary modifications included substantial calculations that were not contro!!ed to the same level as design changes, and, emergent conditions were not evaluated adequately on systems that had temporary modifications installed. The latter resulted in the potential inoperability of the A emergency diesel generator following a tomado.
FROM: 4/1/98 TO 10/30/98 Page 10 of 13 30 November 1998
MILLSTONE 3 PLANT ISSUES MATRIX Date Type Source 10 SFA Code item Description 4/1/98 Weakness IR 97-209 N
ENG 4B A weakness was identified in the threshold for writing an SE for a Final Safety Analysis Report 4A Condition Report (FSARCR) which later was found to have been previously identified by the licensee.
However, the licensee's corrective actions failed to review FSARCRs between mid-1996 and July 1997. The licensee subsequently determined that SEs should have been written for approximately 50 percent of the FSARCRs written during that period of time. None of the SEs resulted in an unreviewed safety question determination.
4/1/98 Weakness IR 98-80 N
PS 1A Numerous longstanding problems were found to exist in the post accident sampling system.
URI URI 98-80-01 1C Problems revealed by this review included procedures that lacked sufficient detail, deletion of a 2A yearly sump sample, a number of condition reports which did not seem to get the system repaired adequately, missing valve identification, and instrument tubing and fitting leaks. Due to the nature of the problems, these findings are being made an unresolved item and will be documented in a subsequent inspection report.
4/1/98 Negative IR 98-80 L
PS 1C Due to a lapse in tracking respirator qualifications many site emergency response organization NCV NCV 98-80-01 3B (SERO) members became disqualified but were not removed from the SERO roster.
FROM: 4/1/98 TO 10/30/98 Page 11 of 13 30 November 1998
[
MILLSTONE 3 PLANT ISSUES MATRIX ABBREVIATIONS USED IN PIM TABI E j
i CFR Code of Federal Regulations CR Condition Report t
EQ Environmental Qualification
[
4 IR inspection Report MEPL Material Equipment Parts List NNECO Northeast Nuclear Energy Company i
NRC Nuclear Regulatory Commission RSS Containment Recirculation Spray System i
i TS Technical Specifications l
UFSAR Updated Final Safety Analysis Report GENERAL DESCRIPTION OF PIM TABLE COLUMNS t
The actual date of an event or significant issue for those items that have a clear date of occurrence (mainly LERs), the date the source of the f
information was issued (such as for EALs), or the last date of the inspection period (for irs).
Type The categorization of the item or finding - see the Type / Findings Type Code table, below.
t Scarce The document that describes the findings: LER for Licensee Event Reports, EAL for Enforcement Action Letters, or IR forNRC Inspechon Reports.
j D
Identification of who discovered issue: N for NRC: L for Licensee; or S for Self Identifying (events).
t SFA SALP Functional Area Codes: OPS for Operations: MAINT for Maintenance; ENG for Engineering; and PS for Plant Support.
f i
Code Template Code - see table below.
1 I
Details of NRC fmdmgs on LERs that have safety significance (as stated in irs), findings described in IR Executive Summaries, and amplifying g
mformat,on contamed in EALs.
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FROM: 4/1/98 TO 10/30/98 Page 12 of 13 30 November 1998
N MILLSTONE 3 PLANT ISSUES MATRIX TEMPLATE CODES J TYPE / FINDINGS CODES ED Enforcement Discretion - No Civil Penalty 1
Operational Performance: A - Normal Operations: B - Operations Dunne Transeents; C - Wograms W Wocesses Strength Overall Strong Ucensee Performance 2
Material Condition: A - Equipment' Condition or B - Programs and Processes Weakness Overall Weak Ucensee Performance I
EEE*-
Escalated Enforcement item - Waiting Final NRC Action 3
Human Performance: A - Work Performance; 8 - Knowledge, Skills, and Abilities /
T ~
VIO Violation Level I,11, lit, or IV 4
Engmeenng/ Design: A - Design; 5 - Engmeenne Support; C - Programs and l
NCV Non-Cited Violation Processes-Deviation from Ucensee Commitment to NRC l
DEV.
5 Problem Identification and Resolutioin A - Identification; 8 - Analysis; and C -
Positive individual Good inspection Finding Resolmion Negative Individual Poor inspection Finding NOTES:
LER Ucensee Event Report to the NRC Eels are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance with the " General Statement of Policy URI**
Unresolved item from inspection Report and Procedure for NRC Enforcement Action" (Enforcement Policy), NUREG-1600.
Ucensing Ucensing issue from NRR However, the NRC has not reached its final enforcement decision on the issues identified by the Eels and the PIM entries may be modified when the final decisions MISC Miscellaneous - E.m Preparedness Finding (EP),
are made. Before the NRC makes its enforcement decision, the licensee will be Declared Emergency Nonconformance issue, etc. The provided with an opportunity to either (1) respond to the apparent violation or (2) type of all MISC findings are to be put in the item request a predecisional enforcement conference, Description column.
URIs are unresolved items about which more information is required to determine f
whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the PIM entnes may be modified when the final conclusions are made.
i 4
FROM: 4/1/98 TO 10/30/98 Page 13 of 13 30 November 1998 t
'd
j Enclosura 2 MILLSTONE INSPECTION PLAN FOR DECEMBER 1998 THROUGH MAY 1999 L
Inspection No.*Of -
Procedure Tide / Area Planned Dates inspectors Type 81700 Physicaf Sectaity Program fiar Power Resctors / Site-Wide Security Program 12/7/98 -12/11/98 2
Core t
" *"E '
41500 1/18/98 -1/29/98 2
Regional Initiative Confirmatory Action Letter (CAL) Training items t
4 Onh %g of Mm RW oMMn hans e&ow Rmtor 92700 3/1/99 - 3/12/99 1
Regional Initiative facafdes / Unit 3 LER Closure
'I 84750 3/1/99 - 3/5/99 2
Core Unit 2 Effluents Program j
37550
!~,igh- :10.g / Unit 3 Engineering Oversight 4/5/99 - 4/16/99 3
Core Radoecdve Waste Treatment, and EftDuent andEnvironmentalMonitoring /
4/26/98 - 4/30/98 1
Core Site-Wide Environmental Program 83750 Occupadonaf Radadon Exposure / Site-Wide Radiation Program 5/10/99 - 5/14/99 1
Core Effecdveness of Licensee Controls in idendfying, Resolving, and Prevendng 5/10/99 - 5/21/99 4
Regional initiative Problems / Unit 3 Corrective Action Team inspection s
Leaend Core Minimum NRC Inspection Program (Mandatory At All Plants) 3 Regional Initiative Additional inspection Effort Planned By Region 1 Area Specific inspection Focus L
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