ML20198F050

Notice of Violation from Insp on 970825-29.Violation Noted: as of 970829,adequate Dose Assessment Methods Were Not in Use.Page 23 of Incoming Submittal Was Not Included

ML20198F050
Person / Time
Site:	Millstone
Issue date:	12/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198F012	List: ML20198F008 ML20198F050
References
50-245-97-81, 50-336-97-81, 50-423-97-81, EA-97-481, NUDOCS 9801090286
Download: ML20198F050 (103)

Text

.

NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket Nos. 50 245,50 336,50-423 PO Box 128, Waterford, CT 06385 License Nos. DPR 21, DPR 65, NPF 49 Millstone Nuclear Power Station EA 97 481 During an NRC inspection conducted on August 25 29,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. 10CFR50.54(q) states that; "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 650.47(b) and the requirements in appendix E of this part.

10CFR50.47(b)(9) states that; " Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of radiological conditions are in use."

Contrary to the above, as of August 29,1997, adequate dose assessment methods were not in use, in that al! personnel responsible for dose assessment could not adequately perform radiological dose assessment for potential offsite consequences of radiological conditions in a manner necessary to support timely emergency management decision making for protective action recommendatione.

This is a Severity Level IV violat on (Supplement Vill Emergency Preparedness).

B. 10CFR50.54(q) states that: "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 550.47(b) and the requirements in appendix E of this part.

10CFR50.47(b)(8) states that: " Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

Contrary to the ebuve, as of August 29,1997, adequate facilities and equipment were not being maintained, in that the TSC/OSC reference library contained uncontrolled drawings and other documents related to the response effort were in the facility but were not marked as controlled documents.

This is a Severity Level IV violation (Supplement Vill Emergency Preparedness).

9001090286 971230 PDR ADOCK 05000245 G PM

Notice of Violation 2 s C. 10CfR50.54(q) states that; "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 150.47(b) and the requirements in appendix E of this part. "... The nuclear power reactor licensee may make changes to these plans without commission approval only if the changes do not decrease the effectiveness of the plans and the piens continue to meet the standards of $50.47(b)and the requirements of appendix E to this part. ..."

Contrary to the above, the NRC determined, by direct inspection, that during June 1997, the licensee implemented Revision 22 to the emergency plan. The licensee decreased the effectiveness of the emergency plan in Revison 22 and implemented it without prior NRC approval. Decrosses in effectiveness included changing accountability time from 30 to 45 minutes, a provision decreasing the coverage for 4 health physics positions from 30 to 60 minutes, and staffing time reductions for  ;

other emergency response staff members.

This is a Severity Level IV violation (Supplement Vill Emergency Preparedness).

D. -10CFR50.54(t) states that; "A nuclear power reactor licensee shall provide for the development, revision, implementation, and maintenance of its emergency preparedness program. To this end, the licensee shall provide for a review of its emergency preparedness program at least overy 12 months by persons who have no direct responsibility for implementation cf the emergency piuparedness program.

The review shallinclude an evaluation for adequacy of interfaces with state and local goverments and of licensee drills, exercises, capabilities, and procedures..."

Contrary to the above, the Audit Report No. A25113, entitiled " Connecticut Yankee / Millstone Emergency Plan Audit and 10CFR50.54(t) Review for 1996" dated January 24,1997, did not include all elements of 10CFR50.54(t) such as adequacy of interfaaes with state and local goverments, emergency preparedness program capabilities, and procedures.

This is a Severity Level IV violation (Supplement Vill Emergency Preparedness).

Pursuant to the provisions of 10 CFR 2.201, Northeast Utilities is h aby required to submit a written statement or explanation to the U.S. Nuclear Reguisary Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 1, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of receipt of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked at a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputhg the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Notice of Violation 3 Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information if you request withholding of such material, you inus.t specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790ib) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at King Of Prussia, PA

- this 30th of Daconibar,1997

Enclosure) i Docket Nov. 50 245;50 336;50 423 f

EA No.97-481 ,

USNRC Region I Public Meeting Room December 22,1997 10:00 a.m. '

List of Attendees: ,

Mluntana Nualmar Power Station Staff ,

i H. Miller, Director Unit Services ,

P. Stroup, Director Emergency Planning Services M.- Bonaca, Director Nuclear Engineering M. Bowling, Millstone Point Unit 2 Recovery Officer D. Amerine, Vice President Nuclear Engineering and Support D. Goebel, Vice President Nuclear Oversite T. White, Director Audits and Evaluation T. Blount, Manager Emergency Planning Services l W. Eakin, Senior Engineer Radiological Assessment  ;

USNRG .

L. Nicholson, Deputy Director, Division of Reactor Safety  !

M. Modes, Chief, Etnergency Preparedness, Safe Guards and Incident Response Center

• Branch J. Durr, Chlef, inspections W. Lanning, Special Projects Office S. Dombek, Special Projects Office ,

D. Holody, Office Regional Adminstrator Technical Staff J. Lusher, Emergency Preparedness Specialist D. Silk, Senior Emergency Preparedness specialist P. Frechette, Safe Guards Specialist D. Screnci, Public Affairs Officer B. _ Fewell, Regional Counsel Other R. Cheyne, Barrington Wellesley A. Male, Pennsylvania Power and Light Company, Manager Nuclear Assessment I

I

s -

r F

! Pre-Decisional Enforcement

! Conference ,

Millstone Emergency Planning issues 4

! 1 l

l NRC Region 1 Headquarters King of Prussia, Pennsylvania l December 22,1997 i # \

l 1 l Northeast Nuclear Energy

.l

\ / .

l Agenda i l + Opening Remarks Martin Bowling

+ Management Assessment David Amerine i

l + Dose Assessment issues Mario Bonaca i l

+ Emergency Plan issues Peter Stroup i

l + Emergency Facilities issues PeterStroup 1

+ Oversight Issues David Goebei Thomas White l -

+ Summary David Amerine

/ s

! 2 l Northeast Nuclear Energy i

• s u

1 s -  :

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E i

i I

I Management l

i Assessment  !

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l_.

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David Amerine l Vice President l Nuclear Engineering & Support  ;

i

1. \

3 i Northeast Nuclear Energy

(_.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . -

! s -

l Insufficient Management involvement is I the Root Cause of the Emergency ,

, Planning Program Deficiencies l

+ This insufficient management involvement:

- permitted technical arrogance l - allowed insen.sitivity to regulations l - did not verify sufficient training l - did not employ sufficient self assessment or ~

oversight

+ Nuclear oversight is now closely monitoring the '

! emergency planning process

+ Management commitment to the emergency plan is strong ,

i e s 4

l Northeast Nuclear Energy '

i

N #

l l

l Dose Assessment l

Issues Mario Bonaca l Director, Nuclear Engineering s v 5

i Northeast Nuclear Energy 1

.lj

\ /

i Restatement of Apparent Violation VIO 50-245. 336. 423/97-081-04 l The combination of misuse of the term TEDE, lack of a rapid I means to compute TEDE, mathematical errors, complex ,

options, questionable assumptions, and

typographical / human factors problems in the dose l assessment procedures warrants a complete review and l upgrade program. This along with the inability to perform  ;

l dose assessment in a timely manner to provide protective ,

l action recommendation upgrades, as discussed in Section P1.4 is an apparent Violation of 10 CFR 50.47(b)(9) which l

l states; " Adequate methods, systems, and equipment for i l assessing and monitoring, actual or potential offsite I

consequences of radiological conditions are in use."

1 e x t 6

Northeast Nuclear Energy h

4

i .

i 1

Insufficient Management Involvement is Root Cause of j Dose Assessment Deficiencies

+ Permitted technical arrogance i

+ Allowed insensitivity to regulation i

+ Did not employ sufficient self-assessment or oversight 7 j Northeast Nuclear Energy

- . _. . -. .--I

j .

i N #

l Steps Taken to Prevent i

Recurrence of Dose 1

Assessment Deficiencies

+ Management ownership, l

l involvement and accountability now established i + Self assessment was performed in i 1997 i

/ \

. 8 I l Northeast Nuclear Energy i

i

r . .

\

( j Corrective Actions l l

That Have Been Taken  !

i, f

l + Dose assessment procedures have been l revised 1 l + The IDA (Initial Dose Assessment) model 1

)

has been developed and implemented -it fully complies with regulatory requirements  ;

I~ + An independent assessment by industry peers helped identify remediation actions

+ Independent experts were utilized to help l

develop and implement solutions i 9

Northeast Nuclear Energy l i

l

i i

s -

Corrective Actions That Have Been Taken

+ Deficiencies, non compliances, problems, '

l comments and concerns have been remedied

+ A Dose Assessment Workshop was l conducted on December 11 and 12,1997 l -agreement on methodology was

\ obtained l

-expectations were communicated

! / s 1 10 Northeast Nuclear Enecy l

i _ - _ _ _ ___ _ __

_ _ _ _ _ _ ~

4

.j N /

Focus of Detailed l Corrective Actions ...

l

+ Adequacy of methods and

! consistency with regulatory j:

requirements ,

l

+ Procedural improveinents i

j + Personnel proficiency and j l performance i i i

. f s .

11 i Northeast Nuclear Energy 1

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Detailed Resolution of l Observations / Findings .

J /ssue: Conrusion with the definition, calculation and use of TEDE as 1' defined in EPA-400 l

4 Resolution: l Procedures were revised. TEDE is now calculated as defined in EPA-400 utilizing the nee: IDA '

j model in both the control room and the EOF 13 '

Northeast Nuclear Energy

-- ~

x f Detailed Resolution of l

Observations / Findings l

/ssue: On-shift personnel made substantial human factors and math errors when performing dose i

! assessments in the control room Resolution:

Manual calculations have eeen  :

replaced with a human engineered computer program (IDA?

j

) 14 i

Northeast Nuclear Energy I

, y l .

l Detailed Resolution of L

Observations / Findings .

lp n

Issue: Performance issues exist il between different assessment ]

l . teams observed l l Besolution: +

l L- Procedures have been revised, [

! training has been upgraded and l

given and on-going drills are j being used to test knowledge , !

v I.

l and proficiency j e s  !;

i 15 i Northeast Nuclear Energy ,

i it,

~

. . 'l V #

Detailed Resolution of Observations / Findings '

Issue: RDAT members had difficulty locating and performing proper attachments within various l procedures Resolution. .

Revised procedures have been  ;

l streamlined and condensed to eliminate confusion i

i 16  !

Northeast Nuclear Energy }

l

l

s -

Detailed Resolution of Observations / Findings

/ssue: On-shift procedure EPOP 4432 l misused TEDE, did not compute thyroid CDE and contained inconsistencies Resolution:

EPOP 4432 was totally rewritten to incorporate the use of IDA. IDA is Quality Software and computes TEDE and thyroid CDE based on l EPA-400 17 Northeast Nuclear Energy

- - - _ - - - _ - - - ._ _ _ _ - _ .. -J

• e N #

Detailed Resolution of Observations / Findings Issue: On-shift personnel had great difficulty performing dose assessment in the walkthrough ,

environment, >50% failure

+

Resolution:

l Old manual calculation methods

! were not human factored. Manual methods have been replaced with IDA. On-shift personnel have been

trained in IDA  !

18 Northeast Nuclear Energy l

N #

Detailed Resolution of -

Observations / Findings Issue: The ADAM [ Accident Dose l Assessment Model? does not compute TEDE, ground deposition .

or CEDE values .

Resolution:

ADAM is now used for plume ]

tracking and field comparison only p u

1. N .

19 t Northeast Nuclear Energy l

1. e s ,

Detailed Resolution of Observations / Findings

! Issue: Data entry worksheets to perform "what-if" calculations with ADAM  !

were cumbersome and overly l

complex Resolution:

All such worksheets have been

eliminated in the new revision of  ;

procedures. IDA is now used to i

l perform what-if calculations 20 Northeast Nuclear Energy j

= .

\ e

Detailed Resolution of l Observations / Findings -

l . Issue: Underlying assumptions and l technical bases for procedures

were not clearly stated, not

! readily available or understood  ;

L Resolution:

Procedures have been revised.

Bases for methods and l conversion factors are contained l within a Basis Document i!

21 Northeast Nuclear Energy

\  ;

Detailed Resolution of Observations / Findings

/ssue: RDAT members had difficulty performing assessments in a sufficiently rapid manner to support emergency management decision-i making Resolution:

Procedures have been streamlined and methods revised to allow for ['

rapid assessments. Drills are .

ongoing to test proficiency .

1. \

22  !

Northeast Nuclear Energy l

N /

Detailed Resolution of Observations / Findings l

l Issue: On-shift procedure EPOP 4432 l (16 comments) 1 i Resolution:

i Comments were resolved Issus: Release Rate procedure s NUC EPOP 4428E (24 comments?  ;

Resolution: .

Comments were incorporated l 24 -

Northeast Nuclear Energy l 1

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Detailed Resolution of Observations / Findings Issue: Dose Assessment procedure NUC EPOP 4428F (7 comments)

Resolution:

Comments were resolved ,

1 25 Northeast Nuclear Energy

}

= .

s ,

No Further Action is Required At This Time for Fuli H Co.mpliance

! + Tabletop practice will continue through the month of January

+ A Nuclear Oversight evaluation will l be performed after all corrective l actions are completed l

l l

26 l Northeast Nuclear Energy

• e N /

Safety Significance is Low

+ Radiation monitor data provides j adequate information for PARS j

+ Default PAR provides adequate public protection i

27 l

Northeast Nuclear Energy

l N #

Conclusions 4

y

+ The 1997 self assessment identified 1

! program deficiencies .

+ Corrective actions to assure l compliance have been taken l

+ Management is fully involved l

+ Safety significance is low i

e s  :

28 i Northeast Nuclear Energy l l

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i Emergency Plan and Facilities issues

~

)

Peter Stroup Director, Nuclear Emergency Planning Services

/ s 29 Northeast Nuclear Energy

6 ,

N /

Restatement of Apparent Violation 4

l The inspectors concluded that with the l implementation of Revision 22 the licensee made changes to the

\ emergency plan which decrease the l emergency plan effectiveness. The

\ changes were :nade without commission i l approval. In some instances the plans as changed no longer meet the standards of 10 CFR 50.47(b), and the requirements l of Appendix E.

t 30 Northeast Nuclear Energy )

.I x '

Ineffective EP Management Control of Change is the Root l Cause of the Apparent Violation

+ Contributing Cause was the j Complexity of Changes

- station Emergency Response l Organization ;j l

l - schedules i i 0 I

. r

/ _

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31

~

i Northeast Nuclear Energy  ;

N /

Steps Taken to Prevent l

1 Recurrence of EP Problems

+ Management Expectations i Communicated j l

+ Strengthened EP Management Staff

+ NU EP Staff Training

- plan importance l

- 50.54 (Q)

+ Continuing Self Assessment- j

+ Department Procedure Enhancements .

]

32 Northeast Nuclear Energy 1

s -

i Corrective Actions That Have Been Taken .

Addressed in Revision 23 (Aua 1997) -

Issue:

l Removed " Normal Station Organization Millstone Station"

(

Resolution:  ;

Returned in Revision 23 i

i l

e s i 33  ;

Northeast Nuclear Energy

S Corrective Actions j That Have Been Taken  !

.[f

,i /\ddressed in Revision 24 (to be aooroved)  !

Issue: ~

l i

Change On-Call to On-Call & l i

4 Subject-to-Call Reporting Time Details Missing

^

for Subject to Call j Resolution: I Added to Rev 24 i!n!

34

- Northeast Nuclear Energy [

t

s _

Corrective Actions l That Have Been Taken l Addressed in Revision 24 (to be anoroved)

i Issue:

1 Station evacuation time changed l

from 30 to 45 minutes Resolution:

Clarity added  ;

l h

! 2

1. \  !

35 i Northeast Nuclear Energy l i

4 j

l . .

N __

Corrective Actions That Have Been Taken

! Addressed in Revision 24 (to be approved)

Issue:

Plan Table 5-1 eliminates on-shift maintenance Resolution:

Accounted for by Plant j Equipment Operators (PEOs).

36 Northeast Nuclear Energy -

k N /

Corrective Actions That Have Been Taken .

Addressed in Revision 24 (to be approved)

Issue:

NUREG 0654 cross reference incomplete

! Resolution: .

Cross reference reviewed and revised  :

i 37 Northeast Nuclear Energy

~ ~

t s e

! Corrective Actions That Have Been Taken 1

1 Addressed in Revision 24 (to be approved)

Issue:

Emergency Action Level details missing from plan Resolution: }

Detail added.

Specific set points not shown i

/ \  !

38 i Northeast Nuclear Energy  ;

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\ /

! Corrective Actions '

That Have Been Taken j

Addressed in Revision 24 {to be approved) l Issue:

incomplete listing of supporting

procedures  ;

Resolution:  !

Full listing provided, including j facility / equipment j maintenance f

/ N E 39 i Northeast Nuclear Energy i; p

e q Corrective Actions That Have Been Taken '

u Addressed in Revision 24 (to be approved) n 1

U Issue:  ;\

o Maps & monitoring locations l

eliminated from plan l

- y 4

Resolution: a 1

Restored via reference to  !

facility / equipment maintenance [

procedures ill

/ \ ,

40 i.

Northeast Nuclear Energy l

t l

Corrective Actions ,

That Have Been Taken Addressed in Revision 24 (to be approved)

Issue:

l Listing of supporting plans and .

i sources omitted  ;

Resolution:  ;

Added to Appendix L i

i l

41 ,

s Northeast Nuclear Energy l i

'N /

l 1 Corrective Actions .

That Have Been Taken 4

Addressed in Revision 24 (to be approved)  !

\

Issue: i

! Inconsistent statement, Section l 6.2, Initial Dose Assessment i i

i Resolution: .

Statement rewritten for j i consistency i:

i 2

i i f s i

! 43 l V Northeast Nuclear Energy 1 ,

_ _ . -_ - . _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ - ~ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ - . _ - _ --

N /

Corrective Actions That Will Be Taken

+ Submittal of Revision 24, MP E-Plan, l Dec 1997, Fall Agreement

+ Management Emphasis with NU EP l Staff, Jan 1998 i

+ NU EP Resource Loaded Schedules -

4

Jan 1998 l

i 44 .

Northeast Nuclear Energy  ;

N /

Safety Significance is Low L

!

• NUREG 1031, Supp 4, December 1985

+1ssues primarily administrative in nature .

45 i Northeast Nuclear Energy l i

s -

i l Conclusions

+ Self Identified Several Issues

+ Timely Correction

+ Emergency Plan Revision 24 i

+ Low Safety Significance i

i I~ '

l 4 e s 46 ,

i Northeast Nuclear Energy 4

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N /

'I i

l 4

Millstone Emergency Preparedness L

i Fac.l.t.i iies 1

a

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i -

1 1 :!

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47 i l Northeast Nuclear Energy -

. L a

l $

s e i

i l Restatement of Apparent Violation '

l l As a result of ERF tours, inspection of emergency response equipment / kits, and a review of the EPMNPS and it implementing procedures, it was determbed that information required by 10 CFR Part 50 to assure that the maintenance of these emergency response l facilities and equipment would be adequately

! maintained was not contained in the plan. An l apparent violation of 50.47(b){8) was identified .

l conceming control ofinformation, documents, l and equipment in emergency response facilities and for the failure to inventory l

equipment following use.

1. s  :

48 Northeast Nuclear Energy

l s -

l

Reasons for Apparent Violation i

+ Ineffective EP Management of Facilities

! + Ineffective EP Management of i Control of Change i

4 4

1. N  !

i 49  ;

Northeast Nuclear Energy

N /

l Steps Taken to Prevent l Recurrence of EP Facilities

! Problems .

+ Elevated management expectations l

i

+ EP staff training on E-Plan importance l

+ Increased detail in EP maintenance l procedures l + Review panel established

• Supporting department procedure l revisions

+ Continuing self assessment 50 Northeast Nuclear Energy i

' e

Principal Categories of L Needed Facilities Attention u

+ Emergency facility items

+ Procedures, documents in l

facilities l + Administrative controls l + Additional information I

d i  :

51 '

Northeast Nuclear Energy

j s .

! Corrective Actions

! That Will Be Taken

+ Supporting department surveillance l procedures revised - March 1998 l + Documented facility readiness reset after use - December 1997

+ Simplification of document ,

maintenance requirements - August l

1998 l + Evaluate OSC locker locations - Jan 1998 .

, s  ;

52 Northeast Nuclear Energy i

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e- -

1 l

s 4

, - n L

Safety Significance is Low [

a

~

j + Facilities and equipment proven l e

operational i

a Issues primarily administrat.ive in

[

nature W4 l

u i

t i

e s  ;

! 53 t i Northeast Nuclear Energy i

ie 4

_ __ . _ _ _ _ _ _ _ _ _ _ . -- - . _ _ --.._----o

-\

i N #

l l i

l Conclusions t

+ Timely correction l + Implemented facility and i .-

equipment maintenance program

- now reflected in E-Plan l

+ Safety significance is low

e

! > j l

4 J

l .

p N 54 l

Northeast Nuclear Energy i

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Dave Goebel .

i 1

i Vice President - Nuclear Oversight i

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Northeast Nuclear Energy 1

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1 N #

Pre 1997 Assessments of Nuclear Oversight Ineffectiveness

• ACR 7007 Event Response Team i

• Fundamental Cause Assessment Team l

l (FCAT) l

• Annual external audits of the program (JUMA) j

• Root Cause Evaluation of the  ;

l Effectiveness of the Oversight ]

l Organization (Jane Grant Report)  ;

'~

56 i Northeast Nuclear Energy l l i

.. . _ _. . I

• O N /

Nuclear Oversight "

Has improved n

[

• Improvements in Nuclear Oversight: ,

a

[ - Nuclear Oversight Recovery Plan i ,

l - Continued improvements going l forward j

• Recent Assessments '

l i  :

- NSAB  ;

-Independent Assessment Team 1

! / N B j 57 i l Northeast Nuclear Energy i i i i __ _ ._ .__ _ -

i

s a l Nuclear Oversight Recovery Plan Developed to improve Performance 1

j

• Restructure and Staff the organization

• Establish training program l

• Revise processes and procedures

• Improve the quality of NO work products j i

• Undergo rigorous assessment by an j industry-recognized Independent j i Assessment Team

• Improve communication with Unit and '

Support Organization i

! 58 l Northeast Nuclear Energy i j i

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i . .!

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l Nuclear Oversight Has Addressed its Weaknesses .

1 5

! Nuclear Oversight Recovery Plan 180 -- -

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Northeast Nuclear Energy  ;

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Assessing Readiness:

l Nuclear Oversight Restart l

Verification Plan (NORVP)

• Identified 22 key issues I

~

• Developed critical attributes i ,

I

• Assess and score attributes l

• Report key strengths and weaknesses

• Provide areas where improvement is j

i needed j

• Emergency Plan is an independent i

area of focus 60 l

Northeast Nuclear Energy

l

• l I

i Unit 3 NORVP NRC 40500 Inspection Readiness 9/19/97 9/26/97 10!T97 10/10/97 10/17/97 l 10/2457 10/31197 11/7?97 11/21!97l 12!5'97 Leadership .Y Y Y Y. Y '

Y Y Y Y Y SelfAssessment Y Y Y' Y Y Y Y Y Y Y

Corrective Action Y. Y Y Y Y Y Y Y Y Y VM

^ ^ ^ ^ ^

NSAB/ Oversight (~ M T MG1 lf: ,%Q i_iiiiu SQ RGf Q^ k~

Physical Plant Readiness 9/12f97 9/19!97 9/2S/97 1013!97 10/1057 10/17/97 10/24/97l 11/7/97 11/21/97 12/5/97 Configuration Management Y Y Y Y Y~ Y Y Y Y .Y Y Y Y Y Y gag G Satisfactory Pmcedural Qual / Adherence 9 O- .i Y- Y..

E;gineering Evaluatioristarted 11/7/97 y y z- g Work Control / Planning Y Y Y Y Y Y Y Y Y .Y- I imrrovement g Needed Maintenance /l&C /dC ^ ~gn 5M Es s Y;gg .Y. Y Y Y OSTI Readiness a significant eakness l 9:12/97 l 9/19/97 l 9/26197 l 10/357 !10/10/97l10/17/97l10/24/97l 11/7/97 11/21/97 12/5/97 SCWE l Y l Y l Y l Y. l' Y l Y l Y' l Y 'Y Y Emergency Prep Wat %2a3:l ~Y l Y l Y l Y .Y Y a Not Assessed Materials l ~ Yf $ BJiel Y' l 'YL l Y' l Y l Y l Y Y' Y Regulatory Compliance l Y l Y' l Y l Y l Y ~' l ~Y l Y l Y Y Y Radiation Protection l Y~-l Y l{4G gjR } gj _ ^ ' Q,5%gGSj Mj g , *g g Training l Y l Y l~ Y l Y" l Y ' ' g85 2l Y ~l Y Y. Y --

Conduct of 0perations Y l Y' l Y l Y;

l~Y' l. Y l Y_ l :- Y ' Y Y Chemistry MGY:ill'?;GF l3gG $ Y - lWSfGl: Y l Y l Y Y- 4#8 !"I Y Y T G'ri V G :' TTG D gg l i

Environ. Compliance Evaluation started 10/3 xY y y Startup & Power Ascension KMirIL BR 15lB Q (;Q _'~ ^^^ __ @ ' fay:j ggj j " [8] ~;

Long Term Perform. Improve. 888 GW M ggL Fire Protection Evaluation started week of 10/24/97 Y~~ '" Y TY ~.Y '

61

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Emergency Preparedness Requires Continued 1 improvement

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.l

. t N /

Nuclear Oversight is an -

Improved Organization l + Emergency Plan is a key part of l our current and future efforts .

l

! + Process and procedures are in place to preclude recurrence of j 1996 EP Audit i

i  !

i 63 Northeast Nuclear Energy l

L_____________________ _ . _ -

1

\ /

1 i

?

l l

l f

i 1

Oversight ssues ,

Thomas White l Director, Audits & Evaluation i

i e s i 64 Northeast Nuclear Energy 1

N /

l Restatement of Apparent Violation ~

l VIO 50-245. 336. 423/97-081-05 l Based upon the extent of concerns l identified by the inspectors review of oversight in the EP area, the inspectors

~^ - concluded that inadequate audits constituted an apparent violation of l

10 CFR 50.54(t).

i 65

! Northeast Nuclear Energy l

s -

Examples of ineffective Management of1996 Audit

+ Audit ineffectively scoped l ..

+ Planning failed to account for changing plant conditions

+ Inappropriate management decision -

no local officials interviewed

+ Insufficient manning for audit

+ Surveillance feedback not included in the report 66 Northeast Nuclear Energy u

e a

/

N Examples of ineffective Management of 1996 Audit

+ Audit ineffectively scoped

+ Planning failed to account for changing plant conditions

+ Inappropriate management decision -

no local officials interviewed

+ Insufficient manning for audit

+ Surveillance feedback not included in the report 66 Northeast Nuclear Energy

.j s <

i Corrective Actions That l

Have Been Taken

+ 'New Management Team - reorganized into SALP areas .

+ Increased the total number of assigned I

auditors - from 7 to 22

+ Completed identification and j verification of commitments -including

10CFR50.54 (t)

+ Upgraded governing procedures l

l + Developing new lead auditors 67 l Northeast Nuclear Energy

i

\

Corrective Actions That .

Have Been Taken ,

+ Audit scope expectations given to all l auditors and challenged by Audit &

l Evaluation Management

+ Expectations for usage of Industry technical specialists established i + Integrated Assessment Teams used for drills and exercises -immediate l feedback given to line - results in audit l conclusions l l + Line involvement improved 68 l

Northeast Nuclear Energy i

i

i

> a .

g /

1997 Audit Was Rigorous and i Performed as Scoped

+ Two industry technical specialists used,

! and local authorities interviewed

+ Five Findings in the areas of:

Post Accident Sampling (2)

Corrective Action Timeliness  !

l Sitewide Administrative Technical Specifications OveraII E-Plan issues l + Six Deficiencies identified 69 Northeast Nuclear Energy

I Conclusions

+ Millstone Audit area has been .

strengthened significantly

+ 1996 Audit was inappropriately managed, poorly written, and lacked rigor

+ 1997 Audit was rigorous and properly

~~

scoped

+ Commitments are captured and utilized

+ Continuous improvement is being j emphasized 0 e s y

Northeast Nuclear Energy

- e N /

4

~

Summary i

David Amerine ,

1 71 Northeast Nuclear Energy

1 . .

I N /

Summary

+ The 1997 Annual Exercise performance was good.

l

+ A number of the issues were self-identified.

+ Appropriate Corrective Actions to restore compliance have been taken.

+ The Nuclear Oversight Department has been declared effective by the Nuclear Safety Advisory Board.

+ The violations are of low safety l significance.

72 i

Northeast Nuclear Energy i

4 9 s -

v k

i

Pete Stroup's .

BACKUP SLIDES

'I

1. N 73 Northeast Nuclear Energy

. ~ r Additional Information  :

I l

+ Changed from one station duty officer per unit to one for the entire station Corrective Action from 1993 Commitment to NRC t i

/ \

74 Northeast Nuclear Energy

l .

l s -

Corrective Actions That Have Been Taken

! + Document control issues resolved

+ E-Plan Revisions 23 & 24 l

+ Improved emergency response facilities controls l

l l

l l

l 75 Northeast Nuclear Energy i

N /

i Corrective Actions That Have Been Taken 1

Emera.ency Facility items Issue:

Lockers Located in Operational l Support Center (OSC) Penthouse

~

~

not ALARA l

Resolution:

Locker locations similar to tool cribs. Further review planned. .

76 Northeast Nuclear Energy

l l x e l

Corrective Actions

That Have Been Taken Procedures. Documents in Facilities Issue

-

Not all key facilities described in MP E-Plan ,

l Resolution:

Detalis added in Revision 24 77

)'

Northeast Nuclear Energy

i N /

l Corrective Actions l That Have Been Taken

Procedures, Documents in Facilities i

Issue:

Maps, status boards, diagrams, minimum staffing chart not described or referenced in the MP E-Plan l Resolution-

! Facility and equipment maintenance l procedure revised to incorporate i

information identified in the issue statement 78 Northeast Nuclear Energy l

! Corrective Actions l That Have Been Taken l' Procedures. Documents in Facilities Issue:

MP E-Plan did not contain

! information describing facility ard l equipment maintenance i

! Resolution:

! Plan describes via reference to i

maintenance procedures in Revision 24 l / N 79 Northeast Nuclear Energy

3 N /

. Corrective Actions ~

l That Have Been Taken Procedures. Documents in Facilities Issue:

Equipment in OSC lockers not .

identified in MP E-Plan 1

1 Resolution.

Now identified via reference to facility and maintenance Procedures addressed in E-Plan Revision 24 i

80 i Northeast Nuclear Energy r

N /

l Corrective Actions

That Have Been Taken l Administrative Controls j Issue:

i Facility map controls Resolution:

Equipment and faciiity procedure revised to j

! address

Issue:

l Director, Station Emergency Operations l (DSEOD E-Plan copy in EOF was not the latest rev -- also, prior .evision found Resolution Current revision provided

/ \

81 Northeast Nuclear Energy i

\ /

l Corrective A.ctions

That Have Been Taken Administrative Controls .l j

issue

Access controls to lockers - EP l lockers were locked - adjacent locker with EP label was not locked

[

~

Resolution:

Locker in question is not an EP

locker - labels corrected 82 l

Northeast Nuclear Energy i

T /

Corrective Actions That Have Been Taken 4

Administrative Controls Issue:

Uncontrolled drawings found in Technical Support Center (TSC) l Resolution:

Working drawings left unattended were removed 33 Northeast Nuclear Energy

. .j

• e l s -

Corrective Actions That Have Been Taken Administrative Controls Issue:

l Some procedures beyond 2-year i review Resolution:

Update sheet provided. One procedure being cancelled - approval for use described in DC-4 i

1 84 Northeast Nuclear Energy

s Corrective Actions That Have Been Taken Administrative Controls issue:

EP Department aware of EOF laboratory equipment calibration l Resolution: '

Calibration documentation now provided to EP Department 85 Northeast Nuclear Energy

s -

Corrective Actions .

That Have Been Taken Administrative Controls Issue: ,

l Copy of the MP E-Plan missing from l the ERFs l Resolution: 1

, Plan copies added to ERFs and Document Control distribution list l

e s 86 Northeast Nuclear Energy

- _ _ _ - - - -- _ ___ - - -, e - .

. .I s -

l Corrective Actions

That Have Been Taken l Administrative Controls

issue

l EP Department did not inventory after l use Resolution:

Inventories were performed after use, but were not documented - now inventories will be documented '

87 Northeast Nuclear Energy c _ _

l x /

!. Corrective Actions-

That Have Been Taken Administrative Controls

~

l Issue:

EP inventories only performed quarterly Resolution:

{

inventories were performed after use, but were not documented - now inventories will be documented

i:

f s 88 Northeast Nuclear Energy l

l s , u 1

Corrective Actions L That Have Been Taken l

Administrative Controls

Issue-EP Department aware of self-l contained breathing apparatus inventory status l

Resolution-j inventory documentation now provided to EP department

~

/ .

s 89 Northeast Nuclear Energy t

__ _ _ - . -~

4 e ,

Corrective Actions That Have Been Taken Additional Information Issue:

DSEO phone inoperable Resolution:

Phone was operable, but area code shown was incorrect - now corrected

/

90 Northeast Nuclear Energy

s -

Corrective Actions j That Have Been Taken Additional Information Issue:

Telephone directory availability Resolution: '

Corporate printed directory is most recent to 1996 electronic directory

! is current - Emergency Planning Users Guide 08 directory is available for SERO, and is updated at least quarterly 91 Northeast Nuclear Energy -

i

i s e Corrective Actions .

, That Have Been Taken

! Additional Information Issue:

Respirator labels do not have expiration date Resolution:

Respirators valid for one quarter from

! inspection date - all respirators within

, certification l

l s  %

92 Northeast Nuclear Energy l

l

s -

Corrective Actions That Have Been Taken Additional Information issue:

No control TLD or finger ring located  :

Resolution: \

Control at TLD issue point or HP offices 93 Northeast Nuclear Energy

x MP Emergency Preparedness Facility Improvements

• Corrective Actions That Have Been Taken Maps, Status Boards, Diagrams, Minimum Staffing Chart Not

~

described or referenced in the l

MP E-Plan Facility and Equipment Maintenance Procedure Revised

~

1 -

to Incorporate i

/

94 Northeast Nuclear Energy

9

• ,' 113 PROGRAMS WHICH PROTECT HEALTH & SAFETY EMERGENCY PLANNING Ensure Millstone Station can effectively respond to an emergency event.

STATUS Open. All issues associated with Unit 3 will be completed by January 31,1998.

PROBLEM STATEMENT Weakness in training and procedure utilization have led to less than satisfactory performance in emergency preparedness, particularly in event classification and protective actions recommendations.

SUCCESS CRITERIA

• Demonstrate effective Emergency Response. - COMPLETED Real: Effective Emergency Response Organization as evidenced by satisfactory performance in the August 21,1997 NRC-evaluated exercise.

• Emergency Planning Programs Upgrade. - PARTIALLY COMPLETED .  ;

ggal; Complete emergency preparedness maintenance program improvemen' actions stemming from emergency preparedness program assessments and inspections conducted in July /Augast 1997.

Current Actual: Many of the programs have been ngraded. The primary elements remaining are the Emergency Plan Revision which is axpected to be completed by December 30,1997, and the finalization of the dose assessment by January 31,1998.

• 114 RECOVERY APPROACH Four (4) steps arc being implemented to restore and maintain the effectiveness of Emergency Planning:

1. Reinforce the expectation that emergency preparedness is a primary duty.

2. Establish an organization staffed with sufficiantly trained personnel.

3. Provide site emphasis on drills, feedback, and critiques,

4. Utilize industry experience to facilitate improvements.

COMPLETED ACTIONS / PROGRESS

1. Reinforce the expectation that emergency preparedness is a primary duty -

PARTIALLY COMPLETED. Established and promulgated Senior Management expectations, in March 1997, regarding the importance of radiological emergency activity in writing to all emergency response pensonnel. Consistent support wa-demonstrated by participation in and attendance at critiques of August 21, Ow n er 23 and November 20 drills. Further reinforcement to be done with SERO personnel is expected to be complete by January 31,1998.

2. Establish an organization staffed with sufficiently trained personnel-COMPLETED.

. Designed Protective Action Recommendation (PAR) Training Material, in May 1997, to address the process. Included State of Connecticut Department of Environmental Protection Management (as recipients of the NU PAR)in the PAR process design.

• Conducted an Emergency Response Organization Job Task Analysis (JTA) in

- January 1997, to ensure design of tasks and functions at the appropriate levels of the response organization and to clarify roles and responsibilities where necessary.

. The Station Emergency Response Organization (SERO) was structurally revised and staffing assignments reinvigorated with senior, experienced personnel. The revised organization was in effect in June 1997.

I

o' 115 e includec radiological emergency activity such as classification, dose assessment, 3 protecth'e action recommendation formulation, and notification to offsite -

- authorit!as into Licensed Operator Requalification Training (LORT) which began -

in February 1997. ,

3. Provide site emphasis on drills, feedback and critiques - COMPLETED ' .

Conducted classroom training and drill scenarios for the emergency response organization personnel. .,

1 e Conducted numerous Station Emergency Response practice drills and training beginning in November 1996. Responders demonstrate understanding and acceptance of recent changes to procedures and tasks between the TSC & EUF.

• Conducted a drill to measure the effectiveness of procedure changes, training,

' and staff performance on June 19,1997. Overall, the emergency plan was effectively implemented.

• Conducted a drill on August 7,1997 to measure continued effectiveness of improvements. The drill demonstrated some areas for further improvement and another drill was held August 13 with acceptable results.

e

• The NRC/ FEMA evaluated exercise was conducted in August 1997 which

! demonstrated the effectiveness of the Millstone emergency Plan. Strengths included but were not limited to Emergency Facility Command & Control, Communications, Facility activation, accountability, Repair Team briefing, dispatch, and debriefing, and State of Connecticut support and interfacec.

l

• Conducted SERO drills October 23, and November 20,1997 with acceptable results.

4. Utilize industry experience to facilitate improvements - PARTIALLY COMPLETED .

. Updated emergency action level clarification documents to include results of

- industry improvements and suggestions from emergency responders. This will be done by December 11,1997 for Unit 3 and February 28,1998 for Units 1 and 2.

• Completed a self assessment of the emergency planning maintenance program in July 1997 with several areas for improvement noted such as the detail within the

- Millstone Emergency Plan document, documentation of activity within the emergency planning group, strengthening of department instructions. Similar findings were made by the NRC during their subsequent program inspection in '

August 1997. These items will all be addressed by December 31,1997.

2 0

110

. Resolved the findings from the NU Self Assessment on Dose Ascessment. An action plan had been developed for the corrective actions but had not yt . been implemented when the NRC EP Program inspection occurred in August 397. -

The inspection findings were in line with the self assessment. Corrective actions were solidified and completed. Procedures wo:e revised and approved by the Station Operating Review Committee (SORC), computer models revised and training conducted in October 1997. Industry peers assisted in the development and critique of the corrected materials. Final evaluation of dose assessment training will be completed by January 31,1998.

• Redesigned the Protective Action Recommendation Process ir, April 1997, to moet industry standaros and the relevsnt aspects of NUREG 0654 Supplement 3 to support a less complex meti.adology for the emergency res, 'ders.

. Benchmarked SALP l Emergency Preparedness performance to establish a going forward standard for the station beginning in September 1996.

REMAINJG ACTIONS

1. Reinforce the porception that emergency preparedness is a primary duty. -

ONGOING Commitment to SERO responsibilities. Achieve, as determined by senior management, consistent support of and participation in emergency preparedness activities by Station managers and personnel. Communicate further reinforcement of requined SERO responsibilities and follow up assessment to be done by January 31, 1998

4. Utilize dustry experience to facilitate improvements ONGOING e Emergency Plan and Equipment improvements.

A review was completed of revision 22 of the Millstone Emergency Plan and several deficient areas were identified through an NU EP Self Assessment.

Revision 23 was produced to correct the deficiencies. A thorough review of revision 23 by an industry expert is underway. Revision 24 to the Emergency Plan and associated facility / equipment maintenance improvements are to be completed by December 31,1997, t

3 1

117 i

. + ;;3 p >;i ,

'N- [

The Exercise Success Criterion has been achieved through successful demonstration of the capability of the Millstone Station Emergency Response Organization in an evaluated exercise conducted on August 21,1997. All attribu'es of a successful ,

response were demonstrated. ,

The Program Maintenance Improvement Success Criterion is partially completed with ,

remaining actions to be complete by January 31,1998. As a result of the Millstone Program Inspection, a revision to the Emergency Plan is required and will be completed t by December 31,1997. -

The Station Emergency Response Organization (SERO) stands ready for full support of the restart of Millstone Unit 3. Further reinforcement of SERO re ,ponsibilities will be complete by January 31,1998.

- . _ . . _ . _ , . -__ -,