ML20210S860

Forwards Insp Repts 50-245/97-202,50-336/97-202 & 50-423/97-202 on 970520-0721 & Notice of Violations.Several Positive Initatives Re Fire Protection Program Were Taken

ML20210S860
Person / Time
Site:	Millstone
Issue date:	08/29/1997
From:	Lanning W NRC (Affiliation Not Assigned)
To:	Carns N NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20210S864	List: ML20210S860 ML20210S870 ML20210S886
References
50-245-97-202, 50-336-97-202, 50-423-97-202, EA-97-376, EA-97-377, NUDOCS 9709120168
Download: ML20210S860 (5)

See also: IR 05000245/1997202

Text

4

ygRio%

0" *

. UNITED STATES Nbb

8'

lo 3 )

~ f

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 306600001

4

9 . . . . . ,o

August 29,1997

EA Nos. 97 376

97 377

Mr. N.S. Carns, Senior Vice President '

and Chief Nuclear Officer

Northeast Nuclear Energy Company

P.O. Box 128

Waterford, Connecticut 00385

Dear Mr. Carns:

SUBJECT: NRC COMBINED INSPECTION 50 245/97-202;50-336/97 202; 50-423/97-

. 202 and NOTICE OF VIOLATION

On July 21,1997, the NRC completed an inspection at your Millstone 1,2 & 3 reactor

f acilities. The enclosed report presents the results of that inspection. During this

inspection period, the timeliness and effectiveness of corrective actions continue to be a

management challenge. In addition, licensee management must ensure that information

provided to the NRC regarding corrective actions and other regulatory responses is accurate

and complete. Finally, licensee management attention is warranted to integrate Nuclear

Oversight perspectives into the discussion making process, particularly for activities

involving Unit 1 personnel.

Two violations were identified during this inspection period. One violation involved several

f ailures to follow your procedure for the application of overcoat to your service water

system piping at Unit 3. The second violation involved a failure to provide complete and

accurate information in response to a Demand for Information pursuant to 10 CFR 50.54 (f)

at Unit 3. These violations are cited in the enclosed Notice of Violation and a detailed

description of the failures are included in the enclosed report. Please note that you are

required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements. 4

This report also discusses several apparent violations of NRC requirements. An apparent 7

violation was identified for Units 1,2, and 3 pertaining to the implementation of the

systematic approach to training for your technical training programs. Your staff failed to i

properly evaluate trainee mastery of tasks and conduct training program effectiveness

evaluations, in addition, an apparent violation was identified for Unit 3 pertaining to I \

recirculation spray system design errors that resulted in operation outside of the design (

basis and system inoperability.

9709120168 970829 NBC FRE 3EITER* 00m77 b

PDR ADOCK 05000245

G PDR

l.ill.l!lll1llllillI!!.!

. . . .l

.

. _

,

d

Mr. N. S. Carns 2 -

These apparent violations are being considered for escalated enforcement action in

accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG 1600. You will be advised by separate

correspondence of the results of our deliberations on these matters. No response

concerning these violations is required at this time; however, any corrective actions

deemed appropriate should be instituted in a timely manner. Please be advised that the

number and characterization of apparent violations described in the enclosed report may

change as a result of further NRC review.

At Unit 1, your staff planned to perform work on the standby liquid control tank, using an

automated work order. Nuclear Oversight became aware of the plans and raised a number

of questions conceming the use of an automated work order in place of a special

procedure. The lack of clear guidance on when a special procedure is required resulted in

significant resistance from the line personnel to Nuclear Oversight's concerns, in this case,

the effort on the part of Nuclear Oversight to raise standards was not readily accepted by

the line organization and lead to a delay in the completion of the work. There have been

other recent examples involving Unit 1 personnel who have challenged Oversight's efforts

to raise performance and safety standards,

Furthermore, command and control problems were identified within the Unit 1 operations

department. Recent changes require the shift managers to report to the assistant

operations manager, a new reporting requirement. Shift managers expressed a concern

about the operations manager not being included in the decision making process and policy

making for the department. Your staff has takt,n steps to ensure that the roles and

responsibilities of the operations manager and the assistant operation manager are clearly

defined under the new reporting structure. A strong operations management presence is

essential to raising standards within the operations organization. To this end, management

is encouraged to stabilize the organization to provide continuity and leadership.

Since 1993 at Unit 2, numerous licensee events reports, adverse condition reports, and

NRC enforcement actions have discussed concerns whether air operated valve actuator

springs are adjusted to apply sufficient force for the valve to perform its intended safety

function. An escalated enforcement item (EEI) was created to address inadequate

corrective actions regarding the issue and is included on the NRC Significant items List.

NRC review of the eel revealed that corrective actions continue to be narrowly focused in

that the scope of the review was limited to containment isolation valves rather than all

safety-related air operated valves.

Our inspection of the inservice testing program at Millstone Unit 3 indicated that the

evaluation that you performed as part of the topical area review was comprehensive, and

that your ongoing corrective actions were appropriate. Previously, your self assessment of

- the inservice testing program had documented programmatic weaknesses. Your corrective

. actions in several cases, sucli as vibration monitoring of pump drivers, exercising of power-

operated valves, and development of a component level design-basis document, now

exceed the requirements of the American Society of Mechanical Engineers (ASME) Boiler

and Pressure Vessel Code. A good questioning attitude was exhibited by your staff as

.-

. Mr. N S. Carns 3

exemplified by your identification of a potentislly generic issue involving in situ testing of

main steam safety relief valves.

As detailed in the enclosed inspection report for Unit 3 significant items list (SIL) issue

closure, your submittal of SIL packages for NRC review has been well controlled and the

pa?.kages have generally provided sufficient information for NRC close out of the item.

Additionally, the inspection report details progress in the development of initiatives and

improvements in technical program (e.g., inservice testing) areas. However, a significant

amount of work remains to be accomplished in other program areas. Your Nuclear

- Oversight organization has identified continuing concerns in the areas of corrective action,

training, and configuration management program controls. These concerns have been

validated to some extent by the Unit 3 findings documented in the enclosed inspection

report. Licensee management emphasis upon properly defining the problem to be solved

may affe::t in large measure the success of your corrective efforts in implementing an

ef fective problem resolution.

The program for maintaining occupational exposures as low as is reasonably achievable

-(ALARA) at each of the three units remains weak. While the framework for an ALARA

l program has been implemented at Units 1 and 2, with the creation of an ALARA

!

Committee and the implementation of an operational work control and work planning

! group, neither have been established for a long-enough period to fully evaluate their

effectiveness. The continuing lack of an effective work control and planning process

together with the lack of a unit ALARA Committee at Unit 3 continues to be of concern.

Generalimprovement was observed in the area of radworker practices.

We found that you have taken several positive initiatives regarding the fire protection

program with significant improvements noted in oversight and organization of the program

L and fire brigade perfcrmance.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures will be placed in the NRC Public Document Room (PDR).

Sincerely,

N

1Va e . Lanning

Dep ty Director of I sp tions

Special Projects Offi .NR

Docket Nos. 50-245

50-336

50-423

Enclosures:

1. Notice of Violation

2. NRC Combined Inspection Report 50-245/97 202; 50-336/97 202; 50-

423/97 202

.

Mr. N. S. Cams 4

.

ec w/enet:

M. Brothers, Vice President Millstone, Unit 3

J. McElwain, Unit 1 Recovery Officer

M. Bowling, Jr., Unit 2 Recovery Officer

D. M. Goebel, Vice President, Nuclear Oversight

J. K. Thayer, Recovery Officer, Nuclear Engineering and Support

P. D. Hinnenkamp, Director, Unit Operations

F. C. Rothen, Vice President, Work Services

J, Stankiewi6z, Training Recovery Manager

R. Johannes, Director Nuclear Training

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/ench

Region I Docket Room (with EQ2Y. of concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC

FILE CENTER, NRR (with Oriainal concurrences)

NRC Resident inspector

W. Axelson, DRA

M. Kalamon, SPO, NRR

W. Lanning, Deputy Director of Inspections, SPO, NRR

H. Miller, Region Administrator, Region I

D. Screnci, PAO

W. Travers, Director, SPO, NRR

B. Jones, PIMB/ DISP

.,

f.

'* Mr. N. S. Carns 5-

Distribution w/enci (VIA E MAIL):

J. Andersen, PM, SPO, NRR

M. Callahan, OCA

'

R.- Correla, NRR.

W. Dean, OEDO

S. Dembek, PM, SPO, NRR i

G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR

D. Mcdonald,- PM, SPO, NRR

P. MqKee, Deputy Director of Licensing, SPO, NRR

S. Reynolds, Technical Assistant, SPO, NRR

D. Screnci, PAO

Inspection Program Branch (IPAS)

DOCDESK

i

u -

--- - . - - ,