ML20216C695

Forwards Insp Repts 50-245/97-202,50-336/97-202 & 50-423/97-202 on 970529-0721 & Nov.Nrc Found That Licensee Have Taken Several Positive Initiatives Re Fire Protection Program W/Significant Improvements Noted in Fire Brigade

ML20216C695
Person / Time
Site:	Millstone
Issue date:	08/29/1997
From:	Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carns N NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20216C700	List: IR 05000245/1997202 ML20216C695 ML20216C747
References
50-245-97-202, 50-336-97-202, 50-423-97-202, EA-97-376, EA-97-377, NUDOCS 9709090123
Download: ML20216C695 (5)

See also: IR 05000245/1997202

Text

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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 06385

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

facilities. 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

failures 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

tegulatory requirements,

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

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

systematic approach to training for your technical training programs. Your staff f ailed to

properly evaluate trainee mastery of tasks and conduct training program effectiveness ,

evaluations. In addition, an apparent violation was identified for Unit 3 pertaining to / ()

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

basis and system inoperability.

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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 concerning 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 taken steps to ensure that the roles and

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

defined under the new reporting structure. A strong operations manag6 ment 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 conditiori 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

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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 o'

the inservice testing program had documented programmatic weaknesses. Your corrective

actions in several cases, such 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

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Mr. N. S. Carns 3

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exemplified by your identification of a potentially 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

packages 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 te solved

may affect in large measure the success of your corrective efforts in implementing an

effective 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

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

and fire brigade performance,

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,

ORIGINAL SIGNED BY

WAYNE D. LANNING

Wayne D. Lanning

Deputy Director of Inspections

Special Projects Office, NRR

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

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Mr. N. S. Carns 4

cc w/ encl:

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. Stankiewicz, 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/ encl:

Region I Docket Room (with e of concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC

FILE CENTER, NRR (with Orioinal 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/C SP

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Mr. N. S. Carns E

Distribution w/ encl (VIA E-MAIL):

J. Andersen, PM, SPO, NRR

M. Callahan, OCA

R. Correia, NRR

W. Dean, OEDO

S. Dembek, PM, SPO, NRR

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

D, Mcdonald, PM, SPO, NRR

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

S. Reynolds, Technical Assistant, SPO, NRR

D. Screnci, PAO

Inspection Program Branch (IPAS)

DOCDESK

DOCUMENT NAME: 1:\ BRANCH 6\lR97202.123

T1 receive a copy of this document. Indicate in the box: "C" = Copy without attachtwat/ enclosure 'E' = Copy with attachment / enclosure "N" = No copy

0FFICE RI/SP0 E RI/SRQ ,-- / l l l

NAME DURP M LAfMNi

DATE 08/J7/97 08/'14/97 08/ /97 08/ /97 08/ /97

0FFICIAL RECORD COPY

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