ML20216C695
| 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: |
| 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,
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This report also discusses several apparent violations of NRC requirements. An apparent
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violation was identified for Units 1,2, and 3 pertaining to the implementation of the
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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
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evaluations. In addition, an apparent violation was identified for Unit 3 pertaining to
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recirculation spray system design errors that resulted in operation outside of the design
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basis and system inoperability.
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Mr. N. - S. Carns
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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
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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
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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.
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
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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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s.
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Mr. N. S. Carns
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Distribution w/ encl (VIA E-MAIL):
M. Callahan, OCA
R. Correia, NRR
W. Dean, OEDO
G. Imbro, Deputy Director of ICAVP Oversight, 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
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DATE
08/J7/97
08/'14/97
08/
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08/
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08/
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0FFICIAL RECORD COPY
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