ML20216G059
| ML20216G059 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/14/1998 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-423-97-82, NUDOCS 9804170322 | |
| Download: ML20216G059 (7) | |
See also: IR 05000423/1997082
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April 14,1998
Mr. Martin L. Bowling, Recovery Officer - Millstone Unit 2
c/o Ms. Patricia Loftus, Director - Regulatory Affairs
Northeast Nuclear Energy Company
P.O. Box 128
Waterford, CT 06385-0128
Dear Mr. Bowling:
SUBJECT: PRELIMINARY INSPECTION RESULTS
This letter provides the preliminary results of the NRC Region I team inspection of
Northeast Utilities (NU) controls in identifying, resolving and preventing issues that degrade
the quality of plant operations or safety at Millstone Unit 3. This team inspection was
performed onsite from February 9 through February 20,1998, using NRC inspection
procedure 40500, " Effectiveness of Licensee Controls in Identifying, Resolving and
Preventing Problems." The detailed findings of the team inspection will be documented in
inspection report 50-423/97-82. The inspection team leader provided you with the rer.ults
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of the inspection at a public meeting on February 26,1998.
Inspection Scope
Our inspection examined the management processes used to provide direction to the plant
staff in order to facilitate effective and safe plant operations. This was accomplished by
reviewing your goals and expectations, communications and teamwork, receptiveness to
problems brought forward, performance monitoring, and your commitment to resolve safety
committee recommendations and audit / assessment findings.
Our inspection also assessed the adequacy of your corrective actions program including
processes for identification, analysis and resolution of plant deficiencies. The inspectors
evaluated your organization's responsiveness in dealing with issues brought forward by
employees through various channels including your employee concerns program. The team
examined the backlog of open problem reports to verify that safety significant issues are
being tracked to completion, reviewed the process to prioritize corrective actions based on
risk, and evaluated your process for assessing the effectiveness of corrective actions.
The inspectors evaluated your process for site and departmental self-assessments. The
team reviewed the corrective actions that were implemented for several significant self-
assessments and third party audits including actions applicable to Unit 3 from the ACR-
7007 Event Response Team Report, and the actions to improve the Nuclear Oversight
Department taken in response to the 1996 Joint Utilities Management Assessment. In
addition, the inspectors examined the effectiveness of your Performance and Evaluations
Group in their audit, surveillance and quality control function.
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The team observed activities involving the Nuclear Safety Advisory Board (NSAB), the Site
Operations Review Committee (SORC) and the Unit 3 Plant Operations Review Committee
(PORC). The inspectors reviewed your operating experience program, including the
programs for evaluation of industry data and site experience.
Preliminary Assessment of the Management Process
The team found that management communications methods with the plant staff were a
strength. There was a common understanding of management's expectations by plant
personnel. However,it was noted that a strategic plan and vision statement on where the
plant is headed were stillin draft. This is considered a weakness in view of the fact that
the current management has been in place since late 1996. Overall, the Nuclear Group
policies and standards were considered good. Teamwork initiatives at the first line
supervisor and above were developed, but have not been fully extended to the worker
level.
Observations and interviews show that managers and supervisors encourage employees to
identify problems. The plant staff feels that management is receptive to problems brought
forward and 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, either through the Corrective Actions Condition Report
process, the Employee Concems Program (ECP), or to the NRC.
The handling of individual HIRD cases by the Employee Concerns Program and the Safety
Conscious Work Environment (SCWE) program is adequately responsive to specific case
needs. Both technical and human-side problems are generally well addressed. The ECP
case intakes and the Employee Concerns Oversight Panel (ECOP) oversight activities and
surveys are used to identify potential or actual HIRD problems or organizational units which
exhibit barriers to free identification and reporting of problems. These are positive
contributions to the overall process. These mechanisms are effective, especially for the
more significant issues identified as problem areas. However, NU management has not
been fully effective in addressing trends and common causes for HIRD allegations
genersted organization-wide to ECP. A significant backlog of HIRD allegations was
pending investigation and the backlog and emergent HIRD allegations had not been
analyzed by NU for broad trends or patterns, and common causes. As a result, the actions
taken to date had not effectively assessed the nature and substance of the continuing high
incidence rate of HIRD allegations at the time of the inspection. Further, the SCWE
processes have not yet been formalized. That is, the program lacks structure in the form
of procedures, formal processes and documentation requirements.
Preliminary Assessment of the Corrective Actions Process
Overall, the team saw evidence that the corrective actions program is functioning, but it is
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clear that the program will continue to require careful monitoring by NU management to
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ensure sustained performance. For example, the team found a notable number of
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additionalissues in a relatively small sample size of Condition Reports, after NU had
completed their own extensive self-assessment preparing for this team inspection. In
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general, the current findings represent minor process problems with the exception of the
boric acid tank level finding discussed below.
The team found a structurud framework in place that 'provided a strong' definition for the
corrective actions program. There is evidence of a good deal of management attention
applied to infuse quality into the program implementation process. The team observed a
general improving trend in quality over the last year for most program aspects, including
issue identification, classification, analysis and actions to prevent recurrence. However,
deficient conditions were found to exist in some specific root cause analyses and
corrective actions.
The team found that the Corrective Actions Program lacked controls when it combined
Condition Reports such that they did not preserve issues and that they did not maintain
their appropriate significance level. This weakness was evident in the handling of multiple
condition reports concerning deficiencies in the Nonconformance Report process. The
team considers this activity to be a program weakness.
The team noted that the licensee had established a generally low threshold for recording
issues but that there was a tendency to assign a lowur Significance Level classification
than appropriate and to waive root cau.se analysis to similar issues. The team is concerned
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that this practice has the potential to cause trends to be missed and possibly result in
ineffective corrective actions.
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' incomplete corrective actions and root cause analysis were identified during the team's
review of several Condition Reports including the repetitive air binding of the Boric Acid
Transfer pumps. The team noted that NU engineering failed to recognize the potential
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unreviewed safety questir. (USO) which resulted from their initial conclusion of a more
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restrictive Boric Acid 'Iank level requirement relative to the Technical Specification. The
team also observed that the reportability evaluation of the event was incomplete and that
NU failed to consider industry operating experience in their evaluation of the problem.
The team found that long term compensatory measures are in effect for fire protection
systems because surveillance testing which verifies operability of these systems has been
suspended. Compensatory measures are being taken to allow restoration of a fire
protection system, but in this case, are being used inappropriately to substitute for long
term system inoperability.
Preliminary Assessment of Site and Departmental Self-Assessment Process
The team found that self-assessments were typically of high quality. It noted that the
quality assurance and quality control functions of the Nuclear Oversight organization have
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improved as a direct result of improved staffing, qualifications, and knowledge level. Of
note is the Nuclear Oversight Restart Verification Assessment, which the team considered
to be a strong initiative. That Nuclear Oversight now has the opportunity to concur on
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corrective actions taken as a result of its audit findings and nonconformance reports is also
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considered to be a substantive improvement.
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Preliminary Assessment of Safety Review Committse/ Operating Experience Programs
The team found that all three safety review committees (Nudear Safety Advisory Board,
Site Operations Review Committee, and Plant Operations Review Committee) operated
effectively, were well prepared for their meetings, and provided quality input in addressing
the issues before them. The team also noted that the independent Safety Engineering
Group has made considerable progress, albeit at the expense of performing safety reviews,
in reducing the backlog of operating experience (OE) reviews. The backlog of OE reviews
on Unit 3 has been reduced from several hundred to approximately 40. However, the
number of ISEG reviews done in 1997 was only 12, down from 24 the previous year.
Preliminary Findings identified by the NRC Team
The NRC inspection nm identified regulatory issues. Based on our preliminary evaluation,
the following finding m.e being considered as potential violations:
- In the area of design control, the team found problems in the Master Setpoint List
(MSL), in that it was inconsistent and did not contain all of the setpoints and the
calculatiun references as required by NGP 5.23. Also, a potential deficiency with the
sub-cooling margin setpoints was found. In addition, the findings callinto question the
adequacy of setpoint control.
- There were two procedural problems identified with maintaining accurate design basis
documents. The Safety Functional Requirements Manual and the Design Basis
Summaries were not maintained as required by NGP 5.28 and PI-29, respectively.
- The team found problems with meeting the organizationalindependence required by
Section 6 of the Millstone Unit 3 Technical Specifications because of the reporting
relationship between the Radiation Protection Manager and the Maintenance Manager.
These requirements are established in TS 6.2.1.d, the Updated Final Safety Analysis
Report and Regulatory Guide 8.8. Also, the independence required for persons
cerforming the independent Safety Engineering Group (ISEG) reviews for human
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performance issues did not meet the intent of TS 6.2.3.3.
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- The inspection identified several individual problems within the Millstone Corrective
Action Program. _ These problems include: (1) incomplete corrective actions and root
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cause analyses, as illustrated by the repetitive air binding of the boric acid transfer
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pumps, and (2) issue closure without completion of all corrective actions, as was the
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case with Design Change Notice (DCN) review required by CR M3-97-0506and the
closure of an Automated Work Order (AWO) to correct service water flow instrument
anomalies that was associated with Operator Work Around 96-03. The team noted that
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completion of the DCN review was an Adverse Condition Report (ACR) 7007 and
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Configuration Management Program restart commitment.
- The team identified some procedural problems with assigning inappropriate significance
levels for Condition Reports. These included the following: incomplete action on
Generic Letter (GL; 89-13, Service Water Fouling, and GL 90-03, Vendor Technical
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Information Program. These are commitments to the NRC and should have been
classified as at least Level 2. The team also observed that some actions on the
Condition Reports for the incompleto Generic Letter issues had been inappropriately
coded as ' Deferred' until after plant restart.
The team reviewed NU actions c7 four issues related to two NRC Significant items List
-(SIL) items (SIL ltems 41 and 73), and has recommended that all four be closed. These
four issues include: ACR-7007 issues relevant to Unit 3; trending of NCRs; the Technical
Specification audit program; and the adequacy of the Nuclear Oversight Program. The
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closure of these issues also results in the final closure of SIL items 41 and 73.
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The NRC's overall assessment of the effectiveness of your corrective action program will
be based on the results of this inspection, as well as additional evaluations such as the
ongoing inspection of ICAVP corrective actions, the NRC's review of the Employee
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Concerns Program, and the upcoming Operational Safety Team Inspection (OSTI).
The SPO staff willinclude these findings within NRC Inspection Report 50-245/97-82,
which will provide the final observations, findings, and any enforcement actions to which
you will be required to respond based on the results of the subject inspection. No
response to the issues discussed in this letter are required at this time; however, any
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potential enforcement items which warrant prompt corrective actions should be addressed
in a timely manner rather than waiting for the final report.
Should you have any questions or comments regarding the issues discussed in this letter,
please contact me at (610) 337-5126.
Sincerely,
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ORIGINAL SIG ED BY
Wayne D. Lanning
Deputy Director of Inspections
Special Projects Office
Office of Nuclear Reactor Regulation
Docket No. 50-423
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M. L. Bowling
cc:
B. Kenyon, President and Chief Executive Officer
M. H. Brothers, Vice President - Operations
J. McElwain, Unit 1 Recovery Officer
J. Streeter, Recovery Officer Nuclear Oversight
G. D. Hicks, Unit Director - Millstone Unit 3
J. A. Price, Unit Director - Millstone Unit 2
D. Amerine, Vice President for Engineering and Support Services
P. D. Hinnenkamp, Director, Unit 1 Operations
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F. C. Rothen, Vice President, Work Services
J. Cantrell, Director - Nuclear Training
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
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M. L. Bowling
Distribution w/ encl:
Region i Docket Room (with .c_gny of concurrences)
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Nuclear Safety Information Center (NSIC)
PUBLIC
FILE CENTER, NRR (with Oriainal concurrences)
SPO Secretarial File, Region i
NRC Resident inspector
B. Jones, PIMB/ DISP
W. Lanning, Deputy Director of Inspections, SPO, RI
D. Screncl, PAO
W. Travers, Director, SPO, NRR
Distribution w/enci (VIA E-MAIL):
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M. Callahan, OCA
R. Correia, NRR
B. McCabe, OEDO
G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR
P. McKee, Deputy Director of Licensing, SPO, NRR
S. Reynolds, Chief, ICAVP Oversight, SPO, NRR
D. Screnci, PAO
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Inspection Program Branch (IPAS)
DOCUMENT NAME: G:tempfile\\405quc2.410
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