ML20236N075
| ML20236N075 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/06/1998 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 1-96-028, 1-96-28, NUDOCS 9807140387 | |
| Download: ML20236N075 (3) | |
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l July 6,1998.
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Mr. M. L. Bowling, Recovery Officer - Technical Services C/o Ms. P. A. Loftus, Director - Regulatory Affairs for Millstone Station NORTHEAST NUCLEAR ENERGY COMPANY PO Box 128 Waterford, CT 06385 l
SUBJECT:
YOUR RESPONSE TO APPARENT VIOLATIONS IN OFFICE OF INVESTIGATION (01) REPORT NO. 1-96-028
Dear Mr. Bowling:
This letter refers to your June 15,1998 correspondence, in response to our May 14,1998 letter.
Thank you for informing us of the corrective and preventive actions docurnented in your.
J letter. Your response is currently under review.
Your cooperation with us is appreciated.
Sincerely, ORIGINAL. SIGNED BY:
Wayne D. Lanning Deputy Director of Inspections I
Special Projects Office
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Docket Nos. 50 245 1
s ll 9907140387 900706 I
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B. Kenyon, President and Chief Executive Officer - Nuclear Group M. H. Brothers, Vice President - Operations J. McElwain, Recovery Officer - Millstone Unit 2 J. Streeter, Recovery Officer - Nuclear Oversight G. D. Hinnenkamp, Director - Unit 3 J. A. Price, Director - Unit 2 D. Amerine, Vice President - Human Services E. Harkness, Director, Unit 1 Operations J. Althouse, Manager - Nuclear Training Assessment Group F. C. Rothen, Vice President, Work Services J. Cantrell, Director - Nuclear Training (CT)
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 l
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 l
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Distribution w/cv of Licensee Response Ltr:
Region i Docket Room (with coov of concurrences)
Nuclear Safety Information Center (NSIC) l 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. Screnci, PAO W. Travers, Director, SPO, NRR J. Andersen, PM, SPO, NRR M. Callahan, OCA R. Correia, NRR B. McCabe, OEDO S. Dembek, PM, SPO, NRR E. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR D. Mcdonald, PM, SPO, NRR P. McKee, Deputy Director of Licensing, SPO, NRR S. Reynolds, Chief, ICAVP Oversight, SPO, NRR D. Screnci, PAO Inspection Program Branch (IPAS)
DOCDESK (Inspection Reports Only)
DOCUMENT NAME:
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Ccpy with attachment / enclosure "N" = No copy
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(860) 447 1791 l as (860) 444 4277 l'lic %rilwnst 1 kihiien Synecm Docket No. 50-245 B17300 U.S. Nuclear Regulatory Commission 1
JUN I 51998 Attention: Document Control Desk Washington, DC 20555-0001 l
I Millstone Nuclear Power Station, Unit No.1 Response to Apparent Violations in Office of Investigations Report No. 1-96-028
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l This letter provides Northeast Nuclear Energy Company's (NNECO) response to your letter dated May 14, 1998.
The referenced Office of Investigations (OI) report W
addresses an event that occurred on July 16,1996, during the removal of a Tri-Nuclear i
filter from the Millstoge Unit No.1 spent fuel pool. NNECO has not been provided a copy of this report / The event has been addressed in NRC Combined Inspection Reports 50-245/96-06, 50-245/96-08, and most recently in 50-245/97-02.
NNECO previously waived the opportunity for a predecisional enforcement conference and provides the requested response in the form of this letter.
Your May 14, 1998, letter refers to two apparent violations.
First, it states that a NNECO employee deliberately failed to follow a procedure while removing the Tri-Nuclear filter. Second, it asserts that this same individual, and a contractor employee, provided incomplete and inaccurate information to the NRC during NRC's investigation l
of the event.
NNECO has acknowledged the root cause of the current Millstone shutdown was ineffective leadership that tolerated performance to low standards. The specific details i
of actions taken to address 16 Key issues, among them Leadership and Procedure Quality and Adherence, are included in periodic reports submitted to the NRC, the most recent of which was entitled, " Progress Toward Restart Readiness at Millstone Station,"
submitted on May 22,1998*. We believe the instances of failing to follow procedures associated with lifting the Tri-Nuclear filter are indicative of those weaknesses. In our March 2,1998* reply to a Notice of Violation we summarized our efforts to address the l
underlying causes of our past performance weaknesses.
W NRC letter to NU, "NRC Office of Investigations Report No. 1-96-028 - Alleged Deliberate Violations of Technical Srteifications During Spent Fuel Pool Activities,"
dated May 14,1998.
l NU letter to NRC, " Progress Towards Restart Readiness at Millstone Station," dated f ay 22.1998.
. 9 NU lette.r to NRC, " Millstone Nuclear Power Station, Unit Nos.1,2, and 3 - Reply to I
' 0[g me,RepQrt Nosa Notice of Violation and Proposed imposition o 50-245/50-336/50-423: 94-44;95-82;96-01;96-03;96-04; 96-05;96-b)
- 08;96-09;96-201]." dated March 2.1998.
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With regard to the second apparent violation, NNECO has no information regarding the l
- statements NRC attributes to these individuals and, therefore, does not have a basis to conclude that any individual. provided incomplete or inaccurate information to the NRC.
'However, NNECO has taken actions to communicate and reinforce management expectations regarding providing complete and accurate information to the NRC.
I in. addition to the actions described in the above mentioned submittals, NNECO provides its response to each of the specific apparent violations in Attachment 1, including an explanation of the reasons for the apparent violation, corrective actions taken, actions to prevent recurrence, and the date when full compliance will be achieved.
There are no new commitments included in this submittal, as indicated in attachment 2.
NNECO does not view the issues presented by the event of July 16,1996 as indicative of current practices. As a result, NNECO views closure of this enforcement action as
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l one in a series of necessary and important steps toward bringing to conclusion a difficult chapter in the company's history. The Leadership Team, together with the
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employees, is contirjuing to work diligently to restore confidence and trust in NNECO's
_1 ability to safely operate our facilities in accordance with the licensing bases, if you have any questions regarding the above, please contact Mr. P. J. Miner at (860)-
440-2085 Very truly yours, i
NORTHEAST NUCLEAR ENERGY COMPANY Martin L. Bowling, Jr.
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l Recovery Officer - Technical Services q
Sworn to and subscribed before me 1
this M ay of.TWE d
1998 Wm{A y
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My Commission expires #6Wwy 2J 2W cc:
See Page 3 1
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. U.S ' Nuclear Regulatory Commission B17300\\Page 3 H. J. Miller, Region I Administrator cc:
S. Dembek, NRC Project Manager, Millstone Unit No.1 T. A. Eastick, Senior Resident inspector, Millstone Unit No.1 W. D. Travers, Ph.D., Director, Special Projects Office W. D. Lanning, Deputy Director of Inspections - Special Projects Office P. F. McKee, Deputy Director of Licensing - Special Projects Office 1
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4 Docket No. 50-245 817300__
s' Millstone Nuclear Power Station, Unit No.1 Response to Apparent Violations in Office of Investigations Report No.1-96-028 i
June 1998 k-
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U.S. Nucl@ar Regulatory Commission B17300\\ Attachment 1\\Page 2 I
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Apparent Violation No.1 - Deliberate Violation of Procedure i
Restatement of the Apparent Violation The investigation determined that one individual deliberately violated Technical Specification 6.8.1a when he failed to follow a procedure while removing the Tri-Nuclear filter. Specifically, the overhead crane was used to lift the Tri-Nuclear filter skid contrary to the special procedure that provided directions for removal of the skid from the spent fuel pool. The investigation also determined that the second individual contributed to the violation of Technical Specification 6.8.1a when he failed to stop the other individual's attempt to remove the Tri-Nuclear filter when he realized the work was not being done in accordance with the procedure.
Reasons for the Apparent Violation At the time of the event, NNECO created an independent Event Review Team (ERT) to determine the root causes and causal factors for the unplanned movement of the stored control rods and personnel contaminations and to recommend corrective actions that would prevent recurrence. The ERT identified numerous actions that occurred during this evolution that were not consistent with station procedures. The ERT determined that the procedural compliance issues associated with this event were primarily associated with: (1) performance of unauthorized work in the field; and (2) not considering procedural requirements when reacting to changing conditicns in the field.
Further, the ERT noted that, during the course of its investigation and interviews, there was no indication that procedures were intentionally violated and that no member of the work crew deliberately failed to follow known procedural requirements. In all cases, the ERT concluded, the actions that were inconsistent with procedural requirements were either not considered to be outside the procedure, or were justified in the rr.ind of the individual as being within the scope or intent of the procedure. NNECO believes that the failure of the work crew to fully adhere to the governing procedure was indicative of historic weaknesses in the area of procedure quality and adherence, i
The ERT identified the following as contributing causes for the procedural non-compliances:
I A perception of "do'ing the right thing" to facilitate the ease in performing a l
i task.
Willingness to accept substandard tools, and compensating fo'r their ineffectiveness by modifying the methods.
Reluctance on the part of workers to terminate a task prior to completion.
Focus is concentrated on the task rather than the procedure.
Incomplete / inadequate pre-job brief.
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U.S. Nuclear Regulatory Commission
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B17300\\ Attachment 1\\Page 3 NNECO does not have a basis to conclude that any member of the Tri-Nuclear filter skid work crew acted with an intention to deliberately v;clate procedures.
- Rather, NNECO views this event as an example of prior poor pedermance in the area of procedure quality and adherence as described in the March 2,1998(" reply to a Notice of Violation.
Corrective Actions Taken and Results Achieved With regard to the specific event, NNECO took disciplinary action, in accordance with its constructive-progressive discipline policy, against two of its employees involved in this event (including the NNECO employee involved in this enforcement action) for failure to meet management's expectations regarding procedural compliance, self-checking, and effective communication.
The ERT recommended a number of corrective actions which have been completed.
Among them were the need to communicate expectations for procedure adherence and improvements to pro,cedural guidance for operations in or around the spent fuel pool.
In addition to reinforcing management expectations regarding compliance with procedures, a procedure was developed to ensure configuration control of equipment and operations in the spent fuel pool area. Additionally, as part of a maintenance refresner course, management expectations regarding procedure compliance, abnormal work conditions, and criteria for work stoppage were reinforced. Also, Health Physics Operations Procedure RPM 2.12.5, " Portable Underwater Filter Systems,"
which covers installation, removal, and operation of the Tri-Nuclear filter, was updated as a result of this event.
In addition to the ERT, formed shortly after the Tri-Nuclear filter skid event, NNECO initiated four Adverse Condition Reports (ACRs) related to the event. ACR M1-96-0247 addresses the event broadly and includes the investigation report and its recommended corrective actions; ACR M1-96-0248 dealt with six personnel contaminations; ACR M1-96-0274 dealt with the consequences of the moved control rod blades; and ACR M1-96-0284 addressed removal of the filter assembly, restoration of the control rod blades, and clean-up of the Millstone Unit No.1 Spent Fuel Pool.
Actions related to this event are more fully addressed in the Millstone Unit No.1 Closure Package which was prepared to address Significant item List item 37 and URI 96-06-02. With the exception of the final corrective action of performing the clean-up of the Millstone Unit No.1 Spent Fuel Pool, which has been scheduled for completion prior to Millstone Unit No.1 RFO 16, corrective actions established in the root cause investigation and in the four ACRs have been completed and were presented in that closure package for NRC review in December,1997.
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'O NU letter to NRC, " Millstone Nuclear Power Station, Unit Nos.1,2, and 3 - Reply to a Notice of Violation and Proposed imposition of Civil Penalties (NRC Inspection Report Nos. 50-245/50-336/50-423:94-44;95-82; 96-01; 96-03;96-04; 96-05; 96-08,96-09,96-201)," dated March 2,1998.
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' U.S. Nuclear Regulatory Commission B17300%ttachment 1\\Page 4 1
Actions to Prevent Further Violations DC 4,
Procedural Compliance, was revised to document and communicate management's expectation for procedure adherence. It has also been modified to include station feedback and enhancements since October,1997.
Continuous monitoring is performed by the line and oversight organizations to identify any areas that may be trending in the wrong direction.
NNECO believes that actions referenced in the cover letter relating to broad based performance improvement are sufficient to avoid future violations of this type.
Date When Full Compliance will be Achieved NNECO has achieved full compliance with respect to the cited violation.
' U.S. Nuclear Regulatory Commission B17300\\ Attachment 1\\Page 5 Apparent Violation No. 2 - Failure to provide complete and accurate information in violation of 10 CFR 50.9 Restatement of Apparent Violation During subsequent interviews with NRC personnel concerning the details surrounding this event, both individuals provided incomplete and inaccurate information to the NRC.
Reasons for the Apparent Violation NNECO has no information regarding the statements NRC attributes to these individuals. Accordingly, NNECO does not have a basis to conclude that any individual provided incomplete or inaccurate information to the NRC.
Corrective Actions Taken and Results Achieved NNECO is not aware of any specific deficiency for which to develop or implement corrective actions. dnetheless, and without suggesting an opinion on the merits of the specific allegation, the new Leadership Team has implemented several actions to clearly communicate _ management's expectations regarding completeness and accuracy in all communications with the NRC. Nuclear Group Policy 4, " Regulatory Compliance and Communications," states the expectations for compliance with the terms and conditions of the operating license, applicable regulatory requirements, regulatory commitments, and for complete, accurate, and timely communications with regulatory agencies. These expectations are reiterated and implemented in procedure RAC 08, Regulatory Communications and Cocketed Correspondence. In addition, the Millstone Unit No.1 Regulatory Compliance Manager prepared and presented a i
briefing sheet entitled " Completeness and Accuracy of Information" to Millstone Unit No.1 managers in February 1998 to further emphasize these expectations.
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In addition, DC 4, Procedural Compliance, was revised to document and communicate management's expectation for procedure adherence. it has also been modified to include station feedback and enhancements since October 1997.
Continuous monitoring is performed by the line and oversight organizations to identify any areas that may be trending in the wrong direction.
Actions to Prevent Further Violations NNECO believes that actions ' described above are sufficient to avoid future violations of the type alleged.
Date When Full Compliance will be Achieved NNECO has achieved full compliance with respect to the cited violation.
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Docket No. 50-245 B17300 l
Millstone Nuclear Power Station, Unit No.1 f
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June 1998 t
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O'S? Nuclear Regulatory Commiss'on B17300%ttachment 2\\Page 2 Attachment List of Regulatory Commitments
'The following table identifies those actions committed to by NNECO in this document.
Any other actions discussed in the submittal represent intended or planned actions by NNECO. Please notify the Manager - Regulatory Compliance at the Millstone Nuclear Power Station Unit No.1 of any questions regarding this document or any associated regulatory commitments.
Regulatory Commitment Committed Date or Outage None None i
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