ML20237C131
| ML20237C131 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/12/1998 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-423-97-83, NUDOCS 9808200235 | |
| Download: ML20237C131 (3) | |
See also: IR 05000423/1997083
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August 12,1998
p Mr. M. L. Bowling, Recovery Officer - Technical Services
l C/o Ms. P. A. Loftus, Director - Regulatory
Affairs for Millstone Station
NORTHEAST NUCLEAR ENERGY COMPANY
PO Box 128
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Waterford, CT.06385
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SUBJECT: INSPECTION 50-423/97-83
Dear Mr. Bowling:
This letter refers to your July 14,1M8 correspondence, in reponse to our June 12,1998
letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
ORIGINAL SIGNED BY:
Jacque P. Durr, Chief
Inspections Branch
Millstone inspections
Docket Nos. 50-245; 50-336;50-423
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9008200235 980812
PDR ADOCK 05000423
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Mr. M. L. Bowling 2
cc:
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
P. 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 Assessmeat Group
F. C. Rothen, Vice President, Work Services
J. Cantrell, Director - Nuclear Training (CT)
S. J. Sherman, Audits and Evaluation
cc: w/ copy of Licensee's Response Letter
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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Mr. M. L. Bowling 3
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Distribution w/cv of licensee ra=aanse letter: l
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Region i Docket Room (with sney of concurrences)
Nuclear Safety Information Center (NSIC)
! PUBLIC
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. FILE CENTER, NRR (with Oriainal concurrences) i
SPO Secretarial File, Region I i
NRC Resident inspector i
B. Jones, PIMB/ DISP -
W. Lanning, Deputy Director of Inspections, SPO, RI
H. Miller, Regional Administrator, RI -
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M. Callahan, OCA
R. Correia, NRR '
B. McCabe, OEDO
E. Imbro, Deputv '0irector of ICAVP Oversight, SPO, NRR ;
W. Dean, Project Directorate, NRR
..P. McKee, Deputy Director of Licensing, SPO, NRR
S. Reynolds, Chief, ICAVP Oversight, SPO, NRR
D. Screnci, PAO
Inspection Program Branch (IPAS)
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L DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\97-83.RPY
l- To receive a copy of this document, indicate in the box: "C" = Copy without
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attrchment/ enclosure "E" = Copy with attachment / enclosure "N" = No copy
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l OFFICE Rl/DRP l Rl/DRP _
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- . NAME BLUMBERG/db DURR % ),
L DATE pfjg/f7 08/ /98 08/ /98 08/ /98
OFFICIAL RECORD COPY
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Northeast none rerry na. (noot 136), witerrora, er 06383
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C ar beg Millstone Nu-lear Power Station
Northeast Nuclear Energy Company
P.O. Box 128 j
Waterford. Cr 06385-0128 l
(860) 447-1791 l
Fax (860) 444-4277
'Ihe %rtheast !!tilitics System
JUL I 31998
Docket No. 50-423
B17261
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Millstone Nuclear Power Station, Unit No. 3
NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83
Reply to a Notice of Violation
- By letter dated June 12,1998 the Nuclear Regulatory Commission transmitted the
results of the above referenced inspection. The letter included a Notice of Violation
citing six areas where Northeast Nuclear Energy Company's (NNECO's) activities were
not in compliance with Nuclear Regulatory Commission regulations.
Attachment 1 provides a summary cf NNECO's commitments cc.itained in this
submittal. Attachment 2 provides NNECO's response to the Notice of Violation items.
As stated in the individual responses, corrective actions have been taken to restore !
compliance. The cause for the majority of the violations was due to the organization i
being in a " recovery mode" for the past two years and not in an " operational mode".
The corrective actions that we have identified will provide the organization with the
operational focus that is needed to safely operate the unit.
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Should you have any questions regarding the information contained herein, please ;
contact Mr. David A. Smith at (860) 437-5840.
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Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
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Martin L Bowling, Jr.V ,
Recovery Officer - Technical Services
l Attachments (2)
oum. mum
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l U.S. Nucl=r Regulatory Commission
B17261\Page 2
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cc: H. J. Miller, Region i Admir.istrator
W. D. Lanning, Deputy Director, inspections, Special Projects Office
J. W. Andersen, NRC Project Manager, Millstone Unit No. 3
A. C. Cerne, Senior Resident inspector, Millstone Unit No. 5
! W. D. Travers, Ph.D., Director, Special Projects Office
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Docket No. 50-423
B17261
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Attachment 1
Millstone Nuclear Power Station, Unit No. 3
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Summary of Commitments
NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83
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U.S. Nuclerr Regul: tory Commission
B17261\ Attachment 1\Page 1
List of Regulatory Commitments
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The following table identifies those actions committed to by NNECO in this document.
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Please notify the Manager, Millstone _ Unit No. 3 Regulatory Compliance at the Millstone
Nuclear Power Station Unit No. 3 of any questions regarding this document or any
associated regulatory commitments.
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Commitment Description Committed Date
Number or Outage
B17261-01 Revise DC 1, " Administration of Procedures and Complete
Forms", to address the use of the " Temporary
Change" process as described in the Technical
Specifications.
B17261-02 Revise DC 4, " Procedure Compliance" to ensure Complete
a procedure change is processed, if required,
prior to recommencing the performance of a task
- or evolution that was stopped due to instructions
appearing to be inadequate, the occurrence of
unexpected results, or the task or evolution could
not be performed as written.
B17261-03 Revise Procedure RP-4," Corrective Action Complete
Program", to ensure the proper level of apprc. val
l is provided for the extension of any corrective
actions to prevent recurrenca.
The following commitments were previously provided in re!ated Licensee Event (
Report (LER) submittals and are provided for tracking purposes only.
B17183-01 The Reactor Coolant Pump Operability Procedure
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Complete
- (OP3601D.1) and Surveillance Forms acceptance
criteria have been revised.
B17183-02 Training has been conducted for Operations Complete
crews on Technical Specification 3.4.1.3
requirements.
B17183-04 A briefing has been provided to the Operations Complete
Procedure Group to provide management's
expectations of clarity and level of detail in
surveillance acceptance criteria.
B17183-05 A briefing has been provided to Operations crews Complete
on expectations regarding verification of
, information and performance of electrical line-
ups, proper use and satisfaction of acceptance
criteria and the need for surveillance validation. -
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U.S. Nuclecr Regulttory Commission
B17261%ttachment 1\Page 2
Commitment Description Committed Date
Number or Outage
B17188-01 The Steam Generator Blowdown Sample Isolation Complete
Valve 3SSR*CTV19C has been retumed to
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service so the normal path for sampling has been
made available.
B17188-02 The Motor Driven Feedwater pump was re-tested Complete
prior to heat-up.
B17188-03 Operating Procedure (OP3201), " Plant Heatup", Complete
has been revised to place the Motor Driven
Feedwater pump in service prior to exceeding 470
degrees F for the Reactor Coolant System.
B17188-04 The Operations crews have received classroom Complete
and simulator training on lessons learned from
this event.
B17188-05 The Unit Director and Assistant Unit Director Complete
expectations for performing the heat-up/ start-up
activities have been discussed with each
Operating crew.
B17189-01 Shift personnel attended a training session with Complete
Unit Management. Operations Manager
emphasized his expectations for effective conduct
of shift turnover / briefs, with an emphasis on
heightened operator awareness and efficient time
management associated with " active" Technical
Specification Limited Condition of Operation
action statement requirements.
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Docket No. 50-423
B17261
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Attachment 2
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Millstone Nuclear Power Station, Unit No. 3
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, NRC Operational Safety Team Inspection (OSTI) Report No. 50-423/97-83
l Repiv to a Notice of Violation
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U.S. Nuclear Regulatory Commission
B17261\ Attachment 2\Page 1
Nuclear Reaulatory Commission Violation "A" (50-423/97-83-01)
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Restatement of the Violation
Technical Specification (TS) 6.8.3 requires, in part, that temporary changes to
procedures of Specification 6.8.1 (including Appendix A of Regulatory Guide 1.33) may
be made provided (a) the intent of the original procedure is not altered; (b) the change
is approved by two members of plant management staff, at least one of whom holds a
Senior Operator license on the unit affected; and (c) the change is documented and
reviewed by the Plant Operations Review Committee (PORC) or Site Operations
Review Committee (SORC) or Station Qualified Reviewer, ... within 14 days of
implementation.
Contrary to the above, as si February 20,1998, administrative procedure Document
Control (DC) 4, "Procedun I Compliance" allowed operators to make non-intent
changes to procedures without being approved by two members of plant management
staff or reviewed by PORC or 609f' a Station Qualified Reviewer, ... within 14 days of
' implementation. Examples of procedure non-intent changes where required reviews
were not completed included not isolating a residual heat removal (RHR) loop from the
reactor coolant system as required when aligning the RHR loop for safety injection
(OP3310A, Residual Heat Removal System); exceeding the guidance of a procedural
caution statement (SP 3606.4, Containment Recirculation Pump 3RSS*P1D
Operational Readiness Test); and performing procedure steps out of order and not
removing vent rigs (OP 3301D, Reactor Coolant Pump Operation).
NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The reason for this violation is attributed to a lack of understanding of the
administrative requirements for non-intent changes to procedures and the application
of "Not Applicable" or "N/A" when not performing steps.
Corrective Actions That Have Been Taken and Results Achieved
Operating procedures, and a sampling of surveillance procedures were reviewed for
improper use of the term "N/A". Deficiencies identified were corrected through
procedure changes or by adding additional documentation to the forms
DC 1, " Administration of Procedures and Forms", no longer refers to a non-intent
change process and specifically addresses the use of the " Temporary Change" ,
process as it is described in the Technical Specifications.
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U.S. Nucisar R gulttory Commission
B17261\ Attachment 2\Page 2
DC 4, " Procedure Comp!iance" was . revised to ensure a procedure change is i
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processed, if required, prior to recommencing the performance of a task or evolution i
that was stopped due to the instructions appearing to be inadequate, the occurrence of
unexpected results, or the task or evolution could not be performed as written.
Presentations were given to the Millstone Unit No. Unit 3 Shift Managers in order to
! provide clarification regarding this practice. These presentations addressed "The Use
j of 'N/A' to Indicate Non-Performance of Procedure Steps" and " Determining if a
l~ Modification Alters the Original Intent". This included a discussion with the Manager,
l Station Procedure Group regarding the proper use of N/A and documentation required.
This presentation was also shared with the Millstone Unit Nos.1 and 2 Shift Managers.
This material was also posted on the Millstone Web Site and communicated to the
organization through our daily communications newsletter.
l Additionally, a lessons learned memorandum was provided to each member of the
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Operations Department and required to be reviewed prior to the next time they stood a
Control Room shift.
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' Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
- Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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B17261\ Attachment 2\Page 3
( . Nuclear Reaulatory Commission Violation "B" (50-423/97-83-02)
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Restatement of the Violation
TS 3.4.1.3 requires, in part, that at least two of the reactor coolant system loops (from
among 4-reactor coolant system loops and/or 2-residual heat removal loops) shall be
OPERABLE in Mode 4.
Contrary to the above, on April 7,1998, at 22:54 hours, only one reactor coolant
system (RCS) loop was OPERABLE with the plant in Mode 4. This violation continued
until April 8,1998 at 18:10, when a second RCS loop was made OPERABLE.
NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The cause of the event was human error. The Shift Manager used surveillance
information without validating that the Technical Specification requirement for the
' Reactor Coolant System loops OPERABLE in Mode 4 was satisfied within the heat-up
procedure. A contributing cause was insufficient detail in the surveillance acceptance
criteria. (This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee
Event Report (LER) 98-022-00, dated May 8,1998. (Reference Northeast Utiliiies
letter to USNRC, B17183).
Corrective Actions That Have Been Taken and Results Achieved
The following corrective actions have been completed and are described in Millstone
Unit No. 3 LER 98-022-00:
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A briefing has been provided to Operations crews on expectations regarding
verification of information and performance of electrical line-ups, proper use and
satisfaction of acceptance criteria, and the need for surveillance validation.
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The Reactor Coolant Pump Operability Procedure (SP3601D.1) and Surveillance
Forms acceptance criteria have been revised.
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Training has been conducted for Operations crews on Technical Specification 3.4.1.3 requirements.
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A briefing has been provided to the Operations Procedure Group to provide
Management's expectations of clarity and level of detail in surveillance acceptance
criteria.
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved ~
Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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B17261\ Attachment 2\Page 4
Nuclear Reaulatory Commission Violation "C" (50-423/97-83-031
Restatement of the Violation
TS 6.8.1 requires, in part, that written procedures sha!I be established, implemented
and maintained covering the activities referenced in Appandix A of Regulatory Guide !
1.33, Revision 2, February 1978. )
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, item 2a, requires
general operating procedures for cold shutdown to hot standby, item 3j requires
procedures for startup operation and shutdown of safety related pressurized water
reactor (PWR) systems for pressurizer pressure and spray control systems, and item
1d requires that administrative procedures covering procedure adherence and
temporary change method be developed.
Contrary to the above, written procedures were not implemented as evidenced by the
following examples:
' Example 1
Operating Procedure OP 3301-G, step 4.1.6, requires the operators to place the
pressurizer master pressure controller in automatic.
On April 12,1998 operators deviated from the operating procedure and did not place
the master pressure controller in automatic in accordance with step 4.1.6. Instead they
manually lowered the master pressure controller in an attempt to match the automatic
and manual signals. This failure to follow procedures resulted in two inadvertent
openings of the pressurizer power operated relief valve.
NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The reason for this violation was the Unit Supervisor and the Reactor Operator did not
operate the Pressurizer Master Pressure Controller properly due to a lack of
understanding of the controller. Prior to taking the Master Pressure Controller from the
manual mode to the automatic mode of operation (in accordance with step 4.1.6), the
operator was instructed to adjust the controller (in accordance with step 4.1.5) to clear
an annunciator that was lit. This caused the Pressurizer Overpressure Relief Valve
(PORV) to open. This condition then resulted in setting up the controller to an output
that would open the PORV for a second time wnen the 2200 psia interlock reset.
Personnel were performing the steps in accordance with the procedure, however, due
to a lack of knowledge as a result of inadequate training on an infrequently performed
evolution, the event occurred -
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B17261\ Attachment 2\Page 5
Corrective Actions That Have Been Taken and Results Achieved
Following the events, the l&C department was contacted to provide guidance on the
operation of the Pressurizer Master F. essure Controller. Personnel verified that the
controller was functioning properly and that the settings were appropriate. Once this
determination was made and adjustments completed, automatic pressure control was
achieved using procedure OP3301G.
Classroom training was provided to each of the operating crews to address both the
lessons leamed from this event, as well as more specific details regarding the proper
operation of the Pressurizer Master Pressure Controller under normal, abnormal and
emergency operating conditions. The training session commenced with an introduction
from line management which explained the purpose of the training, as well as a clear
understanding of management's expectations regarding the safe operation of the plant
through conservative decision making. Following the classroom training, simulator
sessions were conducted where the terminal objective was for the operators to
demonstrate their ability to transfer pressurizer pressure control between automatic and
manual operation. This included hands-on training for the operation of the Master
' Pressure Controller as well as the Spray Valve Controllers.
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
Millstone Unit No. 3 is in full compliance with respect to the cited violation.
Example 2
Operating procedure (OP) 3201, Plant Heat-up", step 4.4.9, requires that steam
generator level be maintained between 45-55%.
On April 11, 1998, operators failed to maintain the level in the "C" steam generator
between 45-55% during a plant heat-up. The level in the "C" steam generator dropped
to the low-low level setpoint (18%) before level was automatically restored by the
motor-driven auxiliary feedwater pumps.
NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The cause of the event was the failure of Control Room Operations personnel to
diagnose that the Steam Generator "C" level loss was the result of an abnormal
sampling blowdown lineup. Controlling the level in Steam Generator "C", was *
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cddressed by providing additional feedwater flow rather than placing a hold on the
heatup and determining the cause of the level control problem.
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B17261\ Attachment 2\Page 6
An associated cause was insufficient planning and several delays during the initial i
stages of heatup which challenged the shift's ability to meet a 24-hour surveillance
criteria (Technical Specification 3.0.3 action) for Response Time Testing of the Turbine :
Driven Auxiliary Feedwater Pump. Also contributing to the event was lack of testing of I
the Motor Driven Feedwater Pump prior to use. The start of the Motor Driven
Feedwater Pump occurred relatively late in the heat-up evolution providing a relatively ,
short period to recover from the Motor Driven Feedwater Pump startup problems.
i This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event
l Report (LER) 98-C23-00, dated May 9,1998. (Reference Northeast Utilities Letter to
USNRC, B17188).
Corrective A Gons That Have Been Taken and Results Achieved
The following corrective actions have been completed and are described in Millstone
Unit No. 3 LER 98-023-00:
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. The Steam Generator Blowdown Sample Isolation Valve 3SSR*CTV19C has been
retumed to Service so the normal path for sampling has been made available.
. The Moto: Driven Feedwater pump was re-tested prior to heat-up.
. Operating Procedure (OP3201), " Plant Heatup" has been revised to place the Motor
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Driven Feedwater pump in service prior to exceeoing 470 degrees F for the Reactor
Coolant System.
. The Operations crews have received classroom and simulator training on lessons
learned from this event.
. The Unit Director and Assistant Unit Director expectations for performing the
heatup/startup activities have been discussed with each Operating crew.
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
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Millstone Unit No. 3 is in full compliance with respect to the cited violation.
Example 3 l
i Condition Based Maintenance Procedure CBM 105, "PM Program Changes and
l Deferrals for U3", states that, " deferral requests are required if a PM ... cannot be
performed within its grace peiiod."
On April 10,1998, a preventive maintenance task (automated werk order 96-12561) for
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the turbine auxiliary feedwater pump govemor had not been deferred or performed ,
within its grace period.
NNECO's Response
NNECO does not dicpute the cited violation.
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B17261\ Attachment 2\Page 7
Reason for the Violation
The reason for this violation is attributed to personnel error in performing scheduling
activities. Within the Millstone Unit No. 3 power ascension schedule there were three
ascension to Mode 3 activities which represented: 1) the first heat up to Mode 3, 2) the
repair contingency window, and 3) a contingency repair window that followed the
turbine generator overspeed testing. The responsible individual incorrectly scheduled
the Preventive Maintenance for changing the oil in the Turbine Driven Auxiliary
Feedwater pump governor during the third ascension to Mode 3 which was scheduled
for May,1998. The " Preventive Maintenance Change and Deferral Request" submitted ,
by Work Planning for this component was properly approved for deferral with the intent
that the maintenance would be completed prior to steam admission. The individual did
not self check his performance when scheduling this activity.
Corrective Actions That Have Been Taken and Results Achieved
in response to this scheduling error, the individual's supervisor reviewed the details of i
the "Stop - Think - Act - Review" (STAR) program with him. The individual was also I
' counseled regarding management's expectation to take the necessary time to assure f
that the work is perfonned properly. '
Corrective Actions to Avoid Future Violations ,
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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'U.S. Nuclear Regulatory Commission
B17261\ Attachment 2\Page 8
Nuclear Reaulatory Commission Violation "D" (50-423/97-83-04)
Restatement of the Violation
Technical Specification (TS) 3.4.9.2 requires, in part, bat pressurizer temperature shall
be determined to be within the limits at least once per 30 minutes during heat-up or
cooldown.
Contrary to the above, on April 1,1998, pressurizer temperature was not determined to
be within the limits at least once per 30 minutes during a plant heat-up. The
pressurizer heat-up rate was not compared to Technical Specification Limits between
0400 and 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> as required.
NNECO's Response
NNECO does not dispute the cited violation.
Reasort for the Violation
The cause of this event is attributed to human error. The Operator was aware that
- Reactor Coolant System and Pressurizer heat-up surveillance were in progress. The
Operator recorded the Reactor Coolant System heat-up rate as required, but
inadvertently did not take the Pressurizer heat-up rate data, which was on a second
data sheet. Historical computer point data were extracted from the plant computer to
verify Technical Specification limits were not exceeded.
Corrective Actions That Have Been Taken and Results Achieved
The operator was counseled regarding this event and his performance. The individual
was reminded of the importance of proper turnovers and performing surveillance when
required. A lessons learned summary was developed and shared with the Operations
Department.
A training session was provided to the on-shift members of the Operations Department
which incided a specific section in the lesson plan regarding this event. Discussion
during the lesson included the event, the apparent cause, review of the lessons
learned, and a question and answer period. An Operations Briefing Sheet was also
provided to the department detailing the importance of pre-job briefs, understanding the i
task at hand, and the individual roles and responsibilities required when performing the
task.
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
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! Millstone Unit 3 is in full compliance with respect to the cited violation.
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B17261\ Attachment 2\Page 9
Nuclear Reaulatory Commission Violation "E" (50-423/97-83-06)
Restatement of the Violation
Criterion XVI of 10CFR 50, Appendix B, requires, in part, that measures must be
established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, defective material and equipment, and nonconformances are
promptly identified and corrected. For significant conditions adverse to quality,
measures shall assure that the cause of the condition is determined and corrective
action taken to preclude repetition.
Contrary to the above, as of April 13,1998, appropriate corrective actions were not
taken to prevent recurring system alignment deficiencies that were identified in an
investigation report, " Configuration Control of Valves Switches / Breakers, CR M3-97-
0485". These deficiencies included valves not properly aligned, inadequacies in the
implementation of the valve and breaker alignment process, and deficiencies in the
implementation of the locked valve procedure.
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NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The reason for this violation is attributed to management's failure to establish and
implement a comprehensive program to adequately document and track component
alignment deviations controlled by existing processes / procedures. Although existing i
processes / procedures are in place to control the individual aspects of component !
alignment, there has been inadequate integration of these processes / procedures into
an effective common program with a single owner.
Specifically, at the time that Condition Report M3-97-0485 was being investigated,
management did not recognize that the existing program was not adequate. On the
contrary, the investigation determined that the program / process / procedures in place at
the time were adequate and that it was a matter of individuals not implementing the
program correctly. The investigation into these recent examples recognized that the
existing program / process / procedures are not well integrated and that thic was the
cause of the event.
Corrective Actiorr, That Have Been Taken and Results Achieved
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Numerous corrective actions have been taken to address the items noted in the
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inspection Report regarding Configuration Control at Millstone Unit No. 3. These items
are detailed as follows:
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B17261\ Attachment 2\Page 10
Procedure RP4, " Corrective Action Program", has been revised to ensure that the
proper level of approval is provided for the extension of any corrective actions tn
prevent recurrence.
Each of the mispositioned valves identified in the OSTI Inspection Report were verified
to be placed in their proper alignment.
The Millstone Unit No. 3 Operations Manager reinforced procedure compliance with
Operations Department personnel with respect to the procedure requirements in DC4
(Procedure Compliance) that allow the use of "NA's" on procedures and forms.
Additionally, there was a discussion regarding where to document the bases for each
use of a "Not Applicable" statment, and that pen and ink changes to component
configuration on forms are not allowed. (DC 1)
The locked valve program was audited by the line organization to Operations
Procedure OP 3260B " Equipment Control" and discrepancies resolved. An evaluation '
of systems not presently included in the locked valve program was performed against
. the criteria'in OP 32608.-
Completed valve lineup forms required to support the startup of Millstone Unit No. 3
were reviewed in order to identify deviations from approved lineups. The deviations t
identified in the completed lineup forms were resolved by making procedure changes
as necessary. Valves in the lineups that were repositioned after the date of valve
lineup completion had their pc.,sitions verified.
OperatinD Procedure line-ups were reviewed to identify references to throttle valve
positions, and appropriate procedure changes entered to provide necessary guidance
for their settings. Throttle valve positions were verified in the field to assure that
components were properly positioned.
Procedure OP 3260B was revised to clarify requirements for verifying positioning of
locked throttle valves and criteria for independent verification selection requirements.
Procedures were reviewed to determine if independent reviews were properly
documented on the valve line-up sheets. Valve line-up sheets were reviewed and field
walk-downs conducted to verify proper positioning.
The surveillance schedule was updated to include the audit of locked valves in
accordance with OP 32608. In addition, the other 3200 series procedures were
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reviewed for frequency based performance requirements. This effort identified two
enhancements that were incorporated into existing tracking programs to assure proper
scheduling and performance.
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B17W%ttachment 2\Page 11
The Engineenng Department evaluated the criteria for labeling of valves for vendor
supplied skid mounted equipment. The program was determined to be adequate from
the viewpoint that valves that are acaally positioned by the operators in the field are
labeled, and those that are not labeled were determined to be maintenance
convenience valves (e.g., valves such as petcocks are used to avoid having to remove
a pipe cap).
Two systems were reviewed to determine if the proper level of electrical components
were included on valve line-up sheets. The Emergency Diesel and Quench Spray
Systems were both reviewed and determined to either have the appropriate
components listed or they were addressed in other Operating Procedures.
A Multi-Discipline Configuration Control Task Force has been established to evaluate,
trend and recommend improvements in the configuration control processes. This task
force is intended to conduct review of configuration control incidents identified through
unit generated condition reports, Nuclear Oversight audits, and regulatory inspection
reports. The task force examines the programmatic aspects of both valve and electrical
. configuration control including but not limited to tagging, position verification,
inaccessible valves, locked valves, and work practices. Results of the review are
periodically sent to the Unit Director and the Vice President of Operations with
reymmended actions to improve performance. The task force is chaired by a senior i
manager with members that represent various departments from all three Millstone l
Units.
Active tag clearances were field " ified prior to restart to assure that components were
properly positioned. No problems were noted. '
Peer checks have been implemented for operator actions during power ascension to
increase assurance of the proper performance of sufety related operational procedures
and surveillance.
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
l Millstone Unit No. 3 is 'n full compliance with respect to the cited violation.
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'U.S. Nucirr Regul: tory Commission
B17261\ Attachment 2\Page 12
Nuclear Reaulatory Commission Violation "F" (50-423/97-83 d} l
Restatement of the Violation
TS Table 3.3-1, Functional Unit 21, Action 5(a), requires, in part, that with a Shutdown
Margin Monitoring channel inoperable, restore the inoperable channel to operable
status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or verify valves as per Specification 4.1.1.2.2 (potential dilution
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paths), are closed and secured in position within the next four hours.
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Contrary to the above, on April 8,1998, at 21:15 hours, 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> after declaring a {
Shutdown Margin Monitor channel inoperable, the valves identified in Specification '
4.1.1.2.2 had not been verified to be closed and secured in position. On April 9,1998,
upon discovery of this deficiency by the licensee, the valves were verified closed and j
secured in place.
NNECO's Response
NNECO does not dispute the cited violation.
Reason for the Violation
The cause of this condition is attributed to human error in that the shift managers failed
to recognize the need to complete the required surveillance in the allowed time. This
oversight was due to poor prioritization of the required tasks during the shift which
resulted in not assigning a responsible individual to perform these tasks.
This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event
Report (LER) 98-024-00 dated May 1,1998. Reference Northeast Utilities Letter to
USNRC, B17189.
Corrective Actions That Have E>een Taken and Results Achieved
The following corrective actions have been completed, some of which are described in
Millstone Unit No. 3 LER 98-024-00:
. Actions were taken to verify that the boron dilution pathways were secured.
. Shift personnel attended a training session with Unit Management where the I
Operations Manager emphasized his expectations for effective conduct of shift
turnover / briefs, with an emphasis on beightened operator awareness and efficient
time management associated with " active" Technical Specification Limited I
Conditions of Operation action statement requirements.
. Additional detail has been added to the Shift Daily Status Report in order to assure
that Limited Conditions of Operation rewive the proper focus. These have been
added up front in the report and are also discussed during the Shift Manager's
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report at both the morning Work Planning Meetings and the Management Meetings.
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B17261\ Attachment 2\Page 13
Corrective Actions to Avoid Future Violations
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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