ML20238C245
| ML20238C245 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/02/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20238C246 | List: |
| References | |
| NUDOCS 8709090722 | |
| Download: ML20238C245 (4) | |
See also: IR 05000423/1985098
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'02 SEP 1987
Docket No.
50-423
Northeast Nuclear Energy Company
ATTN:
Mr. E. J. Mroczka
Senior Vice President - Nuclear
Engineering and Operations Group
P. O. Box 270
Hartford, Connecticut 06141-0270
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Repert 50-423/85-98
and Your Reply Letter Dated July 16, 1987
This forwards the amended Millstone 3 SALP for the period from September 1,
1985 through February 28, 1987.
The SALP report was initially forwarded to you
by our May 14, 1987- letter (Enclosure 1).
On June 18, 1987, we discussed the
SALP with you and your staf f (see Enclosure 2 for attendees). We have reviewed
your written comments, dated July 16, 1987 (Enclosure 3), and herewith transmit
the final SAi.P r eport (Enclosure 4).
In addition, an errata sheet (Enclosure
5) is provided to ass;st in locating changes.
Our review of your comments resulted in their basic inclusion in the SALP in
most cases. We have also made other minor changes based upon our review of
oral comments by your staff, as well as a few editing changes. We did not,
however, incorporate all of your comments.
In the Radiological Controls area,
you commented that the RP group was challenged during the July-August outage.
We recognized that good performance, but found it did not provide a significant
enough challenge to affect our assessment.
In the Licensing Activities area,
you commented that you believe the NRC did not fully understand your approach
l
to the Nuclear Review Board quorum or the information provided on N-1 (three)
loop operation. We acknowledge your recent actions to resolve these matters,
but they did not change our assessment. The resolution of these issues and the
NRC assessment of associated overall performance will be considered for
inclusion la the next SALP.
We appreciate your comments on the SALP and the discussion of your plans for
improving performance.
Thank you for your cooperation.
Sincerely,
I
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87090907D2 070902
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ADOCK 0500
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0FFICIAL RECORD COPY DL30-423/85-98-FINAL - 0001.0.0
08/27/87
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Northeast Nuclear Energy Company
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'02 SEP 1987
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Enclosures:
1.
NRC Region I Letter, W. T. Russell To E. J. Mroczka, dated May 14, 1987
2.
SALP Management Meeting Attendees
3.
Northeast Nuclear Energy Company Letter, E. J. Mroczka to NRC Document
Control Desk, dated July 16, 1987
4.
Systematic Assessment of Licensee Performance Report 50-423/85-98
5.
SALP Board Errata Sheet
cc w/encls:
W. D. Romberg, Vice President, Nuclear Operations
D. O. Nordquist, Manager of Quality Assurance
R. M. Kacich, Manager, Generation Facilities Licensing
S. E. Scace, Station Superintendent
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Rogers
Vandana Mathur, McGraw-Hill Publications (2 copies)
Art McGuire, Construction Industry Litigation Reporter (2 copies)
Public Document Room (PDR)
Local.Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Senior Resident Inspector
State of Connecticut
bec w/ encl:
' Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
J. Taylor, DED0
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W. Russell, RI
J. Allan, RI
D. Holody, RI
K. Abraham, PA0 (2 copies)
T. Martin, DRSS
W. Johnston, DRS
W. Kane, DRP
5. Collins, DRP
DRP Section Chief
T. Rebelowski, SRI, Millstone 1&2
B. Doolittle, LPM, NRR
S. Barber, DRP
l-
Management Meeting Attendees
l-
DRP WISHLIST Coordinators
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RI:DRP
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ENCLOSURE 1
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Docket / License:
50-423/HPF-49
NAY I 4 1987
Northeast Nuclear Energy Company
ATTN:
Mr. Edward J. Mroczka
Senior Vice President, Nuclear
-Engineering and Operations
P.O. Box 270
Hartford, Connecticut
06101-0270
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-423/85-98
On April 16, 1987, the NRC Region I SALP Board reviewed and evaluated the perform-
ance of the Millstone Nuclear Station, Unit 3.
This assessment is documented in
the enclosed SALP Board Report.
A meeting will be separately scheduled to disc;as
the assessment. That meeting's purpose is to provide a forum for candid discus-
sions relating to the performance evaluation.
At the meeting, you should be prepared to discuss our assessment and your plans
to improve or emphasize activities which affect performance.
Any comments you may
have regarding our report may be discussed.
Additionally, you may provide. written
comments within 30 days after the meeting.
Following our meeting and receipt of your response, the enclosed report and your
written response will be placed in the NRC Public Document Room.
Thank you for you cooperation.
Sincerely,
h .T. kv - *Y
William T. Russell
Regional Administrator
Enclosure:
NRC Region I SALP Report 50-423/85-98
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Northeast Nuclear Energy Company
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cc w/ enc 1:
W. D. Romberg, Vice President, Nuclear Operations
S. E. Scace, Station Superintendent
R. M. Kacich, Manager, Generation Facilities Licensing
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D. O. Nordquist, Manager, Quality Assurance
Chairman Zech
Commissioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Carr
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Senior Resident Inspector
State of Connecticut
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bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
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DRP Section Chief
J. Shedlosky, SRI, Millstone 3
E. Doolittle, NRR
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R. Ferguson, LPM, NRR
J. Stolz, NRR
J. Taylor, NRR
W. Russell, RI
K. Abraham RI (2 copies)
SALP Board Attendees
Record Center, INP0
T. Rebelowski, SRI, Millstone 1/2
G. Grant, RI, Millstone 1/2
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ENCLOSURE 2
NRC/ NORTHEAST NUCLEAR ENERGY COMPANY MANAGEMENT MEETING
JUNE 18, 1987
NAME
TITLE
NRC Region I
William F. Kane
Director, Division of Reactor Projects (DRP)
Ebe C. McCabe
Chief, Reactor Projects Section 3B, DRP
J. Thomas Shedlosky
Senior Resident Inspector, Millstone 3
Paul D. Swetland
Senior Resident Inspector, Haddam Neck
Andra A. Asars
Resident Inspector, Haddam Neck
NRC, Nuclear Reactor Regulation (NRR)
Cecil 0. Thomas
Director, Integrated Safety Assessment
Francis M. Akstulewicz
Haddam Neck Project Manager, PDISA
Robert L. Ferguson
Millstone 3 Project Manager, PDI-4
Elizabeth L. Doolittle
Millstone 3 Project Manager, PDI-4
State of Connecticut
Kevin T. McCarthy
Director, Radiation Safety, Department of Environmental
Protection
Northeast Nuclear Energy Company - Corporate
William B. Ellis
Chairman and Chief Executive Officer
Bernard M. Fox
President, Northeast Utilities
John F. Opeka
bkecutive Vice President - Engineering and Operations
Edward J. Mroczka
Senior Vice President - Nuclear Engineer and Operations
Wayne D. Romberg
Vice President - Nuclear Operations
Richard P. Werner
Vice President - Generation Engineering and Construction
C. Frederick Sears
Vice President - Nuclear and Environmental Engineering
0. Peter Terragna
Vice President - Corporate Performance Services and
Organizational Control
E. Randolph Foster
Director, Generation Construction
Donald O. Nordquist
Director, Quality Services
Grant D. Baston
Director, Nuclear Engineering and Operations
Reginald C. Rodgers
Director, Nuclear Engineering
G. Leonard Johnson
Director, Generation Engineering and Design
J. Malcolm Black
Director, Nuclear Training
Thomas J. Dente
Superintendent, NUSCO Nuclear Operations
Richard M. Kacich
Licensing Manager
Albert J. Hajek
Manager,. Corporate Performance Services and Organizational
Control
Generation Facilities Licensing Supervisor
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Enclosure 2
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Northeast Nuclear Energy Company - Corporate (Cont.)
Jack R. Barnett
Generation Facilities Licensing
George R. Pitman
Connecticut Yankee NRB Chairman
Mario V. Bonaca
. Millstone 3 NRB Chairman
Robert N. Smart
Millstone 2 NRB Chairman
Stuart A. Thickman'
Supervisor, Nuclear Safety Engineering
James P. Hoben
Corporate Performance Services and Organizational Control
Haddam Neck Plant
Donald B.-Miller
Station Superintendent
Gary H. Bouchard'
Unit: Superintendent
Eric A. DeBarba
Station Services Superintendent
Leo J. Nadeau
Manager, Generation Projects
Walter L. Varney
Manager, Plant Quality Services
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Roy E. Brown
Operations Supervisor
Donald J. Ray .
Engineering Supervisor
William D. Bartron
Maintenance Supervisor
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Bruce R.-Danielson
Instrument and Control Supervisor
Harold E.' Clow
Health Physics Supervisor
Michael D. Quinn
Chemical Supervisor
Walter E. Heining
Quality Assurance Specialist
William F. Nevelos
Radiation Protection Specialist
Peter A. Marchese
Security Supervisor
James H. Asburner
Supervisor, Generation Construction
Thomas Kazukynas
Fire Protection Engineer
Anthony E. Nericcio
Public Information Specialist
, Millstone Site
itephen E. Scace
Station Superintendent
Carl H. Clement
Unit Superintendent
Harry F. Haynes
Station Services Superintendent
Kenneth L. Burten
Operations Supervisor
James S. Harris
Engineering Supervisor
Ronald W. Rothgeb
Maintenance Supervisor
Ronald Sachatello
Radiation Protection Supervisor
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ENCLOSURE 3
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NORTHEAST UTILITIES
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HARTFORD CONNECTICUT 06141-0270
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July 16,1987
Docket No. 50-423
B12591
Re: SALP
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, D.C. 20555
Gentlemen:
Millstone Nuclear Power Station, Unit No. 3
Systematic Assessment of Licensee Performance
The NRC Staff recently forwarded the SALP Board Report (l) for the 18-month
period ending February 28, 1987 for Millstone Unit No. 3. Subsequent to receipt
of the SALP Board Report, a meeting was held on June 18, 1987 between
members of the Staff and members of Northeast Nuclear Energy Company
(NNECO).
The purpose of this letter is to respond to and comment on the findings of the
SALP Board with particular emphasis on the Board recommendations for the
individual evaluation categories. The responses to the Board's recommendations
for Millstone Unit No. 3 are contained in Attachment A to this letter.
NNECO takes very seriously the ratings and recommendations given by the Board
as an input into the continuing process of evaluating and improving our overall
performance.
As reflected by our comments and observations during the
June 18,1987 meeting, we generally concur with the Board's observations and
previously have taken or are taking steps to address the concerns identified. It
remains our objective to achieve Category I rating in all functional areas for
subsequent SALP evaluations, and the attachment to this letter describes some
of the steps we will be taking to fulfill that objective.
(1)
W. T. Russell letter to E. J. Mroczka, "SALP Report No. 50-423/SS-9S,"
dated May 14,1987.
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U.S. Nuclear Regulatory Commission
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B12591/Page 2.-
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July 16,'1987
We trust that the actions presented in the attachments addressing the concerns
of the Board and our general comments will be considered in subsequent SALP
evaluations.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
'G .S h
E. J. Mroczka
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Senior Vice President
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By: C. F. Sears
Vice President
cc:
W. T. Russell, Region I Administrator
R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3
W. J. Raymond, Resident inspector, Millstone Unit No. 3
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Dock.et No. 50-423
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Attachment A
Northeast Nuclear Energy Company
Millstone Unit No. 3
Response to SALP Report
July 1987
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Functional Area:
PLANT OPERATIONS
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Board Recommendation: Reduce unnecessary annunciations and reactor scrams.
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Response:
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We agree with the overall assessment in this area. We are pleased that the NRC
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recognized significant operator strengths including improved operator ability to
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cope with feedwater system transients, the formality of control room operations
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and direct management involvement in plant operations. We intend to continue
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to emphasize and refine the programs which support these strengths.
We concur with the Board's recommendation to reduce unnecessary annunciations
and reactor scrams. Engineering projects are currently underway to redesign
annunciators to actuate only for actual abnormal conditions and remove
annunciators where appropriate. While we will not reach our goal of a " black"
annunciator board by the end of the first refueling outage, we do expect to
eliminate many of the lit annunciators by that time.
With respect to reactor trips we recognize the advantages of reducing reactor
trips to the absolute minimum. The steam generator condensate pots will be
replaced during the refuel outage to eliminate the transitional level control
oscillations that presently occur between 52% and 65% power. This modification
will also permit the steam generator low - low level trip to be restored to 23.5%
versus the present value of 36.5% A Technical Specification change request
concerning this change will be submitted to the NRC with our Reload 1/ Cycle 2
license amendment request package.
We have also improved our startup
procedures to optimize plant control based on actual operating experience and
will continue to develop our root cause analysis ability to ensure corrective
actions are effective. We believe that these initiatives will reduce the number
of unnecessary reactor trips.
In addition, efforts in the following areas which were cited as strengths in the
SALP Report will continue to be high management priorities. The current effort
to maintain and improve plant housekeeping will be vigorously pursued by
continuing the plant painting program, management tours and correction of
contamination sources.
It has been a continuous management priority to
minimize the number of jumper and lifted leads and aggressively pursue
removing those currently installed. Procedure review and upgrade based on plant
operating experience is another ongoing effort that will receive high priority,
in the SALP Report, it is stated that a minor training weakness was a lack of
operator knowledge in local manual control of feed regulating valves.
This
deficiency was immediately corrected by formal in-plant training for all
operators, and will continue as a part of the non-licensed operator training
program.
The other minor training weakness reported in this section involves " incorrect
simulation of plant configuration" contributing to a safety injection. Although
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the original Pjant incident Report made that assessment, subsequent review of
simulator fideh?y revealed that the simulation was indeed correct and no
configuration change was necessary.
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To summarize, we will continue to stress programs which have contributed to
strengths in the past and have implemented management priorities to strengthen
areas identified for improvement.
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Functional Area:
RADIOLOGICAL CONTROLS
Board Recommendation: Improve technical oversight of radiological monitor
calibration, and laboratory quality assurance / quality
control activities.
Response:
We concur with the SALP assessment that: "Overall in-plant health physics was
a notable licensee strength. This is attributable to a sound program, a capable
staff, and supervisory excellence." The NRC inspectors observed that Radiation
Protection (RP) supervision were accessible to the RP staff and exhibited a
strong "in-the-fleid" presence. The comment that the RP group has not been
challenged during the period is not supported by the group's performance during
the July - August outage, the smooth transition from start-up into operation with
radiological controls, the exceptionally low overall exposure for the first year
commercial operation and the . aggressive program to maintain the plant free of
contamination.
In the area of radiological effluent monitoring the procedural inadequacies have
been corrected and improvements are ongoing.
There is a plan to improve the chemistry laboratory's radiochemical QA/QC
program by using the new AIF/ Industry cross-check program which will be under
way in late 1987, and to increase split samples with Connecticut Yankee and
other Millstone Units.
Water chemistry control is an area of continuing emphasis. The state-of-the-art
in water chemistry is continuously changing and has increased by orders of
magnitude since Millstone Unit No. 3 was originally designed. Several projects
have been generated to add on-line monitoring versus grab samples in different
areas or to upgrade existing in-line monitors. One example of this is the copper-
iron monitor cited in the analysis. The conceptual design of the modification is
complete. This project is currently in the construction estimation phase and a
plan for installation is under development.
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Functional Area:
MAINTENANCE
Board Recommendation: Assure thorough testing af ter maintenance.
Response:
. We agree with the SALP assessment of the maintenance program.
The
recommendation to assure thorough testing after maintenance will be
implemented by increased attentior. in the retest area.
The SALP Report cited the PORY leakage problem as an area where effective
maintenance was not timely. We would like to note that the perseverance of the
engineering and maintenance staffs produced an effective repair during the
March - April,1987 outage.
The PORVs have been in service since April 6
through two plant cooldowns with no indicated internal or external leakage.
There were two minor inaccuracies that should be corrected in the final SALP
Report. Paragraph two cited the rebuilding of two service water pumps based on
IST results as an example of ' effective preventive maintenance. It was only
necessary to rebuild one pump. Paragraph ten cited the correction of a "related"
problem when setting safety valve blowdown rings in response to an NRC
Information Notice.
The replacement of the short ring locking pins was
" unrelated" to the blowdown ring settings.
The report should be revised with respect to the licensee commitment cited to
implement full _ stroke testing of the Feed Regulating Valves {FRV) af ter packing
adjustment. It is not possible to full stroke test the FRV at power. It was our
intent to improve our FRV test method to more closely predict the full closure
capab;11ty based on a partial stroke test at power.
Overall we intend to continue improving our maintenance programs by revising
the preventive maintenance program based on actual operating experience,
continuing management involvement and promoting the team effort approach to
timely and effective maintenance.
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Functional Area:
SURVEILLANCE
Board Recommendation: Continue to emphasize procedure adequacy, and give
evaluation of procedure validation priority emphasis.
Response:
NNECO agrees with the SALP analysis that our surveillance procedures are very
detailed and form a solid basis from which to build a successful program. This is
an example of NNECO's commitment to do the right thing the first time, even
though this approach did result in the late development of sorne of the
procedures.
We have recognized the opportunity for improving our surveillance procedures.
Our initiative to complete the calculations to verify all reactor protection
system setpoints is one example. Currently, we have initiated an independent,
multi-discipline, detailed review of a surveillance procedure sampling to ensure
the
procedures incorporate all aspects of the Technical Specification
surveillance requirements.
In addition, the bulk of the refueling frequency surveillance procedures were
performed during the March - April snubber outage. Approximately 98% of our
surveillance procedures have been verified through at least one actual
performance. Management also continues to promote the attitude that each
procedure should be performed with the attitude that this is the first time the
procedure has been used.
Overall, our emphasis during the coming year will be to build on the solid base of
established procedures and to eliminate the deficiencies.
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Board Recommendation: None.
Response:
We offer no substantive comments and note that on page 23, paragraph 4,line 7,
the word "is" should be "in."
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Functional Area:
SECURITY AND SAFEGUARDS
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Board Recommendation: None.
Response: -
The necessary emphasis.will be given to ensure that high performance levels will
be maintained during the transitions when senior personnel retire.
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(1)
W. T. Russell letter to E. J. Mroczka, "SALP Report No. 50-213/86-99,"
dated June 10,1987.
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Functional Area:
OUTAGE MANAGEMENT
Board Recommendation: None.
Response:
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No comments.
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' Functional Area:
LICENSING ACTIVITIES
Board Recommendation: Assure accuracy of submittals to the NRC.
Response:
We have continually strived to provide comprehensive, accurate, and technically
sound submittals.
In cases where the NRC Staff has required additional
information, we have been quick to respond to the request with follow-up
telephone conference calls, meetings, or additional written submittals.
We recognize the importance of frequent communications with the NRC Project
Manager to ensure that NRC priorities are thoroughly understood. We intend to
continue the practices which resulted in the favorable comments in the Staff's
evaluation of this category.
Further, we will continue to place emphasis on the multidiscipline sign-off
process associated with all correspondence to the NRC to ensure accuracy of
submittals.
With respect to the Technical Specification change request pertaining to the
number of Nuclear Review Board (NRB) members necessary to reach a quorum,
we believe the NRC did not fully understand our approach to this issue. Recent
discussions with the NRC Staff have resulted in an improved understanding and
mutually agreeable proposed wording.
The proposed Technical Specification
change will be resubmitted soon and it is our expectation that we will receive a
favorable SER. We believe the SALP write-up should be clarified accordingly.
Another area which we believe requires clarification is the SALP write-up on N-
1 (three) loop operation.
We believe the NRC did not fully understand the
information provided.
A meeting was held between the Staff and NNECO
representatives in Bethesda, Maryland on July 7,1987 to discuss the Staff's
remaining concerns related to three-loop operation for Millstone Unit No. 3. At
the July 7,1987 meeting NNECO discussed the procedural steps to be used for a
transition from three-loop to four-loop operation and provided additional
~ information concerning the reactor coolant loop isolation valve interlocks and
accident analysis regarding startup of an inactive reactor coolant loop. The
Staf f indicated that their concerns were satisfactorily resolved and it was agreed
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that a subsequent submittal would be docketed to enable the Staff to write a
favorable safety evaluation.
In summary, we believe that the licensing activities associated with Millstone
Unit No. 3 continue to demonstrate that submittals to the NRC are accurate,
comprehensive, and technically sound.
Note that on page 30, the Licensing Activities functional area is noted to be "1"
and should be "H."
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Functional Area:
ENGINEERING SUPPORT
Board Recommendation: Resolve issues requiring engineering attention.
Response:
It was noted in the SALP Report that NU maintains an appropriately sized
Engineering staff on site in both NNECO and NUSCO. The presence of a NUSCO
staff on site has been advantageous. During the 18-month period covered by the
SALP Report, the combined efforts of NUSCO and NNECO Engineering have
resulted in the completion and installation of 100 PDCRs and an additional 77
where the PDCR is approved and either in progress or ready for installation.
The current status of st :eral specific issues is noted below.
1.
Steam Generator Feedwater Flow Oscillation
There has been an intensive effort to solve this issue in the past 18 months.
Numerous discussions and evaluations have been performed by Engineering,
I&C and Westinghouse personnel. As a result of these analyses work has
begun to replace the steam generator condensate pots, instrument tubing
and isolation valves. This change is presently scheduled to be installed
during the first ref jeling outage contingent upon timely delivery of the
isolation valves.
2.
Elimination Of Illumir ated Control Board Annunciators
A review of control board annunciators was performed in 1986. It was
proposed to modify the circuitry of 38 annunciators. To date,18 changes
were implemented and an additional 34 circuits are under review for
implementation.
Six were deleted as being adequate as presently
configured.
3.
Main Steam Valve Building Heating and Cooling
This has been an extremely complex issue as it involves both over heating
and over cooling of different parts of the main steam valve building and
Electrical Environmental Qualification (EEQ) area monitoring.
To date
five Plant Design Change Requests have been worked to correct these
problems; three of these are in the installation or testing phase, two are still
in the design phase with plans to implement one of them for EEQ
temperature monitoring this year. The other on steam drains and vents is a
long-term project and is being evaluated for implementation since it
involves core boring through Category I structures and extensive seismic
design and installation.
Overall, NNECO agrees with the statement that Engineering has a high
workload and has produced much competent work.
We will strive to
continue our progress toward timely implementation of engineering
improvements.
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Functional Area:
TRAINING AND QUALIFICATION EFFECTIVENESS
Board Recommendation: Continue training development to achieve accredited
training
and
assure
consistently
good
operator
examination results.
l
Response:
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Material development is ongoing to support the preparation of the INPO
l
Accreditation Self-Evaluation Report for the four operator training programs.
!
Current plans are to submit this report in October 1987. An INPO accreditation
[
team visit is anticipated in the first half of 1988.
l
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Functional Area:
ASSURANCE OF QUALITY
.
Board Recommendation: None.
Response:
The SALP Report stated that our audit response system was inadequate in that
some audit findings were left unresolved for as long as three years.
In a
telephone conversation on June 10, 1987, between NNECO and members of the
NRC Staff,it was agreed that the SALP Report should be reworded to state that
"some audit findings remained open due to an apparent lack of the availability of
verification audit documentation in the audit packages." This letter documents
that understanding.
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