View source for B11411, Discusses SALP for Facilities.Input to SALP Evaluation Process & Followup to Previous SALP Rept Actions Encl

{{Adams
| number = ML20128B295
| issue date = 03/22/1985
| title = Discusses SALP for Facilities.Input to SALP Evaluation Process & Followup to Previous SALP Rept Actions Encl
| author name = Counsil W
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Minners W, Rubenstein L, Starostecki R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I), NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000000, 05000213, 05000245, 05000336
| license number = 
| contact person = 
| document report number = B11411, NUDOCS 8505240473
| package number = ML20128B265
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 18
}}

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5 March 22,1985
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Docket Nos. 50-213                                        g 50-245                                      a 50-336                                       _
B11411                                      -
7 Mr. R. W. Starostecki, Director                                                                                 i SALP Board Chairman                                                                                            4 Division of Project and Resident Programs                                                                           d U. S. Nuclear Regulatory Commission                                                                             -i 631 Park Avenue                                                                                                 y King of Prussia, PA 19406                                                                                       a 2
Mr. Lester Rubenstein, Assistant Director                                                                       j Core and Plant Systems                                                                                          a Office of Nuclear Reactor Regulation                                                                            j U. S. Nuclear Regulatory Commission                                                                             j Washington, D. C. 20555                                                                                         4 5
Mr. Warren Minners, Chief                                                                                         g Safety Program Evaluation Branch                                                                                j Office of Nuclear Reactor Regulation                                                                            4 U. S. Nuclear Regulatory Commission                                                                                 :
Washington, D. C. 20555                                                                                            =
E Gentlemen:
Haddam Neck Plant, Millstone Nuclear Power Station Unit Nos. I and 2                                         d Systematic Appraisal of Licensee Performance                                             4 a
As you are no doubt aware from previous meetings with us regarding the SALP                                      ]
program, Northeast Utilities (NU) places high priority on achieving excellence in                               -
our endeavors. Category I ratings in all areas of activity evaluated by that                                    =
program would represent one signal that this goal is being realized. Our commitment to strive for Category I ratings originates from NU executive management and is one element of our primary corporate objective of striving                                     -
for excellence in the maintenance of nuclear safety. Given the scope and depth                                  -
of SALP reviews, achievement of superior ratings provides an indication that our management controls are functioning properly. Ratings lower than Category I                                        -
identify potential areas for improvement,                                                                        j In the past, SALP meetings have occurred subsequent to publicacion of the initial                                i NRC SALP report. As a result, we believe that the initial reports have at times                                  j failed to take into account pertinent information and otherwise could have been                                  i strengthened by an exchange between ourselves and the NRC. To minimize the                                       -,
chances of this situation recurring, we are taking this opportunity prior to the                                 -!
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convening of your;SALP Board for our three operating nuclear units to offer-isome of our perspectives on our level of performance during the past months.
                                     ~We believe that doing so may prove useful in your _ deliberations. We are
                                      ' addressing this document-to you in your respective capacities as lead SALP
_ participants (SALP Board . Chairman, or NRR Senior Executives) for our facilities. .
                                     . Generally, we 'believe ' that the .nine. functional areas in which the NRC has :
chosen to evaluate license performance will provide an overall perspective of our operations. However, an evaluation of these areas exclusively does not, in our opinion, comprise the universe of those factors which should be considered in .
assessing ." licensee performance." Perhaps the most significant factor which we believe should be considered and which is not reflected in the nine functional areas is the extent to which a licensee attempts to further the depth and quality
                                     ; of the exchange with the regulators, both _in terms of interacting with the NRC                                                                         ,
and participating actively in _ efforts . to disseminate needed information to 4
industry. NU has consistently adhered to the view that we are obliged to voice-our disagreement with NRC on any. issue involving public health and safety when                                              _
we believe such disagreement is justified. We do so_ in the interest.of further Improving .the' regulatory process and assuring that through discussion and debate, all aspects of a proposed action are understood and considered by both
:NRC and NU.~ We sense that on occasion this corporate philosophy may have disturbed certain: NRC reviewers. However, we do' not believe that this E
(. philosophy                should be counted against us in your SALP evaluation. - On the contrary, we believe~ it necessary and appropriate for us to vigorously interact with the Staff as necessary to ensure that public health and safety is maintained, particularly given the finite resources at the disposal of both NU and the NRC.
         ~'
Examples of = some. of our attempts to further improve the. quality of the regulatory process are enumerated in Attachment (1) to this letter. Many of them have their focus on providing the regulators with an opportunity to become
                                      .more familiar with our plants, procedures and personnel. They are far ranging in scope, involving executive management down through the working level. Our former Chief Executive Officer (CEO) is the current chairman of the board of the Institute of Nuclear Power Operations (INPO). Northeast Utilities executive management is extremely active in numerous industry initiatives, having made several presentations' at public meetings.before the Commission 'as well as meeting with individual Commissioners where appropriate. NU management                                                                                      ,
personnel are extremely ' active in, and in many instances chair, various industry .
groups which are addressing a broad range of nuclear issues.
Regarding . day-to-day activities, our licensing staff attempts to be very                                                                                  -
;                                      responsive to the NRC licensing project managers (LPMs). We attempt to respond to verbal inquiries quickly and accurately, arrange for all necessary meetings and/or conference calls, help the LPMs locate previously docketed
:                                    7 material, and provide express. mail service for both incoming and outgoing correspondence as circumstances require to ensure that priority issues are given
:                                      priority treatment.. We believe that the recent briefings conducted by the new NRR Division of Licensing Director support the above perspective.
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o Another element of our corporate efforts to achieve excellence which may not
      =be reflected in the nine functional categories NRC evaluates as part of SALP is the, extent to,which actions are implemented following a SALP evaluation in order to improve a licensee's level _of performance. Examples of these activities which have occurred since the most recent SALP report for our operating nuclear facilities are provided in Attachment (2) to this submittal. - Again, it is not all inclusive, but is illustrative of our commitment to strive for excellence.
      ;We note that this letter focuses; exclusively on those activities which we believe are relevant to the SALP process and which, based upon our knowledge of the process,' may not otherwise be fully ' considered. The fact that many other pertinent issues and documents are not discussed herein is not to suggest they are less important.
      ; We are aware that the 'NRC has developed procedures for the conduct of the
      .SALP process and has acquired considerable experience over the .last several yea'rs in performing.SALP_ evaluations. In the spirit of further improving the
        -process, we urge you to consider _ the areas of activity discussed above, as supplemented by the Attachments to this document. Further, we invite you to ask any questions which may arise during the conduct of the SALP evaluation for our facilities in the interest of eliminating points of confusion and enhancing the overall quality and' depth of the SALP evaluation process.
Feel free to contact us if any questions arise on this matter.
Very truly yours,
                                                . CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST. NUCLEAR ENERGY COMPANY
                                                . W. G. Counsil Senior Vice President cc:   T. E. Murley W. 3. Dircks V.' Stello, Jr.
H. R. Denton D. G. Eisenhut H. L. Thompson, 3r.
D. M. Crutchfield :
G. C. Lainas
: 3. A. Zwolinski
: 3. R. Miller i

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                                                             .- Docket Nos. 50-213 ~
50-245 50-336
                                                ' Attachment 1 Haddam' Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Inputs to SALP Evaluation Process
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L, March,1985
: o. ..
The following items provide a summary description of various meetings, letters, or other transactions which we believe are relevant to the conduct of the SALP
            ' process for our facilities. In the interest of brevity, only a summary of each of -
the pertinent _ elements is provided below. Further elaboration can be provided if
           .' desired by the NRC.
o       Early in 1984, the NRC published its Policy and Planning Guidance as
                     ' NUREG-0885. By letter dated February 2,_1984, we provided unsolicited -
                    - comments on this document. This submittal subsequently lead to a number of . meetings with the. EDO's . Staff regarding possible improvements in subsequent direction to the NRC Staff.
o-       On - March 23, 1984, we provided a letter to V. Stello Jr. regarding the proposed _ Senior Manager Rule.         We understand that senior staff management believed that this document . presented a worthwhile -
perspective different from that proposed by the Senior Manager Rule and as such, was forwarded to the Commission for their consideration. In November of 1984, the Commission disapproved the proposed rule.
o-     'In recognition of the importance to safety of reducing unscheduled plant trips, we have adopted corporate goals and initiatives to reduce unplanned
                     - trips and their subsequent challenges to safety systems. This program was discussed in summary fashion during a meeting with the CRGR in July of 1984.
o       The issue of environmental qualification is one for which it has proven.to
                    ~ be difficult to achieve closure. Given the long standing nature of the' issue and the turnover of both NRC staff and contractor personnel, we have periodically.provided to the staff a chronological listing of all documents
                    - exchanged between us and the NRC for each of our nuclear units. We have done ~so in the interest of facilitating the process by which the Staff can trace the basis-for closure of any individual aspect of the environmental qualification issue, o       At the request of a senior staff manager, a letter was sent to H. R. Denton on July 15, 1984 regarding the involvement of the Nuclear Utility Task Action Committee.(NUTAC) and its attempts to achieve resolution of the        'l SPDS issue.                                                                     !
            ~
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           'o       : At the request of H. R. Denton, we entertained a visit in June of 1984 by       <
the Environmental Programs Branch of the NRC to allow them to obtain additionalinformation regarding the quality of their work.
o       During the 1984 refueling outage at Millstone Unit No.1, we entertained a visit by NRC contractors from EG&G to allow them to collect information on the decontamination process utilized as part of remedial action associated with the IGSCC issue.
o       In August of 1984, representatives from Brookhaven National Labs, under contract with NRC, visited us to obtain information on implementation of our ALAR A programs, o         In October of 1983, we entertained personnel from the NRC and Battelle
                   . Pacific Northwest Laboratories regarding their interest in biofouling in raw water systems.
I

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of      The issue of the flooding at :the Haddam Neck Plant as' a result _of a
                            .Quabbin Reservoir dam failure consumed considerable resources within NU.
Numerous meetings were held involving the State of Connecticut, FEMA,-
NationalT Weather '= Service, and other organizations.          NU personnel coordinated several visits on the part of the Staff to ensure that all of
                            -their questions were answered satisfactorily.
o-       Severalidays 'before the' completion' of the 1984 refueling outage for .
                           - Millstone Unit No. J1, the staff telephoned us to request that we immediately provide a report of our IGSCC program and results of all inspections. Their original intention was to write an SER prior to startup.
While we. did not accept 'the~ verbal staff position that an SER was
                           ' necessary prior. to_ startup, all requested information was gathered and submitted promptly by {{letter dated|date=June 15, 1984|text=letter dated June 15,1984}}.
o        As part of the resolution of the hydrogen recombiner issue for inerted r
BWR's, the NRC issued Generic Letter 84-09. As a result of questions and '
inquiries from the BWR community regarding the applicability of previous
                           - Northeast Utilities work on this issue, we hosted a seminar in our corporate offices on June 15,'1984 to review our analyses and answer questions. This was done in the interest of furthering industry-wide resolution of this issue.
: o.      On July 17 and 18 'of 1984, we entertained a visit of the majority of the members of the Committee to Review Generic Requirements (CRGR).-
This visit involved discussions with numerous licensed personnel as well as
                           ' discussions with numerous levels of NU management. Significant resources were expended in the interest of further improving communications and-obtaining a better appreciation of our respective viewpoints.
E o     - Generic Letter 84-15 requested a considerable amount of information -
regarding diesel generator performance in the interest of resolving generic issue B-56. In- addition to this 'information, we ' included voluntarily information regarding the performance of the gas turbine at Millstone Unit
,                           No.1.
o,      On July 31,'1984, W. G. Counsil was one of several industry spokesmen who provided information to the commission.on the important-to-safety issue.
;        _                : At this meeting, Mr. Counsil represented the Utility Safety Classification .
,                           Group. This presentation ultimately led to a visit by four members of the,
,                           NRC~the following week at our Millstone facility to gather information on
- ,                         the' treatment of equipment and components not classified as safety _
related. It is our~ understanding that this information was utilized in the development of the subsequent draft generic letter regarding the ATWS -
rule.
o        In August of 1984, we entertained a visit on the part of several members of the NRC on the maintenance issue. This visit also consumed significant NU resources and was done in the interest of improving the then draft Staff Maintenance Program Plan.
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lo     In' September of 1984, Harold Denton and several other staff members of NRR visited the Haddam Neck site as part of the resolution of a Differing Professional Opinion on the fire protection issue.
o~    In light of the safety significance of the reactor cavity pool seal issue at the Haddam' Neck Plant, NU initiated, and remains in the process of implementing, broad corrective actions. While many of these actions'are-
                     " utility specific, we have attempted to share our view of the safety
                     - significance of-this issue throughout the industry. In October of 1984 we
                     , hosted a seminar in.our corporate offices in an attempt to explain the
                      ' details of the event,-its safety significance, and answer any questions.
Because of .short notice for. this meeting, a subsequent seminar was cohosted by Northeast Utilities and INPO on December 13, 1984. We believe this meeting was helpful in heightening industry awareness of the significance of this issue.
Regarding the Order Modifying License which was issued as a result of this tissue in December of 1984, our response was submitted to the NRC some two months . earlier than required. This action reflects our resolve' to address any potential safety issues swiftly and effectively.
o     One of _the elements of our corporate strategy regarding steam generators at Millstone Unit No. 2 concerns a chemical cleaning process planned to occur during the 1985 refueling outage. While this process is governed by
                                                                                    ~
the provisions _of 10 CFR 50.59 and as such no prior staff involvement is required, we voluntarily briefed the staff on December 5, 1984 in considerable detail regarding our planned process and its qualification. No' unanswered questions remained at the conclusion of this meeting.
o-  - At_ the request of the Staff in December of 1984, we agreed to have the Staff conduct a review of our plant specific emergency operating -
procedures as well as the procedures generation package from which the -
plant specific procedures are prepared. It is our unde.rstanding that this differs from the normal. process when only the procedures generation -
package is reviewed by the Staff.
o      As a representative from NUMARC, executive NU management worked with Senior Staff management and the Commission in the last quarter of 1984 and the first quarter of 1985 on the engineering expertise on shift
                      ' issue. Extensive efforts were devoted towards development of a mutually agreeable and workable policy statement.

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o   ' As part of an AIF. coordinated effort, NU executive management and other
                         . industry- executives' met .with several . Commissioners. Individually. in
: January,1985 to discuss approaches.to resolve several issues of importance to both the Commission and the industry. .
to . . ' In September of i 1984, - two . NU representatives participated in a Commission briefing,on the decommissioning issue. This briefing was intended to facilitate Commission' deliberations on a proposed rule on the subject, and familiarize them with the status of utility programs and State PUC activities dealing with decommissioning.
o     On - 3anuary 3, '1985, we were notified of an NRC. endorsed activity regarding the National Science Foundation PRA Peer Review Panel. Some
                        -.two weeks later, NU hosted the first two day meeting of this Panel. The
                         . meeting included tours of the Millstone Station and familiarization with 1PRA' applications at NU.

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:p, Docket Nos. 50-213 30-245 50-336
                                   . Attachment 2
    .                            Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Follow-up to Previous SALP Report Actions March,1985

        ;;; ;,    .x        .
Connecticut Yankee The NRC Systematic Assessment of Licensee Performance (SALP) report issued in October of 1983 gave the Haddam Neck Plant Category 1 ratings in all areas but.one. This one area was surveillance, in which Lthe Staff assigned a Category 2 rating. The Haddam Neck Plant's surveillance plan was broken into component parts and each component individually analyzed. These components and the plant's corrective actions are enumerated below. These component parts
               < cover all deficiencies identified in'Part 4.4 of the SALP report for the Haddam Neck Plant..-
               -COMPONENT:                              COMMENTS / ACTIONS
: 1) ' Data Base                       All Connecticut -Yankee (CY) department heads have updated their portion of -the data base    for     compliance .to. Technical Specifications. Additionally,' the Quality.-
Assurance _ Department, as required by procedure, has performed a complete data base- review.      The data base will be maintained on the computer program.
               ;2)       Timing Systems                Computerized systems have been expanded to include refueling, cold shutdown and all surveillances with frequencies less than a week. However, timing systems will only schedule any surveillance with - frequency greater than a week.        The computerized system is the official CY Date Base.
: 3)       Performance                   Since most surveillance fallings are improper performance, further . procedural guidance and training were needed.
CYSP-71 has been eliminated, and procedure       L QA 1.2-11.1 enhanced to pick up any items implemented by CYSP-71 but not covered in QA 1.2-11.1.
Guidance on actions to take with incorrect procedures,     procedure . corrections and compliance with procedures has been added        ,
                                                     ' to ACPs.
Using ACPs as source documents, CYAPCO has prepared departmental level instructions and provided training on the proper use of procedures.
4)' . Evaluations and Results          Format for surveillance procedure sign-offs is:

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2i Performed by                                          (Level I)
Approved by                                         (Level II or greater)
Reviewed by,                                       - (Level II or greater)
The " Approved by" must be Level II qualified
                                                                             ; as this is the point at which the surveillance
                                                                             ' is~ considered complete. The_ " Reviewed by"
                                                        .*.                    requires. a Level II : or greater, .. but : will s
t normally be a Level III.
The method of recording acceptance criteria on _' procedures has been - upgraded . for consistency and clarity and added to ACPs.
             ,                                                               . QA' - 1.2-11.2 has .been revised to include definitions of approved by and reviewed by.
Definition. of " performed by" was not
                                             ,                                 required, being obvious.
: 5) Corrective Action                             QA 1.2-11.2 has been revised to provide
   ,                                                                           guidance on acceptance criteria and need for Plant Incident Report (PIR) initiation.
: 6) Compliance Verification                     .Each department _ - head responsible .for surveillances                              has          provided -                      their superintendent a program for ' continuing surveillance compliance verification. Quality.
Assurance audits, NRC audits, etc., are not used as the key evaluation factors for compliance -- verification,-                                   unless                 major problems are found. _ Additionally, the I&C Surveillance Feedback Sheet which requests feedback _                from                   personnel                  performing' surveillances when a surveillance is Improper,-
incorrect or is difficult to use has been reviewed                  by                 each , department                               for' implementation as part of their departmental programs.
: 7) Records                                       The            computerized                        schedule                 has          been evaluated as a "living schedule" to replace the forwarding schedule.
Review .and                            approval            of surveillance procedures                  prior to a start-up is a departmental responsibility and is monitored,
;,                                                                             but results indicate no action is needed at this time.                                                                                                                                 ;
                           '8)   Miscellaneous                                 (1) A surveillance as defined in 10 CFR
[
50.36(c)(3) will mean only technical L                                                                                       specification commitments. Other items l                                  .
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can be on the computerized schedule and proceduralized but will not be a surveillance test. - Procedures will be r.
reformatted . to meet . this . definition during the ' normal biennial procedure review process. Scheduled completion of
        ,              all procedures is July 31,1986.
(2) A standard method . for acceptance criteria format has been developed.
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    ;~2             .
Millstone Unit No.1 The NRC Systematic Evaluation of Licensee Performance (SALP) report issued in October of 1983 gave Millstone Unit No._1 Category I ratings in all areas but
           - three. - The areas which received a Category 2 rating, the NRC concerns in these
          - areas and NNECO corrective actions are listed below:
: 1) ~ Plant Operations
                   - Concern:-
On. July. 20-21, 1983 a radioactive . liquid discharge was unintentionally made for 24 hours due to failure to secure flush water through an effluent radiation monitor.
Corrective Action:
All operations personnel, in addition to those directly involved with the incident, have been reminded of their responsibilities and the importance
                   -of following station procedures. Procedure changes have been made to eliminate ^ unnecessary flushes by specifying the condition for which flushing is required. Procedure changes have also been made to include dual valve verification for terminating the flush of the sample chamber.
Concern:
An incident in March 1983 involved incorrect valve line-ups for sensors in the Reactor Protection System. This problem was previously identified in 1981.
Corrective Action:
Methods were implemented to control safety-related instrument valves to prevent recurrence of incidents of this nature. Personnel involved with the calibration and adjustment of safety-related instruments have been
                  - reminded of. the importance of proper restoration . methods , when performing surveillance and maintenance. Surveillance data sheets were revised to include all valve numbers and dual check-off/ initial spaces for every valve manipulated during surveillance and calibration.
Concern:
i
!'                  The Emergency Gas Turbine Generator has been allowed to deteriorate to a point that, during the appraisal period, problems have occurred with the gas turbine and its controls and the generator voltage regulator.
Corrective Action:
Instrument folders have been established for the governor control units as well as the drytest/ analog troubleshooting instrumentation.           Key personnel monitor each gas turbine surveillance start and record selected gas turbine parameters. Maintenance was performed on the voltage

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L                1 regulator' during the recent refueling outage to replace defective parts and clean oxidation from contact surfaces. Installation of a dehumidifier for the voltage regulator cabinet precludes moisture intrusion.
: 2) : Surveillance Concern:
Surveillance ~ procedures had not been revised to include an independent
: verification of system restoration.
Corrective Action:
Surveillance procedures were . reviewed and modified as necessary to include an independent check for. system restoration. Also, surveillance data sheets were revised to include all valve numbers and dual check ~
off/ initial spaces for every valve manipulated during surveillances and calibration.
: 3) - Emergency Preparedness Concern:
Installation of the High-RangelMonitoring and Sampling Systems for the Unit I stack and the Unit 2 vent was not completed.
Corrective Action:
                 - Both monitors have been redesigned to allow prener calibration, and are    -
                                                                                                ?
operational and in service at this time.
Concern:
Lesson' plans for training of each functional area of the emergency response organization were lacking.
Corrective Action:                                                        -
The Training Department individual dedicated to emergency plan training has developed lesson plans and is currently conducting training sessions.
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Millstone Unit No. 2 4                   ,
            ^
The NRC Systematic' Evaluation of Licensee Performance (SALP) report issued-
                   =in October of 1983 gave Millstone Unit No. 2 Category I ratings in all areas but three. These three areas received a Category 2 rating. NRC concerna in these -
                   ' areas and corrective actions taken by NNECO are listed below. -
iPlant Operations
                        - 1)' ~ Concern:
                                                 ~
LAn aggressive program 1for improvement was not' evident in the on-site -
safety committee's . performance. The licensee, through :the safety cornmittee does .not effectively task all ' personnel,. organizations and -
contractors.
              - _                Corrective Action:
The PORC review process was studied and changes implementsd. Major changes were an expansion of the PDCR review process, prior review of major procedure revisions and new procedures, better definition of the use
                               - of ,' subcommittees,' and' responsibilities . review during annual _PORC training. ' Particulars of the expansion of the PDCR process are a more detailed line revie~w of the PDCR before being submitted to PORC,' prior to review by 'PORC members and more detailed. presentations for the complex changes. In addition to the . review' of the PORC process, corporate-wide changes have been instituted to more clearly define safety .
                               . evaluation requirements and these improvements are being monitored by.
                               - P O R C .;
: 32)       Concern:
                               -In two instances important equipment was out of service for an extended period of time before operations personnel identified the condition. ' The two pieces of-equipment involved were the process computer and the radiation monitor recorder.
                              - Corrective Action:
Concerning the . failure - to identify the unoperability of the process
                              - computer, an alarm which would have indicated a computer failure was
                               ' inoperative at the time of the computer. failure. This alarm has been returned to service and will be maintained operable. The replacement computer, scheduled for 1986, has full alarm capabilities,for partial or total failures. . To1 prevent a recurrence of this type, control room operators and licensed superviscry personnel have been briefed on the need to frequently monitor computer displays for up-to-date information and how to determine operability status. A logging requirement has been
                               ' incorporated to ensure verification of computer updating. The licensed operators were reminded of the importance of newly licensed personnel tsing a questioning approach to off-normal situations and getting more experienced personnel involved in the investigation as soon as the condition is noted.

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With - respectEtof the1 failure of the- radiation ~ monitor < recorder, the
                                         . Operations DepartmenttStaff havef been instructed and reminded to monitor; key; Control Room instruments for abnormalities and indications -
       ~
Lof unusual conditions.: In order to ensure that:: activity :is properly
: monitored in accordance with Technical Specifications, the activity levels -   !
                                          'being discharged through aerated and clean waste systems is displayed on
                                        ' a second redundant recorder which.is' on panel C04. This is recorded-in
                                         - view of the reactor operator at his normal station and could be used as a
,.                               a: - back-up if the multi-point recorder were to fail in the future. .
I 3' )f Concern: .
On two occasions the unit'was operated at a power level exceeding that permitted b'y Technical Specifications for the method of' monitoring fuel
                                         ' rod linear heat rate then in use. One instance involved the loss of the
                                         . computer discussed above.and the.second a-failure to adequately review
                                         . the results of an INCA print out.
Corrective Action:
Refer to item (2) for actions resultant from the March 26, 1983 incident.
                                        - Concerning. the November 4 event, unit engineering procedures were
                                         . revised to require verification that the INCA values are consistent with
                                         - the reactor power level and the reactor engineer provided training for his personnel in this process.
: 4)       Concern: -
A series of unplanned or unauthorized releases of radioactive materials on September 16, September 24.and December 28,1982 and' 3anuary 20, 1983, involved common management and personnel errors, particularly
                                         .-lapses in attention to detail and -in first and -second. line management following evolutions. Included were .the discharge' of -the wrong tank          .
discharge on a continuous vice.a batch basis, radiation monitor recorder failure during. a discharge and improper valve line-ups. Subsequent performance suggests. that corrective actions were applied piecemeal, conducted informally and without decisiveness and resulted in-little effect.
Corrective Actions:                                                              ,
                                         -The referenced unplanned or unauthorized radioactive releases have resulted.in numerous corrective actions;>the most significant are listed below.
(a) Procedure changes to ensure the procedures are accurate and easy-to understand and use for the plant equipment operators have been
                                                   . implemented.
                                             - (b) . Instructions to operating personnel have been issued to ensure they     l understand the importance and significance of - the events and           1
                                                   -necessary corrective actions.
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(c) Requirements to have a second radwaste qualified operator verify             l procedure steps for all radioactive discharges in addition to dual         1 verification of valve line-ups for discharges have been' established. -
                                 .-(d) Operations personnel in Unit 2 have been cautioned to critically review all discharges with respect to possible contamination. The          ;
sensitivity.of any unplanned radicactive discharge, no matter how slight,~ dictates that stringent controls be used.                -
(e) Availability of controlled procedures to radwaste operators has been improved.'
(f} ' Hardware changesj have been accomplished which more clearly identify valves and contr'ols which must be manipulated for-radwaste contiol.
(g) Lastly, an independent review of all Radioactive Waste Operating Procedures and interface procedures (chemistry) was conducted by La Unit 2 senior reactor operator who had not been responsible for-procedural review for radwaste. This review was conducted to ensure usability and compatibility with all other procedures.
Changes from this review were reviewed and implemented.'
: 5) . . Concern:
The quality of services depends greatly on the abilities of the contractor as illustrated by the success of the steam generator sleeving task and the           7 difficulties with.the nozzle' dam installation.
Corrective Action:
NNECO agrees that the quality of the service is dependent on the quality of _the vendor. Therefore, Unit 2 continues to evaluatef all projects performed by~ vendors. . This evaluation is utilized during future vendor selections. Concerning the nozzle dam project, modifications performed on the dams and direct NNECO control of the evaluations resolved the problems with the installation. The 1985 effort was accomplished in' a
                            . timely manner.
: 6)     Concern:
The licensee has not been effective in dealing with the fuel vendor.
Corrective Action:                                                                   l NUSCO Engineering is in discussion with the fuel vendor to resolve the manufacturing and design problems.                 Extensive examinations were completed by NNECO, NUSCO and the vendor to identify the failed rods and potential failure mechanisms. A likely mechanism is debris from the thermal shield removal and other primary work. A stringent material inventory control system has been initiated for this refuel to prevent further failures. In addition a full core off-load and fuel sipping is being
           ~
l c
: e. a 4
accomplished during the 1985 refueling outage to improve fuel performance for the next operating cycle. The above efforts complement the fuel reconstitution effort which was completed last fall and which was presented to the NRC in a meeting in NRC Bethesda offices on October 3,1984.
: 8)   Concern:
The Safety Committee, PORC, conducts most reviews through subcommittees rather than having all members perform the review. This has resulted in a decrease in committee effectiveness in some of its review work.
Corrective Action:
See item 1, corrective action.
: 9)    Concern:
A breach of a vital area security boundary was made in the course of a planned facility modification.
Corrective Action:
The breach of the security barrier was a failure of a portion of the PDCR process. A task force on PDCRs has presented recommendations and the recommendations have been implemented. Among these im xovements is a greater consistency during PDCR generation. This and the increased PORC review identified in item I will help prevent future deficiencies of all types from occurring during plant design changes.
Emergency Preparedness See Item 3 for Millstone Unit No.1.
Licensir.g Activities We did not agree with the Category 2 rating in this functional area, for reasons stated in the {{letter dated|date=December 19, 1983|text=December 19, 1983 letter}} to R. W. Starostecki. Accordingly, no significant corrective actions were implemented. It is re-emphasized that the principles and concepts behind our licensing activities for Millstone Unit No. 2 are identical to those applied to the Haddam Neck Plant and Millstone Unit No.1, which were given a Category I rating for this assessment interval.
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