View source for B12312, Forwards Responses & Comments on Findings of SALP Board W/ Particular Emphasis on Board Recommendations for Individual Evaluation Categories.Extension to 861105 for Ltr Submittal Granted Per 861103 Telcon

{{Adams
| number = ML20213D129
| issue date = 11/05/1986
| title = Forwards Responses & Comments on Findings of SALP Board W/ Particular Emphasis on Board Recommendations for Individual Evaluation Categories.Extension to 861105 for Ltr Submittal Granted Per 861103 Telcon
| author name = Opeka J, Sears C
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Murley T
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000245, 05000336
| license number = 
| contact person = 
| document report number = B12312, NUDOCS 8611100434
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 44
}}

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                ""'****''''"'***"                                         HARTFORD, CONNECTICUT 06141-0270 L    L   J  7,Z [,22,"c.,,",                                          (203) 665-5000 98 November 5,1986 Docket Nos. 50-245 50-336 B12312 Dr. Thomas E. Murley, Regional Administrator Region I U. S. Nuclear Regulatot y Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:
Millstone Nuclear Power Station, Unit Nos. I and 2 Systematic Assessment of Licensee Performance The Staff recently forwarded the SALP Board Reports (l) for the 15-month period ending May 31, 1986, for Millstone Unit Nos. I and 2. Subsequent to receipt of the SALP Board Reports, a meeting was held on October 2,1986 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. I and Millstone Unit No. 2 are contained in Attachments A and B, respectively, to this letter. This response was due to be submitted on November 3,1986. In a telephone conversation with a member of your staff on November 3,1986, NNECO was granted an extension to November 5,1986, for the submittal of 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 October 2,   1986 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 ratings in all functional areas for subsequent SALP evaluations, and the attachments to this letter describe some of the steps we will be taking to fulfill that objective, 8611100434 861105 PDR    ADOCK 05000245                             %.
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l l ''            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. We will be updating you regarding the status of implementing the l               corrective actions discussed herein prior to the next SALP evaluation.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
                                                                     .k.O J.F. Opeka '
Senior Vice President By: C.F. Sears Vice President i
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Docket No. 50-245 Attachment A Northeast Nuclear Energy Company Millstone Unit No.1 Response to SALP Report November,1986
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Functional A~rea: PLANT OPERATIONS Board Recommendation: None.

===Response===
The report states that weaknesses were noted in the " correction of Isolation Condenser valve motor-operator problems." We suggest that the term ." motor-operator" be deleted since the problem was with the valve itself and not the motor-operator.
We will continue to evaluate the need for a full-time onsite fire protection coordinator, as was suggested in the report.
The report mentions .various weaknesses identified in LER preparation. We are in the process of reviewing NRC's report from AEOD on this issue dated July 21, 1986. This is the first formal feedback from the NRC on Millstone LERs.
Identified weaknesses will be addressed.
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A-2 T Functional Area: RADIOLOGICAL CONTROLS
                                 - Board ' Recommendation: Improve . radiation . worker training to stress worker' awareness of and -compliance with Health Physics procedures.                                 Improve the effectiveness of the -ALARA program. Strengthen assurance of quality in the transportation area.

===Response===
This functional area. contained numerous criticisms, the majority of which we agree with. The SALP Board recommendations identified three major areas of concern, namely radiation worker training, effectiveness of the ALARA pro-gram, and assurance of quality in the transportation area. As a result of the difficulties experienced in this area, NU has initiated changes to the.
occupational radiation exposure controls program, the ALARA program, and the  .
radioactive waste management program.
The radiation exposure controls program changes being made are in both the L                                ' training and accountability areas. Radia.lon worker training is administered as a part of our General Employee Training. Tc , training of all radiation workers at
                                ' NU, is modified annually to include lessons learned from the previous year, as well as NRC/INPO and NU significant findings from the previous year. Since most of our radiation workers, including contractors, have previously worked at                                                      '
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* r A-3 our facilities and received such training, it. is expected that these annual reinforcements will heighten the awareness of these individuals in this area. NU also believes that supervisors are a key ingredient.in assuring radiation worker protection. Accordingly, we have reminded supervisors of their responsibility to
                                       ~
be fully cognizant of the tasks that they assign to their employees and contractors. This includes providing all the tools, equipment, knowledge and controls, such that these individuals can complete their tasks safely, efficiently and in a high qual'i ty manner.
To provide the impetus to ensure that training and supervisory reinforcement are effective, a program to monitor and enforce radiological practices will be developed and implemented by March 1,1987.
Regarding the Exposure Reduction and ALARA program, NU has recently initiated a number.of further actions in an attempt to lower collective exposures to levels consistent with INPO goals.
Our efforts regarding Exposure Reduction Initiatives have been continuing and are expected to yield paybacks in person-rem reduction. They include methods to reduce dose rates and work scope, and improve worker efficiency. These initiatives are currently receiving a multidiscipline (engineering, construction, operations and ALARA-involving home office and site personnel) review for prioritization and incorporation into the short-term (1 to 2 years) and long-term (2 to 5 years) goals program.

A-4 It should be noted that, over the past few years, Millstone Unit No. I has been among the best domestic BWRs in regard to total occupational exposure.
      .The radioactive waste management program has received considerable attention since the formation of a special committee to review -the entire radwaste program. The results of that committee's. efforts have led to the following changes:
o                The on-site radwaste handling group is being reorganized to provide a dedicated, permanent staff with greater resources for implementation of the program. The supervisory position was upgraded to attract and retain a more skilled individual. Assistant supervisor and station technician posi-tions were created to assist with program administration. The authorized working staff was doubled to reduce the number of contractors involved with radwaste activities. It is expected that this organization will be fully implemented and staffed by the end of 1986.
o                 The training of radwaste handling and quality control personnel to increase their knowledge of radwaste manifest preparation, shipping and burial regulations is continuing. Radwaste supervisory personnel have attended, or are scheduled to attend, a training program in shipping preparations, classifications and burial regulations offered by Chem-Nuclear.                          The program includes a trip to the Barnwell, South Carolina facility aimed at increasing the supervisors' awareness of radwaste shipment from the receiver's perspective.
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     'e     i A-5 o:       NEO Procedure 6.07, " Quality- Assurance and Quality Control in Station-l                        Radioactive Material Processing, Classification, Packaging, and Transpor-tation," defining quality aspects of the radwaste shipping process, has been
                       . issued.        Implementation of this procedure has resulted. in meaningful Lquality checks of the entire shipping process.
o        Reactivation of the' Radwaste Review Committee with an expanded charter which includes transportation issues has occurred.
o        increased attention by the quality organization through additional audits and surveillances will be utilized to ensure the effectiveness of the l                        proposed ' corrective actions.
               -o        A proposal for the formation of a dedicated home office engineering staff l
to address broad radwaste issues such as volume reduction, burial alloca-tion, radwaste system engineering, decontamination and decommissioning has recently been approved for implementation in 1987.
It is our expectation that these significant forward steps will resolve the difficulties we have experienced in the radiological controls area.
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s o A-6 Functional Areat MAINTENANCE AND MODIFICATIONS Board Recommendations: None.

===Response===
We believe that the SALP Report in several limited respects does not accurately
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reflect Millstone Unit No. I performance in this functional area. In the summary of this section, the report states that "much outstanding maintenance work was noted and the environmental qualification program was well implemented, but there were significant problems with the scram solenoid pilot valves, .with the emergency gas turbine generator, and with the main turbine mechanical pressure regulator. These indicate a need to more effectively assure that aging and/or obsolescent equipment is replaced and, where appropriate, redesigned so as to minimize the effect upon and challenges to . safety systems."           Additional
,       information regarding each of these three items is provided below:
: 1. Scram Solenoid Pilot Valve Rework During the 1985 Refueling Outage, 45 scram solenoid pilot valves were reworked. The valves were selected as part of our continuing program to replace Buna-N material. This has been a routine maintenance and upgrade activity during recent refueling outages. During control rod scram testing
 .             following the outage, which also served as a retest for the rebuilt solenoid i             valves, three valve failures were experienced. Two of these valves had       l 1
been rebuilt during the outage. The SALP Report considers inadequate I

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j                             testing of the valves after rework and before power operation to be a prime factor in these failures.
Contrary to this conclusion, adequate retest was a serious concern and was discussed at length prior to performing the work. Since valve performance affects control rod scram times, selection of the valves to be rebuilt, in addition to other factors, was made based on the ability to perform scram timing on those valves af ter the outage (by June,1986) without signifi-cantly impacting plant capacity factor or introducing a possibility of challenges to safety systems.       In-place retests cannot be adequately performed during the outage. because of the potential for subsequent control rod drive seal damage that could occur when the reactor vessel is not pressurized.
It was noted in the SALP Report that " discussions with maintenance personnel revealed a high level of knowledge about current maintenance activities. This included the scram solenoid rework effort. . . ". Again, this comment recognizes the planning and attention to detail that went into overall performance of this task.
The SALP Report also references our commitment to rebuild the remaining solenoid valves by June, 1986.        In the context of the report, this commitment is presented as being an NRC mandate due to our rework schedule not being timely. Contrary to the above, it should be noted that this commitment was our initiative based on what we believed to be timely completion of a rework program.

A-3 In conclusion, we do not believe that the SALP summary reflects a true understanding of our performance of this task, nor does it present a valid conclusion in identifying our program as a significant problem. It should in no way serve to lessen the SALP rating in this category. Instead, it should serve as an example of our ability to effectively plan and carry out maintenance activities, to react to unexpected conditions encountered during performance of these activities, and to plan and perform appropri-ate corrective measures.
: 2. Gas Turbine Performance On November 27, 1985, the Gas Turbine received a start signal and failed to start. Investigation revealed that the Gas Turbine tripped on high exhaust temperature. The " root cause" of this event was a failure of the Air Start Regulator Valve. This valve had just been installed prior to the failure. The valve that failed had been rebuilt by the manufacturer and all associated Q.A. documentation was in order. This valve was installed in response to an SEP commitment to the NRC to replace governor controls on a routine basis.
On January 13, 1986, while performing an operational readiness demonstra-tion af ter maintenance but before declaring the Gas Turbine operable, the Gas Turbine failed to start.                                                                                        Prello.!wy information indicates that the event was due to a fault in the Electric Governor Regulator. This Electric Governor Regulator had been installed on January 8,1986 as a result of a preventative maintenance program. All Q.A. documentation was in order,

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                                                                    'A-9
.          - r and the testing of the Gas Turbine was the re-test for the EGR replace-ment.
1 It is apparent that the 'two Gas Turbine failures were not due to our -
                               ' inability to replace' aging equipment. The second failure was caused by and 1
detected during the retest following a routine 'changeout of a governor -
component. These failures should not even be included in this report, since the failures were attributable to the replacement components which were                                           i i
j                                 Installed to preclude unanticipated failures.
Credit for proper routine maintenance efforts should be given.. An example i
                                 .of such' an effort was the re-adjustment of the Servo-limiter that was
;                                 performed on. August 21, 1986.         .However, maintenance ' and routine activities, "which may have . prevented . a failure," are very hard to l
document and thus hard to credit.
i The SALP Report states that our " procedures, training, trending of
;                                  equipment characteristics, and management overview have been increased, r
j but these actions were primarily responsive ones." We recognize that there l                                  have been problems related to the Gas Turbine Generator. In the past, and i
especially since 1982, we have made continuous changes in our procedures
!                                  and programs to increase the reliability of the machine. We have been very successful in this effort, as can be seen from system performance improvement. Further experienced-based improvements to our programs are being made, but to say that these actions are solely responsive ones is l
$                                  both inaccurate and invalid. Instead, they demonstrate our ability to
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A-10 develop effective monitoring and maintenance -programs, to implement these programs, and to make changes to these programs based on new data and operational experience. It should be recognized also that, since this system is unique to Millstone Unit No.1, we are developing our programs based on Millstone Unit No. I experience only, rather than from an industry
       . data base. Under these conditions, more frequent program changes and longer program development times are expected. We believe that our actions related to the Gas Turbine Generator have been both effective and justified, and therefore do not provide reason for lessening the SALP rating in this category.
: 3. Mechanical Pressure Regulator Performance On February 5,1986, the Mechanical Pressure Regulator (MPR) System failed, causing a pressure oscillation resultin6i n a reactor scram. Mainte-nance, which included planned replacement of the sensing bellows gasket and the inspection of a snubber valve, had been performed on the MPR during our recent 1985 refueling outage. During this refuel outage, the snubber valve was found to have some slight contamination and was cleaned. Following the reactor scram, the MPR was adjusted, tested, and returned to service. Additional work on the MPR was scheduled for the next outage.
On May 21, 1986, while shutting down for a planned turbine rotor inspection, a manual scram was initiated when reactor pressure began to oscillate due to the malfunction of the MPR. Operator initiation of a

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manual scram was a conservative . response by the operator to this
            . situation. Planned maintenance was again performed on the MPR, which -
i included an inspection of the snubber valve as well as modifications to the
!            rate adjustments. :The snubber valve had been clogged with a foreign substance. - The valve was cleaned and returned to service. The MPR was adjusted,. tested, and returned ' to service. ' As an added . preventative measure, the snubber valve was scheduled for replacement.
i l             On August 28, 1986, the snubber valve was replaced. The valve that was removed was once again clogged. Further investigation revealed that the nickel plating had been worn off the valve. This most likely is the result of
             ^ steam passing through the valve when the MPR had a faulty gasket. The valve had not-been replaced earlier due to long lead times in obtaining spare parts. Future inspections and preventative maintenance of the new I'            _ valve are planned to preclude future misoperation due to internal clogging.
o'f the component. An investigation' into the source of the clogging is continuing. We are confident that the root cause is not associated with aging components.
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l              The attention given to this system has been greatly increased over the past several years. We are presently in a transition state, going from what once was complete vendor support to an in-house maintenance program for this system. In all cases, we have utilized experts from various manufacturers f              and have followed their maintenance recommendations. It should be noted I
here that actions taken to date have resulted in a marked improvement in MPR operation. We believe that we will now begin to see a system
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                                                                                               < o ty                             challenges To"&fity5 systems.. MPR performance is not related to an
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                          .             ' not serve to lessar?ttie SALP rating in this area.
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* SUnic examples of these programs are listed below.                                                                . ,
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1                                    Reactor Recirculation System a
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A.                 Recirculation Speed Control components were replaced.
s u                     , 11,7                   The installation of,a new type of Motor Generator Field Brush with' s                    .,,             significantly longer.- operating life ' to minimize brush wear 'was                                                              ,
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                             .                ' t..               A program to test the, Motor Generator is ongoing.
                                               .D.                A.new Motor Generator Fleid was procured.
E,               The exikting Motor Generator Field was re-built.
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Feedwat'er and Drains System A. Heater Bay Positioner upgrades to improve performance and reliabil-1 ity have been completed.                                                '
B. Periodic Feedwater Control Valves Positioner changeouts are ongoing.
C. The installation of additional Feedwater Flow Transmitters to im-prove plant monitoring capability has been completed.
D. The installation of new Reactor Level Transmitters has been com-pleted.
E. The installatior, of new Reactor Pressure Transmitters has been completed.
F. A program to replace Feedwater Control System components is ongoing.
G. Routine performance checks of the following are ongoing:
1
: 1) Feedwater Control Valves and their lock-ups
: 2) Moisture Separator Drain System
: 3) Feedwater Heater Controls.
Gas Turbine Generator A. Gas Turbin'e Regulator components have been replaced to improve reliability.
B. A dehumidifier was installed in the regulator compartment to prevent corrosion damage to regulator components.
C. The Gas Turbine batteries were replaced.
1

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i A-14 D.         The Gas Turbine Generator Rotor was replaced when inspection revealed possible insulation problems.
Electrical Systems
[                         A.         Routine checks of the Main Generator Regulator are ongoing.
B.         Routin'e checks of the station transformers to monitor performance
                     ;                   are ongoing.           ,
C.        . Routine checks of the 4160 volt motors are ongoing.
i j                              D.        The calibration of all protective relays is ongoing.                   l
        .-                    E..        A program to calibrate station time delay relays has been instituted.
I t                F.         The station 125V batteries have been replaced.
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t       G.g ~ The Neutron Monitoring System batteries have been replaced.
3 H.t All solenoids on the Main Turbine have been replaced.
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           ,                   !.         Contact. Integrity tests of pressure switches are ongoing.
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A.         A balance of plant vibration monitoring program was initiated for all i
rotatsg plant' equipment.
B.         Improvements to plant air systems to minimize potential for cross-contamination of .olant components were implemented.
                                               \
C.         Improved condenser leak detection methods to reduce personnel
                                         ' radiation exposure and minimize plant capacity factor impact have
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A-15 ~
             . D. A Service Water System inspections program to improve reliability has been implemented.
E. The Service Water Strainer isolation valves were replaced.                                                             1 F. The screen wash strainer body was replaced and the internals were -                                                    l coated to increase component lifetime.                                                                                 ,
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I This list is incomplete, but is representative of the type of program development
                                                                                                                       ~
and plant improvements that are being implemented at Millstone Unit No.1.
Based on them and on similar programs like them, we believe they should provide                                   .
a highly favorable impact on the overall SALP rating in'this category.
: Based on our review of the SALP Report and our perception of our performance, l       we have not. identified a basis' for an overall rating of Category 2 in the area of f
Maintenance and Modifications. It appears that the NRC assessment of Items 1, 2 a'nd 3 above could be altered based upon the informatiori' contained in this letter. We believe that the Millstone Unit No. I rating for this functional area should be Category 1.
It should also be noted here that Millstone Unit No. I completed 374 days of
      . continuous power operation during the assessment period.                                                         Our success in implementing successful maintenance and modification-related tasks is directly reflected in this accomplishment.      As plants get older, it is expected that attention to detail in planning and performance of component maintenance must increase. Our operating accomplishments, capacity factor and availability demonstrate our success in these areas. The capacity factor for Millstone Unit No. I was 81.2% for this SALP period (93.4% capacity factor not counting
: s. ,
A-16
          ' refueling period). This compares favorably with the average capacity factor for   l US BWRs during 1985, which was 54.3E(1) The forced outage rate for Millstone
          ~ Unit No. I was very low, namely,1.7%, while the rest of the industry averaged F
11.9 (1)  " Operating Units Status Report," dated January,1986.
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A-17 Functional Area: SURVEILLANCE Board Recommendation: None.

===Response===
No comments.
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A-18 Functional Areat EMERGENCY PREPAREDNESS Board Recommendation: Reassess effectiveness of commitment tracking sys-tem.
       . Response:
There was no discussion in the SALP report relating to this recommendation.
However, it should be pointed out that a comprehensive commitment follow system is used for all drill and exercise critique. findings. This is periodically updated. In addition, there are' emergency preparedness (EP) surveillance tracking systems to ensure tha't periodic emergency facility and equipment tests are accomplished. A station Administrative Control Procedure will be effective in November,1986 to formalize this EP surveillance system. We suggest that the NRC review the above systems at'a future date.
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s A-19 Functional Areas. SECORITY AND SAFEGUARDS'-
i-Board Recommendation: None.
Response:                                                                                                                                                                              ,
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A-20
: Functional Area REFUELING AND. OUTAGE MANAGEMENT Board Recommendation: None.

===Response===
            -This section of the SALP Report reflects what we believe to be'an accurate representation of our performance during the 1985 Refueling Outage. No rating was giv'en 'due to what the inspectors determined to be insufficient time for performing an accurate evaluation.
As noted in the SALP Report, significant activities were performed during the period from October 25, 1985 to December 23, 1985. These activities included weld overlay repair of the jet pump instrumentation vessel nozzles and isolation condenser steam supply lines, replacement of safety-related valve motor oper-ators with environmentally qualified units and the replacement of the emergency gas turbine generator rotor.- Not mentioned in the report, but considered by us to be significant in nature, was cleaning of the recirculation pump MG set fields.
            -This task was planned based on trending of component performance, and demonstrates our ability to anticipate and correct situations that, if left unattended, could result in signicant losses in unit availability and capacity factor. All major activities were completed with .no significant problems, as noted in the report, due to planning and good communication during performance of the work.
I

A-21 The report also makes mention of our on-line management decisions that were instrumental in effective implementation of piping repair activities.           These
        . activities ' occurred without major impact on the outage duration because we
           ' anticipated the piping problems and planned accordingly.
Although 32 hours of inspection time represents only 2% of the total inspection time that was expended to assess our performance, we believe~it to be sufficient in providing a rating in an area in which every aspect of our performance was found to be outstanding. . If more inspection time would have been available, we believe that it would only strengthen the assessment made in the report.
Additionally, because of the manner'in which refueling and outage management data are presented to inspectors (e.g., published reports, daily updated schedules and log books, etc.), assessments made in this area are not expected to require the same number of inspection hours as would be required in other areas. Not providing a rating for a functional area where we believe a Category I rating is deserved sends a negative signal to Millstone Unit No.1 personnel involved in
           - this area. We would request that a rating be provided based on the inspection performed. We firmly believe the correct rating is Category 1.
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A-22
         ' Functional Area: ASSURANCE OF QUALITY l
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         . Board Recommendation: None.
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===Response===
i This functional area is a synopsis of the assessments in the other nine areas. The -
responses for the other functional areas address specific actions.which are b'eing taken to minimize and/or eliminate problems in those areas.
j-         As stated in our response to Maintenance and Modifications, we believe that we
         ' have good programs . to assure quality performance of aging equipment and adequate post-maintenance testing. As is stated in our responses to both the Radiological Controls and the Training and' Qualification Effectiveness .func-l-         tional areas, we are taking significant measures to improve werker adherence to and endorsement of routine radiation protection controls. We will continue to take measures to improve our assurance of quality in all areas.'

A-23 Functional Area TRAINING AND QUALIFICATION EFFECTIVENESS Board Recommendation: None.

===Response===
Since the end of this SALP period, four of ten training programs have been accredited by INPO. The four operator training programs, for non-licensed operators, . reactor operators, senior reactor operators and shift technical ad-visors, received accredit'ation from INPO on August 21, 1986. On October 1, 1986, the Self-Evaluation Reports for the remaining six training programs were submitted to INPO. INPO reviews and site accreditation visits for these six programs are not expected to be completed until well into 1987. Although not
                   ~
yet accredited, these training programs are already in place, with most of.the lesson plans complete. Including all four nuclear units at NU,1533 training programs are scheduled for 1987.
The Nuclear Training Department undertook a major reorganization during the SALP period to meet the corporate goal of " training excellence." The training staff (which has tripled since 1984) is committed and dedicated to the develop-ment and delivery of superior quality training in all operator and technical disciplines. We expect these efforts to result in performance-based improve-ments of the job incumbents. Some of the changes that have been implemented to re-orient operator and technical training include:

A-24 (1)  Installation of the Millstone Unit No. I Simulator
: o. On-site reverification testing was completed in May,1986.
o     Availability of the simulator has resulted in significant enhancements to Licensed Operator Training Program-and provided opportunities to support other station activities, o      Since July,~ 1986, the simulator has been used to support the Licensed Operator Requalification Program. It is anticipated that the simu-lator will be used to support approximately 50 percent of licensed.
operator requalification training in future yea'rs.
o      The simulator has been integrated into both Reactor Operator and       ,
Senior Reactor Operator Initial Training Programs. The simulator portions of these programs, each consisting of approximately 200 hours, began on September 29, 1986, and is currently ongoing. A Senior Reactor Operator upgrade class is currently scheduled to begin
                .approximately February 2,1987.
(2)  I&C Technician Understanding of Technical Specifications o      The Instrument and Controls (I&C) instructional staff prepared and delivered in May, 1986, a - four hour presentation of Technical specifications to 10096 of the Millstone Unit No. I and 2 I&C Department's Technician staf f.
I

a ,
A-25
    .(3) ' Radwaste Transportation and Han'dling As was stated in our response (2) to Combined Inspection No. 50-245/86-06, 50-336/86-06, and 50-213/86-04, several corrective steps to avoid radwaste shipping problems are being taken.
Additional . training has- been provided to individuals involved in the -
shipment of radioactive waste to assure suitable proficiency in the area of .
transportation of radioactive material.
Title                                         Dates o     NUS training session for Radwaste Handlers    03/31/86 - 04/01/86 o     NUS training session for Radioactive          04/02/86 - 04/04/86 Materials Supervision, Shippers and QA/QC Inspectors o     NUSCO Training Department course of           07/14/86 - 07/18/86 radioactive materials shipping                07/21/86 - 07/25/86 o     CNSI Workshop on Radioactive Waste            05/28/86 - 05/30/86 Packaging, Transportation and Disposal
                  -attended by Radioactive Materials Handling Supervisor (2)    3.F. Opeka letter to T.E. Murley, " Response to I&E Inspection No. 50-245/86-06,50-336/86-06 and 50-213/86-04," dated August 21,1986.

A-26 A continuing training program for Radwaste personnel is being developed.
o      The Health Physics section of the_ Technical Training Branch of the Nuclear Training Department will complete a job analysis and pro-cedure based task analysis in accordance with procedure NTM-1.06,
                   " Systematic Instructional Design" for the following areas: Radwaste Handlers, Radwaste Supervision and Station Technician (R/W), and Radwaste QA/QC by February 28,1987.
o      A set of instructional objectives resulting from this analysis effort will be produced 'and approved by the Training Program Control Committee fo'r Radwaste by March 30,1987.
o      A performance based -continuing training program consisting of classroom and on-the-job training will be developed by July 30, 1987 and completely implemented prior to December 31,1987.
(4)   At our request, INPO conducted an accreditation assistance visit at NU on August 25-26, 1986, to review and make recommendations on our accredi-tation efforts for the radiological protection technician training program.-
(5)   The following items represent additional enhancements to our training program:
o     An electrical switchgear and motor control center lab has been created.

{ )'
A-27 o Two new instrument and controls labs have been established.
o Full-scale mock-ups for reactor coolant pump seal replacement training have been procured for all four nuclear units.
(
o A full diesel engine has been procured for diesel overhaul' maintenance training.
~
o A full chemistry lab including all of the instrumentation used on all four nuclear units has been established.
o A gamma spectroscopy lab has been built.
J o A fully equipped and staffed graphics department has been established to support the training department-.
o A fully equipped technical library has been established.
1 4
Sf i

e e, A-28 Functional Area: LICENSING ACTIVITIES Board Recommendations: None.

===Response===
No comments.

Docket No. 50-336 Attachment B Northeast Nuclear Energy Company Millstone Unit No. 2 Response to SALP Report November,1986 l
I l

3,:   ...
B-1 Functional Areat PLANT OPERATIONS Board Recommendations: None.

===Response===
d We will continue ' to ' evaluate the ' need for a full-time onsite fire protection coordinator.
The report mentions various weaknesses identified in LER preparation. Millstone Unit No. 2 has reviewed the NRC's report from AEOD 'on this issue dat'e d July 21, 1986, evaluating suggested improvements and specifically reviewing the two
               " principle weaknesses" identified in the report summary: (1) failure to provide an assessment of the safety consequences and (2) the lack of identified failed components.
Concerning the failed component deficiencies, the report referenced 5 of the 10 LERs reviewed as not having completed the failed component fields. NUREG-1022, including its supplements, requires that the failed component field be lef t blank if the event is not attributable to a failed component. Mr. Hebdon, the author of the 10CFR50.73 rule, confirmed this method of LER preparation at an NRC/ Utility Symposium in 1985. Therefore, this identified weakness is un-founded.
The safety assessment, though implied in the LERs, was not specifically identified or annotated as a safety assessment of the. event. Therefore, in an

B-2 effort to' clarify LERs in the future, Millstone Unit No. 2 will adopt an outline format in its LER preparation. This should eliminate the weakness as described
      - in.the evaluation and ensure consistency in its LERs.
In addition to the proposed outline format, the entire evaluation by the NRC was discussed with Millstone Unit No. 2 engineering department personnel to ensure completeness in future LERs.
l 1
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=.
B-3
             = Functional Area: RADIOLOGICAL CONTROLS -
Board Recommendations: Improve radiation worker training to stress worker.
awareness of and compliance with Health Physics procedures. Improve the effectiveness of' the ALARA program. Strengthen assurance of quality in the transportation area.

===Response===
See Millstone Unit No. I's response.
It should be noted that Millstone Unit No. 2 has had high exposure primarily because of extensive steam generator repair requirements.
1

B-4 Functional Area: MAINTENANCE AND MODIFICATIONS Board Recommendations: None.

===Response===
No comments.

(         i g  . t ,-   3 n-
!                                                        B-5 Functional Area SURVEILLANCE :
i-i q                Board Recommendation: None.
J

===Response===
The report discussei2' violations o'ccurring during the performance of the Local r             '
: Leak Rate Test (LLRT) program for Millstone Unit No. 2. The following actions i
have been taken to ensure that similar violations do not occur in the future:
l' l
l                o    'After the last LLRT was performed,.a complete review of the program was
                      . undertaken. This included a review of procedures, forms, and equipment
                      -used during .the LLRT program. The - outcome was a revision to the l'
procedures and forms and an upgrade in equipment and its maintenance. In order to address the finding on lack of calibration, each test requires the p                      operator to verify calibration dates prior to the start of the test. In order to address the finding on failure to follow procedures, the procedures were t
clarified to provide clear direction and the operators were familiarized
!                      with the use of the procedures.
o    A discipline engineer has been assigned on a full-time basis the direct responsibilitiy.of supervising the performance of the 1986 LLRT program.
f                      His duties include assuring procedural compliance and scrutinizing every aspect of the program for weak points or areas of uncertainty. He reports directly to the Operations Supervisor.

J
                                                         . B-6 o   The same discipline engineer mentioned above will recommend long-term improvements to the LLRT program. It is anticipated that additional procedural upgrades and procurement of state-of-the-art equipment will ensure not only a program that complies with present regulations, but also a LLRT program that could be a model for other facilities.
L i
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. ; a ;,
B-7 Functional Area: EMERGENCY PREPAREDNESS Board Recommendation: Reassess effectiveness of commitment tracking sys-tem.

===Response===
See Millstone Unit No. I's response.
l 1

B-8 Functional Area: SECURITY AND SAFEGUARDS Board Recommendation: None.

===Response===
No comments.

B-9 Functional Area: REFUELING AND OUTAGE MANAGEMENT Board Recommendation: None.

===Response===
In the Facility Performance table on page 6 of the report, it is incorrectly stated that a Category 2 rating was assigned for the previous SALP period for the Refueling / Outage Management functional area.             .A Category I rating was actually assigned.(1) i (1)      See the T.E. Murley letter to 3.F. Opeka, " Systematic Assessment of Licensee Performance," dated May 20,1985, page 3 of Millstone Unit No.
2's report.

                        ._ .             ~ . -
o; e B-10 Functional Area: ASSURANCE OF QUALITY Board Recommendation: None.

===Response===
As stated in the report,.this functional area'is a synopsis of the assessments in the other nine areas. The responses for the other functional areas address specific actions which are being taken to minimize and/or eliminate problems in             _
those areas. We will continue' to take measures .to improve our assurance of quality _ in all areas.
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                                                                               .n          ;
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B                                                                                  o Functional Area: TRAINING lAND QUALIFICATION EFFECTIVENESS 1
Board Recommendation: None. '

===Response===
            ']
u            a V'i i                  See Millstone Unit No. l'Erespcas',I.
:: ,            ~
t (1)          Install tion oPtpgMillstone Unit No. 2 Simulator l                                                 .               ':~;{
o           Training on the simulator began on August 12,1985.
                                               ..~
                             '                                                      ~<
o          ' Availability of the siriulator has resulted in significant enhancements to Licensed Operator, Training Program and provided opportunities to support other station activities.
_1
                                 ^
of-The simulator is being used to support the Licensed Operator
                                               - Requalification Program. It is anticipated that the simulator will continue to be used to support approximately 50 percent of licensed operat[r requalification training, s
o           The simulator has been integrated into both Reactor Operator and Senior Reactor Operator Initial Training Programs. The simulator portions of these programs consist of approximately 200 hours and 100 hours, respectively. A licensed operator class and a licensed operator upgrade class, each including simulator training, were completed on July 3,1986.
e

. .. m B-12 Functior.al Area: LICENSING ACTIVITIES Board Recommendations: None.

===Response===
No comments.
i   -
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