View source for B12672, Provides Update on Implementation Status of Corrective Actions Discussed in 861105 Response to Recommendations in SALP Board Repts for 15-month Period Ending 860531 & Addl Relevent Info

{{Adams
| number = ML20147B226
| issue date = 01/11/1988
| title = Provides Update on Implementation Status of Corrective Actions Discussed in 861105 Response to Recommendations in SALP Board Repts for 15-month Period Ending 860531 & Addl Relevent Info
| author name = Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000245, 05000336
| license number = 
| contact person = 
| document report number = B12672, NUDOCS 8801150178
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 39
}}

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1 NORTHEAST UTILITIES                                       c.nem omc.. . seio.n sire.i. Bernn. Connecticui l 1            'N C UNI 7S
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HARTFORD. CONNECTICUT 06141-0270 L     L   J  $7/S'$2.lyg7;                                       (203) 665 5000 January     11, 1988 Docket Nos. 50-245 50-336 B12672 Re: SALP U.S. Nuclear Regulatory Commission Attn:       Document Control Desk Washington, D.C. 20555 Gentlemen:
l Millstone Nuclear Power Station, Unit Nos. 1 and 2                                                 '
Systematic Assessment of Licensee Performance l
l The SALP Board Reports (1) for the 15-month period ending May 31,                                              l 1986 for Millstone Unit Nos. 1 and 2 were issued on August 29, 1986.      After a meeting between members of the Staff and Northeast Nuclear Energy (ppapany (NNECO) on October 2, 1986, NNECO submit-ted a response               to the SALP Board recommendations for the indi-vidual     evaluation categories ) The report on December 4, 1986, SALP Board issued their final which included a revision to the rating for the Refueling and Outage Management functional area for Millstone Unit No. 1.
The purpose of this letter is to provide an update on the imple-mentation status of the corrective actions discussed in our November 5, 1986 response, as well as providing additional relevant infornation.              Attachment A provides the status of the corrective actions for Millstone Unit No. 1 which were incomplete as of our November 5, 1986 response.                  Items which were completed (1)    T. E. Murley letter to J. F. Opeka, "Systematic Assessment of Licensee Performance (SALP) Report Numbers 50-245/85-98 and 50-336/85-98," dated August 29, 1986.
(2)    J. F. Opeka letter to T. E. Murley, "Systematic Assessment of Licensee Performance," dated November 5, 1986.
(3)    T. E. Murley letter to J. F. Opeka, "Systematic Assessment of Licensee Performance (SALP) Report Numbers 50-245/85-98 and 50-136/85-98 and Your Reply Letter dated November                                   5, 1986," dated December 4,           1986, 8801150170 800111                                                      /
PDR GL ADOCK 05000245 PDR
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l U.S. Nuclear Regulatory Commission B12672/Page 2 January 11, 1988                                                       )
as of that response are not discussed in this letter. Attachment B provides the status of the' corrective acticns for Millstone Unit No. 2.
We believe the actions presented in the attachments address the concerns of the Board, illustrate that these concerns are being adequately resolved, and will be useful to the NRC in conducting subsequent SALP evaluations. Please feel free to contact us if any questions arise on these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
                                                  #     dd W J? 'Mr6czkgf Senior Vice President cc:  W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit llo. 2          ,
W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 i
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: l.                                   Updated Status on SALP Functional Areas                                                                                                           >
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Attachment A B12672/Page 1 January 11, 1988 Functional Area:    PLANT OPERATIONS Board Recommendation:     None.
Status Uodate:
A variety of improvements have been implemented or are ongoing at Millstone Unit No. 1 in this functional area.
In our response dated November 5,   1986, we committed to continue to evaluate the need for a full time on-r.ite fire protection coordinator. The station fire protection progrnm has been revised to allow the fire protection specialist within the Station Services Engineering Department to perform more effec-tively. Responsibility for routine inspections and walkdowns have been transferred to each unit. The Station Services Engineering Department will continue to provide coordination for external inspections and audits and technical assistance to the units for fire protection matters.
Corrective action has been taken to address various concerns identified in LER preparation. Millstone Administrative Controls Procedure ACP-QA-10.09,     "Licensee Event Reports," has been revised to require an outline format for LERs. This ensures that Millstone LERs are consistent and contain all required informa-tion. The Unit LER coordinators have been working together to improve the overall quality of the LERs. Training sessions have been planned for all engineers that prepare LER reports.       The LERs are also reviewed by the LER coordinators for content and format before being presented to PORC.
Our status update for the Maintenance and Modifications function-al area includes a discussion of improvements that have been made concerning the mechanical pressure regulator (MPR) and the electric pressure regulator (EPR). Routine transfers from the MPR to the EPR and back are being conducted during turbine stop l   valve testing to improve operator manipulation of the pressure regulating system.
Unit 1 is testing the effectiveness of the General Electric Zinc Injection Process (GEZIP) for reducing Cobalt-60 in the recircu-lation system piping. The test will also verify the impact of the process on chemistry control. The recirculation piping was decontaminated and GEZIP is being continued to reduce the radia-tion levels in the drywell.
The Hydrogen Water Chemistry Pre-Implementation Test was conduct-l   ed during October, 1987. The radiation levels increased on the average a factor of 1.75 times the normal level at power

    . ~     . .   -               ,     -             .  -- .
: . i                                                                   ;
f Attachment A B12672/Page 2 January 11, 1988 i
operation. Furthermore, only'two indoor areas were identified as  l
)
requiring additional shielding, and outdoor measurements (inside    ,
and outside the protected area) revealed no significant'effect on the environment or necessary modifications.- overall, the results
             ~
of the test proved very positive with indicators that radiation levels could-be further ieduced due to a conservatism applied to the data. Evaluations of the feasibility of a permanent -system are ongoing.
Unit 1 has installed and is operating'an ion exchange system for    -
processing liquid radioactive waste from the floor drain system.
The system has replaced operation of the radwaste concentrators and has served to lower both operating costs and radwaste burial volume. Additionally, substantial man-rem savings have been
                                ~
realized as a result of eliminating the need for concentrator maintenance.                                                        !
t An improved CRD handling tool has been purchased. Its use during
             ' the 1987 refueling outage provided a significant reduction in the   ;
time and manpower required to remove CRDs from the reactor vessel. This resulted in significant exposure reductions during the 1987 refueling outage and will continue to reduce exposure in the future.
i              New in-line oxygen analyzers have been purchased for Unit 1
;              feedwater and reactor coolant chemistry control.                    ,
Several new chemistry data     trend plotting programs have been    !
:              produced, j              Several pieces of new laboratory equipment have been purchased to   ;
i              improve the sensitivity and efficiency of sampling and analysis.    ;
Unit 1 has installed a torus-to-drywell nitrogen pumpback system i              and is currently testing the system for operability. Installa-      !
tion of this system will enable the maintenance of a one-pound differential pressure between the drywell and the torus without the need for daily containment venting and purging though the
;              atmospheric control system.      Additional benefits will include   ,
i reduced nitrogen consumption, reduced operation of the standby gas. treatment system, and enhanced capability to monitor gross     .
containment leakage.                                                :
A summary of the August 18, 1987, inspection of Millstone Unit I              No. 1 by the Regional Administrator was provided in Inspection      i Report 50-245/87-21, dated September 24, 1987, and in Appendix I    t to Inspection Report 50-423/87-17, dated October 14, 1987.      The ;
overall finding was that Millstone Unit No. 1 was in "very good     ;
material condition" and the "absence of general debris and          :
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e 't Attachment A B12672/Page 3 January 11, 1988 excellent    housekeeping  conditions   were  particularly   note-worthy. . .
In the opening remarks of the exit interview for the Appendix R audit it was stated by the audit team leader and again by the Fire Protection inspector, that of the plants audited to date, the Millstone Unit 1 audit went the smoothest thus far. It was also stated that the audit team was particularly impressed with the thoroughness of the support documentation, the operator knowledge, the general cleanliness of the unit, and the excellent cooperation from the staff.      In evidence of the quality of preparation for the audit, the result was--no violations, no findings, and only two open items.
As identified in NRC Inspection Report 50-245/87-12, the opera-bility of the standby gas treatment system was compromised while moving fuel during the 1987 refueling outage. We identified this situation and took immediate action to correct the problem and reported it as a Technical Specification violation. As described in your report, due to aggressive and open management involve-ment, the NRC determined not to issue a Notice of Violation.
Through the BWR Owners Group Scram Frequency Reduction Committee, we have reviewed over 150 industry BWR scrams (for applicability to Millstone Unit 1) and have made a number of procedure changes to eliminate the possibility of similar scrams at Millstone Unit 1.
Cumulatively, we believe that the above-summarized initiatives, most of which are self-motivated, contribute positively towards improved performarace in the area of plant operations.
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Attachsaent A B12672/Page 4 January 11, 1988 i
Functional Area:       RADIOLOGICAL CONTROLS Board Recommendation:       Improve         radiation  worker  training  to stress urker awareness and compliance with Health Physics procedures. Improve the effectiveness of the ALARA program.
St cengthen assurance of quality in the transportation area.
Status Uodate:
In our response dated November               5, 1986,  we stated that the on-site radwaste handling group was being reorganized to provide a dedicated, permanent staff with greater resources for implemen-tation of the program. The supervisory position was upgraded to attract and retain a more skilled individual. Assistant super-visor and station technician positions were created to assist with program administration.      The authorized working staff was doubled to reduce the number of contractors involved with radwaste activities.      The radwaste handling group is now fully staffed with the exception of the station technician position.
The training of radwaste handling and quality control personnel to increase their knowledge of radwaste shipment preparations, shipping, and burial regulations, is continuing.              A retraining session for these work groups was                conducted by the Nuclear Training Department during April, 1987.             The session provided a survey of all major radioactive waste topics including waste forms, classification, shipment preparations, and burial require-ments.
During September and October 1987, NNECO Radioactive Material Handling personnel, supervisory personnel, and Quality Services Department personnel received the first half of a                  two-year training program designed by the Nuclear Training Department and the associated Training Program Control Committee.
Radwaste supervisory personnel have attended a training program in shipping regulations, classifications, and burial regulations offered by Chem-Nuclear. The program includes a trip to the Barnwall, South Carolina facility aimed at increasing the super-            ,
visors' awareness of radwaste shipment from the receiver's perspective.
NUSCO Operations      QA Conducted a comprehensive audit of the radioactive waste packaging and transportation program from September 8 to October 8, 1986.             The NUSCO Radiological Assess-ment Branch assisted in this audit by reviewing the program for             ,
waste characterization and classification as defined in 10CFR61.

Attachment A B12672/Page 5 January 11, 1988 Audit items were sequentially closed and final verification of corrective actions was conducted in July 1987.
The station QC department has made several inspections and audits to identify any deficiencies.
The improvements made in the performance of the Radwaste Handling Group is evident in three recent NRC inspections and an American Nuclear Insurers inspection that resulted in no findings.
A dedicated corporate engineering staff to address broad radwaste issues such as volume reduction, radwaste system engineering, etc., was formed in April 1987. A supervisor was appointed.
The Radwaste Review Committee was reactivated with a new charter and has held three meetings so far.
An aggressive radwaste reduction program is being implemented that includes quantifiable goals for each operating unit and Generation Construction,     contracting   a   "supercompactor"   to compact 55 gallon drums of radwaste off site, and the purchase of a hydro-grit d< contamination facility, and a program to separate wood and metal material fro'n dry-active waste to be decontaminat-ed and disposed of as clear waste.
Millstona Unit No. 1 had che lowest total occupational exposure of all domestic SWRs in 1986 and has in recent years been one of the best performing domestic BWRs in this regard.         The total radiological exposure received in 1986 was 162 man-rem.
On December 10, 1987, the NRC staff and NNECO met to discuss questions that the staff had raised during their review of the Millstone Unit No. 2 Forty-Year Operating License Amendment.
While the focus of this meeting involved Millstone. Unit No. 2, the principles discussed are equally relevant to Millstone Unit
[   No. 1. NNECO formally submi*ted the responses to these questions on December 18, 1987. This letter described the Exposure Reduc-tion Program that is unde- say at the four NU nuclear plants.
The Exposure Reductior:     . gram, consisting of a revised goal process and Exposur        ; tion Initiatives, was implemented in early 1987. A three yea _ average goal (1987-1989) process and annual man-rem budgets similar to expense budgets have been i   established for each of the three Millstone units. The 1987-89 three-year average man-rem goal for Unit 1 is 447 man-rem and the 1987 budget was 719 man-rem.       Through December 31, 1987, the radiological exposure received at Millstone Unit No. I was 716 man-rem. The Unit 2 1987-89 three-year average goal is 585 man-rem,  and the 1987 budget was 180 man-rem.           Through December 31, 1987, the actual radiological exposure received at

l As.tachment A B12672/Page 6 January 11, 1988 Millstone Unit No. 2 was 159 man-rom.                             In addition, man-rem forecast budgets have been prepared for 1988 and 1989 to ensure meeting the three-year average.      Our 1990 and beyond three-year average goals are set at 580 man-rem for Millstone Unit No. 1 and 525 man-rem for Millstone Unit No. 2. In order to attain these goals, NNECO has developed short and long-term initiatives as the second part of the Exposure Reduction Program.                         These initiatives were described in detail in the December 18, 1987 submittal.                            In addition, this submittal described the thousands of man-rem that have been avoided through our ALARA program since the early 1980s. The effects of the short-term Exposure Reduction Initia-tives has been apparent in 1987. A GE Zinc Injection process was implemented. A major ef fort is underway to develop more effec-tive procedures / controls on ALARA reviews, ALARA goals and budgets and on improving communications between the station and corporate office ALARA coordinators.
A radiological awareness program is underway to improve ALARA, HP work practices, and minimize radwaste production. The program includes man-rem status boards,       posters and awareness items, observation cards, and presentations to other departments by the Health Physics Department to increase awareness and sensitivity to common problems in radiological protection.                             The Level III Radiation Worker Training Program, which requalifies incumbent NU employees    for dosimetry   issue,   includes a module on the NU Exposure Reduction Program and the three-year goals and annual budgets. In addition, a special training program on ALARA job reviews and controls was provided to company and contractor construction supervisors.
The Chemistry Department      has   improved the                      laboratory    radio-chemical QA/QC program by participating in the Atomic Induecrial Forum cross-check program.      The split sample program between Millstone Station and the Haddam Neck Plant has also been expand-ed to include liquid, gas, particulate, and iodide cartridges.
Northeast Utilities has purchased and installed a compactor to reduce the volume of radioactive waste shipped for burial.                            The compactor operational procedures are being developed and the unit is currently going through the final stages of preoperational testing and is expected to be in operation in mid-January 1988.
Up to 85 percent of dry active waste generated will be compacted.
In addition, 100 percent of the dry active waste is sent to a vendor for supercompaction.
An extensive program to monitor the on-site laundry facility for hot particle contamination has been developed and implemented.

Attachment A B12672/Page 7 January 11, 1988 In December 1986 the feedwater regulating valve disks were replaced with new disks manufactured from stellite-free materi-als. This removed a significant source of Cobalt-60 from the plant.
Our status update for     the Plant Operations functional area includes additional discussions of actions we have taken which also are relevant to Radiological Controls. Brief descriptions of the use of the General Electric Zinc Injection Process, the performance of the Hydrogen Water Chemistry Pre-Implementation Test, and the installation of an ion exchange system for process-ing liquid radioactive waste are provided.
1 In summary, we are setting and meeting tough AIARA goals and are improving in the Radiological Controls functional area.
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Attachment A B12672/Page 8 January 11, 1988 Functional Area:      MAINTENANCE AND MODIFICATIONS Board Recommendation:       None.
Status Update:
In our response dated November 5, 1986, it was stated that we were in a transition state, going from what was once complete vendor support to an in-house maintenance program for the mechan-ical pressure regulator (MPR) system. NNECO is continuing to place significant management attention on improving the perfor-mance of the MPR.      The Instrument and Control (I&C) Department has been assigned primary responsibility for maintaining the regulator and is coordinating maintenance efforts with the Maintenance Department.      I&C is also working closely with vendor technical representatives to identify means of improving the performance of the regulator.        Reduced power evolutions were performed to make adjustments to the MPR. Weekly cansfers from the electric pressure regulator (EPR) to the MPR and back during turbine stop valve testing are being conducted.         This process provides a routine exercising of the MPR and gives the operators the opportunity to gain experience and confidence in its opera-tion. The transfer evolution from EPR to MPR and back has been evaluated by the Human Performance Evaluation Section for human factors and a number of improvements were identified and imple-mented during the 1987 refueling outage co enhance information available to the operator during EPR/MPR transfer.
The following     is  a list of activition completed during      the evaluation period.
A complete rebuild of the MPR and modifications to the EPR were completed. This was done to provide a more reliable pressure regulating system and to improve operator interface.
l A filter packaging system was added to the MPR oil supply system.
l l   Booster relays were added to the low pressure feedwater heaters' l   A&B emergency drain valves control air supply to improve the response time of the valves.
The Yarway level detectors were rebuilt to provide long term reliability of reactor protection and emergency core cooling
!   initiation devices.
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The I&C Department completed .he following actions to improve performance of critical plant components:
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Attachment A B12672/Page 9 January 11, 1988                                                     .
o     Adjustments were made to regulator controls for the gas turbine.
o     Formal in-service testing of feedwater regulating valves and feedwater heater level controls was conducted.
o     The replacement of aged components in the GE/MAC equipment-is continuing.
o     A program to upgrade Yarway internals was implemented, o     Surveillance of the LPCI break detection switches has been increased. Replacement of the switches with some better     ,
suited for the application are scheduled for 1988.
o     Modifications  have been proposed resulting from a gas turbine generator reliability study to improve the gas turbine governor. Its replacement with a Woodward micro-    .
processor system is planned for the 1989 refueling outage.
An extensive spare parts shelf life program is being instituted, including an inventory to identify degradable material on hand,     :
creation of a shelf life material data base, additional shelf
* life procedures, and increased receipt inspection training for stockhandlers.                                                      .
A new process computer and the safety parameter display system have been installed, further enhancing the ability to accurately    ;
monitor and appropriately respond to dynamic plant conditions.
In the last SALP Board Report the NRC Staff expressed concern with our efforts to address aging of plant equipment.           The following actions have been completed and are indicative of our efforts to address plant aging problems, o     Both condenser outlet crossover valves and the C-D inlet crossover valve were replaced during the 1987 refueling outage to preclude future problems with their repair.
o     The steam jet air ejectors (SJAEs) were rebuilt and exten-sive work was done on the valves associated with the air ejectors. Additional work was done on the turbine seals and   ,
efforts to locate air inleakage were successful in achieving a significant reduction in offgas flow.      Flow was reduced ,
from 120 SCFM to less than 30 SCFM.
o     Condenser tube sheets and water boxes were repaired with Belzona coating to minimize saltwater intrusion into the condensers and to protect the water boxes against erosion.

r o  .
Attachment A B12672/Page 10 January 11, 1988 o    All four service water pump discharge check valves were removed and refurbished. New stainless steel retaining nuts and washers were installed to prevent check valve failure and improve the wear characteristics of the parts.         All exposed surfaces were sandblasted - and painted with epoxy paint to improve resistance to corrosion.
o    The six inch service water header under the floor of the screenhouse (which supplies the chlorinator) was replaced with new pipe that was painted with epoxy paint. This was.
to prevent developing an unisolable leak in the service water system.
o    Du'  ag tc,e outage all areas of the service water system that were opened were coated either with epoxy paint or Belzona materials to improve the erosion / corrosion resistance of the system's materials.      Additionally, exterior surfaces of service water and emergency service water piping in C, D, and E bays were cleaned and then painted.with epoxy paint.
This should improve the resistance of the exterior of this piping to external corrosion and extend the life of the piping in these systems, o    New cylinder liners were installed and a thorough overhaul of the diesel generator engine was completed. This should greatly enhance the long term reliability of the unit.
o    A new cacing was installed on the C condensate booster pump.
o    chevron packing and live-loaded packing were installed on a number of valves in order to evaluate these alternatives as long term solutions to packing leak problems.
o    Core spray valves CS-21A & B were replaced. The old valves l          were becoming difficult to repair and replacement parts were t          unavailable.
l     o    The inlet and exhaust plenums on the gas turbine were l          replaced and refurbished.
The new CRD handing tool was used in the changeout of 22 CRDs.
l It provided a significant reduction in undervessel time and l     exposure. Following the changeout, a number of changes in
;     equipment were made to address "lcssons learned" from the use of the new tool.

'  o Attachment A B12672/Page 11 January 11, 1988 Functional Area:    SURVEILLANCE Board Rucommendation:     None.
Status Uedate:
A variety of improvements have been implemenited or are ongoing at Millstone Unit No. 1 in this functional area.
A procedure was developed to bypass the moisture separator high level trip, to allow troubleshooting, and to repair the moisture separator controls while on-line.
The SRM response surveillance was changed to allow continuous fuel movement while checking SRMs to save critical path time.
Corrective action in response to the Staff's concerns stemming from the inadequate performance of I&C surveillances during August 1987 includes the following:
o    The I&C Department has included less frequently performed surveillances in its on-the-job training program.
o    The test devices for APR, LPCI, and CS surveillances are being color-coded, o    Protective covers were installed to allow testing of only one APRM channel at a timo, o    I&C supervisory    observation was   increased  for high-risk surveillances.
o    Significant events training was revised to include discus-sions of personnel-type errors.
o    Department guidelines     regarding  surveillance  performance were revised.
o    Plant management will      continue to assess   future  outage schedules to minimize personnel pressure.
As a result of three surveillances that were not performed within the required interval, administrative changes have been imple-mented that will reduce the possibility of such errors. In each case, corrective action was taken immediately to conduct the surveillanco, and administrative programs were revised, including a new requirement for redundant reviews of surveillance sched-ules, to prevent reoccurrence.

Attachment A B12672/Page 12 January 11, 1988 Functional Area:      EMERGENCY PREPAREDNESS Board Recommendation:        Reassess   effectiveness  of   commitment tracking system.
Status Update:
The comprehensive 1986 Commitment Follow Listing was closed out after the October 8, 1987, Emergency Plan Exercise. All 1986 NRC open items were closed by the NRC Inspection Team.            The 1987 Commitment Follow Listing (one NRC open item and numerous licensee identified action items) has been developed and imple-mented for tracking commitments during 1988.
On August 31,    1987,(1) the Federal Emergency Management Agency (FEMA)   provided to the NRC its Final Exercise Report of the November 19-20,    1986,    Exercise of the Offsite Radiological Emergency Response Plans for the Millstone Nuclear Power Station.
The report states that the State of Connecticut demonstrated c high level of readiness for dealing with a radiological emergency and that the State Emergency Operations Center (EOC) is well equipped with appropriate resources, staffed by trained and dedicated professionals and effectively managed by a competent director and operations chief. The FEMA report also states that activation of all local EOCs was prompt and that these staffs consisted largely of knowledgeable and dedicated volunteers.        In addition, the report states that the State internal and external communications systems were excellent.
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(1)   R. R. Bellamy letter to E. J. Mroczka, dated October 20, 1987.

Attachment A B12672/Page 13 January 11, 1988 Functional Area:    SECURITY AND SAFEGUARDS Board Recommendation:    None.
S.tatus Update:
The reorganization of the Security Department is being implement-ed. NNECO is now interviewing applicants to permanently staff key positions in the new organization. All key positions are scheduled to be filled during the first quarter of 1988.
An Administrative Review Committee (ARC) has been established in order to formally review administrative documents, design chang-es, lesson plans, post orders, etc., prior to changes.       This formal review ensures that all interested parties consider the effects of the proposed changes for compliance with all require-ments and suitability for operational implementation.
The annual corporate management audit has been completed. This year's audit included a detailed inspection of all protected and vital area barriers. An action plan is being developed in order to implement appropriate recommendations in a timely manner.
During the past few months NNECO has been taking steps to address a number of security issues that were identified by the NRC in an Inspection Report and Notice of Apparent Violation dated October 2,  1987 and discussed during an enforcement conference with Region I on November 3, 1987. NNECO is currently preparing a response to the NRC Staff's final report on this matter dated December 14, 1987.
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Attachment A B12672/Page 14 January 11, 1988 Functional Area:       REFUELING AND OUTAGE MANAGEMENT Board Reccmmendation:       None.
Status Update:
Significant management attention is continuing to be placed on further improving the integrated planning of refueling outage activities.      The need to safely and efficiently conduct our refueling outages while attaining our ALARA goals continues to be emphasized.
Advanced planning was an integral part in the success of the 1987 refueling outage. The critical path was calculated a full year before the outage was to begin.         A list of items that could potentially impact the critical path was generated to provide management additional insight into these situations.      The opera-tions Department was given a schedule six months prior to the start of the outage to optimize the scheduling of the removal of systems from service.      In previous outages, this was done only one month prior to the outage start. The projects in the 1987 refueling outage were man-loaded to provide a more accurate indicator of the size and types of crews needed to complete the project. The Maintenance Department was increased to handle its normal outage work and also the unexpected work items that occur in outages.
Five months prior to the start of the 1987 refueling outage, the most senior, Senior Reactor Operator was removed from shift to work full time on planning and scheduling outage activities.      In the scheduling of outage activities, the philosophy directed by management is to ensure that at all times, regardless of Tech-nical Specification requirements, at least one emergency power source and at least one emergency core cooling system are avail-able. The presence of the Operations Department perspective in the scheduling of the outage was very beneficial in meeting this philosophy and in minimizing the overlap of system unavail-l   abilities. An outage crew consisting of plant operators was used l   during the outage to oversee and direct daily activities and r   provide the continuity necessary to ensure the schedule was followed with minimal impact on all departments.          The shift
(   operators worked a modified four-shift rotation which minimized I
overtima for the operators on shift while still providing addi-l   tional manpower when necessary.
1 Comprehensive management attention and adherence to the schedule allowed the outage to proceed without unforeseen complications.
As job scopes expanded, the impacts to the critical path were analyzed     and    then   prioritized    after  evaluating   safety l

Attachment A B12672/Page 15 January 11, 1988 implications and ALARA goals. Management was made aware of this data to assist in making knowledgeable decisions.      Though the schedule was very aggressive, at no time was it beyond the capabilities of the organization.      The 1987 Millstone Unit i refueling outage was originally planned for a duration of 70 days. The final outage duration was 76 days (turbine off-line to 100 percent power) due to additional testing and expanded work scopes.
In the 1987 refueling outage, the major work items completed were the   chemical decontamination of the recirculation system, torsional testing of the turbine generator, and specified in-service inspections. The replacement of the "B" low pressure turbine rotor, the jet pump instrumentation nozzle assemblies,                             '
and extraction steam piping as well as completing the Appendix R work and painting 96% of the torus equated to significant accom-plishments for this outage.
Outage management has been working with the BWR Owners Group to gain insight into the way similar plants are conducting success-ful and short outages. Outage management is also investigating the ASEA-ATOM BWR plants in Finland and Sweden because of their record for short outages and low personnel radiation exposure rates during outages.
The schedules for the 1989 and 1991 refueling outages are cur-rently in the planning stages.       Various scenarios are being developed from information known to increase the efficiency and effectiveness of our outages as well as to have outages fit into a 35 to 42 day window. Millstone Unit 1 is in the process of developing a multicycle schedule with a three year outlook to better plan preventative and corrective maintenance as well as outages.
The outage planning department is currently implementing organ-izational changes to further improve the effectiveness of manag-ing outages. This, coupled with internal critiques, will improve and ensure the continuity in future outages.
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Attachment A B12672/Page 16 January 11, 1988 B1Dctional Area:      ASSURANCE OF QUALITY Board Recommendation:      None.
Status Update:
The QA and QC departments / functions have been consolidated to form a reorganized quality organization under a single director, reporting directly to the vice president of Nuclear and Environ-mental Engineering. The consolidated Quality Services Department has been formed with one set of quality procedures that are used by both the QA and QC groups. This new organization is designed to more effectively and efficiently utilize resources to accom-plish one quality goal.
In addition, the Nuclear Training Department and Quality Services Department are conducting a job and task analysis for the Quality Services inspector position.      The analysis data will be used as input    for   the  design    and   development   of   a  knowledge-/
performance-based training program for Quality Services inspec-tors. This training program will be used to initially qualify Quality Services inspectors and also to maintain qualification.
The training program is using the procedural guidance provided in the Nuclear Training Manual following the Systematic Instruc-tional Design Model. With this direction, the Quality Services Inspector Training Program should be in an INPO-accreditable format if it is included in the INPO Accreditation Program in the future. To date, diagnostic examinations have been conducted of QC personnel to identify weaknesses, and training is being developed to dddress these weaknesses. Team training with other departments is also being utilized to help reduce exposure and radioactive waste while improving safety and quality in the job.
A pilot program of team training of QA/QC personnel with other department personnel is in progress.         An example pertinent to Millstone Unit 2 is training for RCP seal replacement on the full scale mock-up. Personntl from Maintenance, Reliability Engi-neering, Industrial Safeti, Health Physics (Technicians and ALARA coordinators) all trained together. Several improvements to the seal replacement process were made as a result of the multi-discipline    involvement  in   the   program. Improvements  should result in reduced exposure and radwaste while improving safety and quality in the job.
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Attachment A B12672/Page 17 January 11, 1988 Functional Area:       TRAINING AND QUALIFICATION EFFECTIVENESS Board Recommendation:       None.
Status Update:
In our response dated November 5, 1986 NNECO provided an update on training program accreditation, noting four operator training programs which received INPO accreditation on August 21, 1986 and six programs for which INPO reviews and site accreditation visits remained pending.      The successful completion of the following milestones exemplifies the significant progress which has been made in conjunction with the reorganization during the SALP period to meet the corporate goal of "training excellence."
l   The operator Hot License Training Programs have fully integrated l   the plant-specific simulator into both hot license and requali-i fication training.
The Health Physics Section of the Technical Training Branch of the Nuclear Training Department completed a Job Analysis and full Procedure-Based Task Analysis on February 28, 1987.      The analyses were performed in accordance with the Nuclear Training Manual, Procedure 1.06,      "Systematic Instructional Design," for the following work groups:      Radwaste Handlers, Radwaste Supervision and Station Technician (RW), and Radwaste QA/QC.           A set of instructional objectives resulting from this analysis effort was formally approved by the Radwaste Training Program Control Committee on March 31, 1987.         A performance based training program, based upon the approved training objectives, including classroom and on-the-job training was developed by July 31, 1987.
Implementation of this program was completed for all three work groups on November 24, 1987.
i   To better equip our station engineering staff to respond to their position requirements, a knowledge-based training program was completed in 1987. This program contains modules in technical as well as administrative areas identified following a modified job      i task analysis of the positions involved.
On December 15, 1987, Northeast Utilities appeared before the Institute of Nuclear Power Operations Accrediting Board in Atlanta, Georgia, and was awarded Accreditation for the following training programs.
o     Mechanical o     Instrumentation and Controls o     Health Physics o     Chemistry

Attachment A B12672/Page 18 January 11, 1988 o     Electrical o     Technical Staff and Managers With this action Millstone Units 1 and 2 now have all identified training programs accredited.
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Attachment A B12672/Page 19 January 11, 1988 Functional Area:     LICENSING ACTIVITIES Board Recommendation:     None.
Status Update:
Northeast Utilities personnel are playing a lead role in the development of the NUMARC/NSAC guidance document on 10CFR50.59 safety evaluations. The intent of this effort is to establish clear, unambiguous, uniform guidance in an area which is open to interpretation and confusion. NU personnel were heavily involved in a formal presentation of a draft of the document to designated NRC management    personnel. NU's own guidance document     on 10CFR50.59 safety evaluations was a key element in the develop-ment of the NUMARC/NSAC document, with additions and modifica-tions from other utilities. We plan to continue supporting this NUMARC-coordinated effort until we reach a consensus between the industry and the NRC.
As of October 1987, office space has been designated at the Millstone Site for full-time use by Licensing personnel to facilitate increased focus on plant activities and improve the interface between the plant and Generation Facilities Licenning on licensing-related issues. It is intended that this action will improve the quality and timeliness of licensee responses and increase the frequency of prompt, personal communications with station personnel.
In the area of commitment implementation, we have demonstrated our sensitivity to the need to improve commitment tracking and implementation. Although we had already identified and under-taken some improvements in this area, the Staff raised this concern as part of a routine inspection in August 1987.       Our response on October 1, 1987, highlighted improvement areas and demonstrated a high level of management involvement and corpo-ratewide attention which we feel is moving toward attaining the performance level we desire. Via letter of December 8, 1987, the Staff agreed that these actions are responsive.
NNECO submitted the Millstone Unit No. 1 ISAP Response Letter on August 4,   1987,  which included an Integrated Implementation Schedule (IIS). This IIS has scheduled completion of proposed modifications and selected studies during the next few years, commensurate with the ISAP priority rankings, and other addi-tional constraints. The ISAP pilot program will be completed in the near term with the submittal of the IIS License Condition.
It is envisioned    that IIS updates will be submitted every six months following issuance of this License Condition.

Attachment A B12672/Page 20 January 11, 1988 NNECO has found the ISAP to be a very resource-efficient process by which all safety issues and plant improvement projects are evaluated for associated benefits. Additionally, NNECO considers the process to represent an excellent forum for resolution of all outstanding issues. The {{letter dated|date=August 4, 1987|text=August 4, 1987, letter}} provides NNECO's recommended disposition of some 64 ISAP Topics, exclusive of the 21 topics that were resolved prior to August 4.           One example of the effectiveness of this comprehensive approach concerns the resolution of numerous purge and vent related issues, which resulted in the installation of the torus-to-drywell pumpback system discussed in the Plant Operations functional area.
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Docket No. 50-336 B12672 4
Attachment B Northeast Nuclear Energy Conpany Millstone Unit No. 2 Updated Status on SALP Functional Areas A
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January 1988

Attachment B B12672/Page 1 January 11, 1988 Functional Area:    PLANT OPERATIONS Board Recommendation:    None.
Status Uodate:
A variety of improvements have been implemented or are ongoing at Millstone Unit No. 2 in this functional area.
With respect to fire protection and'LER preparation, we refer you to the Millstone Unit No. 1 status update in the Plant Operations functional area.
The  Operations Department has implemented a modified shift rotation schedule designed to improve the health and working conditions of shift-working employees. The new schedule was created by the Unit 2 Operations Department employees with the assistance of the Center for the Design of Industrial Schedules.              -
The new schedule is expected to improve operator health, perfor-mance on the job, and the quality of scheduled time off.       The program features reduced frequency of shift changes (Wake / sleep timing changes), reduced time that each operator works during the low point of the body's natural alertness cycle, and education of the employees and their families in various coping strategies for dealing with the demands of rotating shift work.        Additional information is provided in the {{letter dated|date=December 23, 1987|text=December 23, 1987, letter}} from E.
J. Mroczka regarding shift optimization.
Emergency Diesel Generator reliability has been improved by removing the SIAS start, changing the length of run times during operability checks, and reducing the number of starts by changing preventive maintenance from weekly to biweekly.
New in-line sodium analyzers have been purchased for Unit 2 steam generator blowdown.
The  operation of the condensate polishing system has been
            . improved. For example, the anion regeneration is now based on capacity instead of throughput. This has greatly reduced sodium throw.
Unit 2 condenser air inleakage is being maintained at less than 4 scim resulting in less than 8 ppb oxygen in the condensate.
The Unit 2 hotwell sodium analyzers have been modified to improve their readout.
Several new chemistry data trend plotting programs have been produced.

Attachment B B12672/Page 2 January 11, 1988 Several pieces of new laboratory equipment have-been purchased to improve the sensitivity and efficiency of sampling and analysis.
A pressurizer pressure deviation alarm which alerts operators to a changing reactor coolant system pressure was installed.         This warning assisted operators during the three reac*er coolant system pressure decreases this cycle.
Cumulatively, we believe .that the above summarized initiatives, most of which are self-motivated, contribute positively towards improved performance in the area of plant operations.
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Attachment B B12672/Page 3 January 11, 1988 Functional Area: '     RADIOLOGICAL CONTROLS Board Recommendation:       Improve . radiation  worker  training   to stress worker awareness of and compli-ance with Health Physics procedures.
Improve the effectiveness of the ALARA program. Strengthen    assurance    of quality in the transportation area.
Status Uodate:
With respect to the-Board Recommendation above, we refer you to Millstone Unit No. l's status update in the Radiological Controls functional area.
Shielding has been improved around the Unit 2 nonregenerative heat exchanger area to reduce radiation levels in the loop areas.
Unit 2 participated in a pilot Spent Fuel Consolidation program          ;
to extend storage capacity of the Spent Fuel Pool. Although this activity had the high potential for radiation exposure and radioactive    contamination,   NNECO     exercised  the   nt :essary controls to limit the exposure. The total exposure for this task was 3.965 man-rem, or 0.885 man-rem less than the goal of 4.85 man-rem.
                'ALARA programs have been emphasized to all Unit 2 personnel.
These include the following:
o     Permanent shielding and temporary shielding rack installa-tion for the nonregenerative heat exchanger area.          This reduces exposure during routine loop inspections and reduces the exposure incurred while installing temporary shielding for maintenance activities.
o     Design and fabrication of a rack for storage of the CEA Extension Shaft sleeves.
o     Insullation of permanent frisking booths in the Containment       i and Auxiliary Building.
 !               o     Temporary shielding control improvements.
A tool crib for storage of contaminated equipment was located outside the personnel hatch near containment.          This reduces personnel exposure and reduces radwaste.
The implementation of the Blue Bag /SAVE Tag System provides methods of identifying materials and tools in radioactive areas L

Attachment B B12672/Page 4
    -January ~11, 1988 and prevents inadvertent discarding of valuable -tools and mate-rials, reducing radwaste.
The Millstone Unit 2 actual radiological exposure for 1987 was 159 man-rem, compared to the goal of 180 man-rem.         Of the 159 man-rem exposure, 81 man-rem was expended on.a two-week steam generator repair outage. This resulted in an operating period monthly average exposure of 6.7 man-rem, as compared to an original goal of 8 man-rem per month.
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Attachment B B12672/Page 5 January 11, 1988 Functional Area:      MAINTENANCE AND MODIFICATIONS Board Recommendation:      None.
Status Update:
The following is a list of activities completed during this evaluation period:
Modifications have been made to improve the reliability of the steam generators including condenser and feedwater heater re-placement to remove copper, modifications to the makeup water system to reduce impurities, addition of a nitrogen blanket to the condensate storage tank, and installation of state of the art sample station instrumentation.
Hydrolazing and sludge lancing removed significant copper and iron deposits (approximately 900 lbs. from the steam generators) from the secondary side piping.
RCP vibration monitoring equipment has been upgraded to improve diagnostic capability for increased pump reliability.
* The "C" RCP motor was replaced with one containing a more reli-able upper bearing.
The Instrument Air system reliability has been improved by installation of backup air supply to critical plant components, crossties to Station Air, alarms, and flow restrictors. This was cited by INPO as a strength.
Power. supply improvements to the auxiliary feedwater pump room sump pump have been made to enhance reliability of the AFW system during a loss of normal off-site power.
A new process computer has been installed adding SPDS, ICC and archival capabilities.
Unit generation / performance    has been   continually optimized.
Efforts in this area include:
o     Condenser tube fouling test is in progresL to determine cleaning requirements for optimum performance and heat                                   ,
removal capabilities, o     Modifications to the 2A/B and 6A/B feedwater heater level control valves were implemented.
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Attachment B B12672/Page 6 January 11, 1988 o    Instrument taps on the 6A/B feedwater heaters were relocated based upon a performance study by an outside consultant.
o    A moisture carryover test has been conducted to determine if design carryover conditions exists.
A major increase in the size of the Unit 2 Maintenance Shop has been implemented along with the establishment of a dedicated on-
* site snubber test facility. New facilities were also created for Unit 2 I&C personnel.
A new containment pedestal crane has been installed which will allow two evolutions requiring crane support to be accomplished at one time and allows for a faster crane speed during high rad movements.-
Duplex lube oil strainers were installed on the reactor coolant pump motors. This will enhance seal performance since the motor will not be required to be stopped to clean the lube oil strain-er.
Control of plant work on a day-to-day basis has been improved.
Efforts in progress include:
o    Daily status reports are produced and morning meeting reviews of scheduled / planned work with a day ahead look are conducted.
4 o    Daily meetings between the Shift Supervisor and Maintenance planner /AMS to review / discuss / plan the next day's mainte-nance activities and tagging are conducted, o    Reviews of the sensitivity of this issue by supervisors with                         ,
department personnel on recurring (as-needed) basis are                              '
conducted.
Weidmuller terminal blocks were installed.      The original knife switches were responsible for two down power evolutions last cycle due to erroneous reactor coolant pump trouble indications.
The terminal blocks eliminate knife switch problems.
A micro-verso trip conversion of all 480 volt AK type breakers was performed. This modification corrected the problem of unreliable trip devices in these breakers.
Average Maintenance    Department corrective maintenance backlog (AWos that can be worked) has been reduced to 76 AWos for 1987.

'  O Attachment B B12672/Page 7 January 11, 1988 A license amendment request is being prepared concerning boric acid reduction. Issuance of the requested amendment will allow us to reduce the large amount of maintenance time required to maintain the boric acid heat tracing, as well as the high expo-sure associated with maintaining this system.
While  visiting Millstone Unit      No. 2  during  the week    of October 26-30, 1987, the NRC Staff Project Manager raised some questions regarding the vital de switchgear room chilled water system and the fact that it was not operating. Documentation, including a safety evaluation performed in accordance with 10CFR50.59, was provided to the Project Manager. In a telephone conversation on October 30, 1987, NNECO discussed this issue with the NRC Staff, including members of Region I. As a result, NNECO provided the Staff with additional details regarding the history of this system in a {{letter dated|date=December 4, 1987|text=letter dated December 4, 1987}}. At the time this issue was raised, NNECO had been working on this system and placed it back in service as of November 6, 1987, as documented in the {{letter dated|date=December 4, 1987|text=December 4, 1987, letter}}. NNECO had determined that there was no safety concern associated with having the chilled water system out of service since an engineering evaluation had deter-mined that under the most severe heat load conditions,        the battery room exhaust fans provided sufficient cooling for the rooms.

Attachment B B12672/Page 8 January 11, 1988 Functional Area:     SURVEILLANCE Board Recommendation:                         None.
Status Uodate:
In our {{letter dated|date=November 5, 1986|text=letter dated November 5, 1986}}, we informed the Staff that a discipline engineer had been assigned on a full-time basis the direct responsibility of supervising the performance of the 1986 Local Leak Rate Test (LLRT) program. 10:3 duties included assuring procedural compliance and scrutinizing every aspect of the program for weak points or areas of uncertainty.                                                                                                                                     Additional procedural upgrades and the procurement of state-of-the-art equipment have further improved the program. The same discipline engineer for the 1986 LLRT program will be conducting the 1988 LLRT program.
The following activities were completed during the evaluation period:
BOP pipe inspection led to repairs which allowed the unit to operate through Cycle 8 with no leaks in any large bore pipes in the extraction steam, feedwater and condensate systems.
The diesel generator auxiliary component IST program was devel-oped and implemented.
A complete containment tendon surveillance including installa-tion, testing and operation of the tendon grease pressurization system to eliminate water intrusion was performed.
The use of quarterly thermography surveys of plant electrical and mechanicel equipment has detected plant problems before they have affected overall reliability.                       Most notable was the detection of a loose connection on the 'B' phase of the "C" RCP containment electrical penetration. This could have resulted in a plant shut down for two weeks or more.
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Attachment B                                                                            ,
B12672/Page 9
      . January 11, 1988 Functional Area:     EMERGENCY PRdPAREDNESS Board Recommendation:           Reassess effectiveness   of      commitment tracking system.
Status Uodate:
See Millstone Unit No. l's status update.
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Attachment B B12672/Page 10                                                                                        >
January 11, 1988 Functional Arga:    SECURITY AND SAFEGUARDS Board Recommendation:-   None.
Status Update:
See Millstone Unit No. l's status update.                                                             7 1
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Attachment B B12672/Page 11 January 11, 1988 Functional Area:      REFUELING AND OUTAGE MANAGEMENT Board Recommendation:      None.
Status Update:
Consistent with our efforts to safely and efficiently conduct our refueling outages while striving to attain our ALARA goals, the integrated planning of refueling outage activities is continuing to receive greater emphasis. The outage has recently commenced, and we are confident that extensive preplanning will pay divi-dends which will be evident as the outage progresses. Some of this preplanning is specified below:
o     The outage    schedule was essentially frozen three months prior to the start date. No additional tasks were incorpo-rated unless they were of an emergency nature.
o     All design change packages were submitted to the station for review and approval three months prior to the start of the outage.
o     Six weeks prior to the start of the outage, an experienced senior control operator was removed from shift to work full time on the preparation of outage activities, o     Extensive critical review of all steam generator activities in the preoutage months resulted in one of the shortest (52 days)   refueling outage schedules in Millstone Unit No. 2 's history. This will equate to expending less expo-sure and money, minimize the chances for personnel injury, and provide a better overall capacity factor for 1988.
o     The critical path schedule for the 1989 and 1991 refueling outages will be developed by mid-1988.      The goal for all future outages will be 35 to 42 days.        Various segments within future outage schedules will be examined to determine if specific tasks can be accomplished more efficiently.

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Attachment B B12672/Page 12 January 11, 1988 Functional Area:     ASSURANCE OF QUALITY
: Board Recommendation:    None.
Status Update:
See Millstone Unit No. l's status update, 6
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9 O Attachment B B12672/Page 13 January 11, 1988 Functional Area: TRAINING AND QUALIFICATION EFFECTIVENESS Board Recommendation:       None.
Status Update:
See Millstone Unit No. l's status update.
Operator training has been strengthened.         This includes good coordination / cooperation between the Training Department, the Operations Supervisor, and on-shift personnel; regularly sched-uled meetings between the operations Supervisor and training supervisors; and, when necessary, Training Department participa-tion in operations Supervisor's meetings to discuss on-shift training optimization / issues.
Technical and staff training efforts have received significant praise as evaluated by the INPO accreditation team visit in September of this year. I&C's involvement corresponds to approx-imatoly 12% of the department's available work schedule in 1987.
This involvement includes classroom, on-the-job training perfor-mance, simulator enhancement of instrument failure analysis and standardization of I&C training programs between Millstone 1, 2, 3, and the Haddam Neck Plant.      High risk on-the-job surveillance training was performed on the simulator instead of the actual plant.
The Unit manufactured or purchased many mock-ups to aid           in training for specific plant jobs.      Some of the mock-ups now used are:
o     RCP seal and associated RCP seal cavity mock-up.
o     EEQ connection mock-up, o     An actual      diesel  generator  and  cross-sectioned  diesel governor.
o     Core protection calculators      for diagnostics and trouble-shooting.
Three of the four Assistant Maintenance Supervisors have complet-ed the month-long safety intern program.      This program familiar-izes first-line supervisors with the Safety Department and the role safety plays in their immediate surroundings and throughout the company.      It is an opportunity for first-line supervisors to becomo directly involved in safety issues from the perspective of the Safety Department.      This program effectively emphasizes the

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Attachment B B12672/Page 14 January 11, 1988                                                                                 i importance of safety to the individuals primarily responsible for                                [
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                  ; c-  o Attachment B B12672/Page 15                                                                                                           [
January 11, 1988                                                                                                         ;
Functional Area:          LICENSING ACTIVITIES                                                                          l Board Recortmendation:              None.
Status Uodate:
See Millstone Unit No. l's status update for our discussion of our involvement with the development of the NUMARC/NSAC guidance document on 10CFR50.59 safety evaluations, the designation of office space at the Millstone site                                         for use by Licensing 3
personnel, and commitment tracking and implementation.
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