ML20205T518

Forwards NRR Input for SALP Evaluation for Mar 1985 - May 1986.Detailed Review of Licensing Activities & Supporting Data & Summary Encl

ML20205T518
Person / Time
Site:	Millstone
Issue date:	05/21/1986
From:	Osborne D Office of Nuclear Reactor Regulation
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20205T515	List: ML20205T512 ML20205T518 ML20205T524
References
NUDOCS 8606130336
Download: ML20205T518 (10)

Text

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. Docket No. 50-336 Distribution:

Docket File

! NRC & L PDRs Richard W. Starostecki, Director MEMORANDUM FOR: DCrutchfield Division of Project and Resident WRegan Programs, Region I FMiraglia FSchroeder THRU: Ashok C. Thadani, Director DEisenhut PWRProjectDirectorate#8 HDenton Division of PWR Licensing-B PKreutzer DJaffe FROM: Dee B. Osborne, Project Manager PWR Project Directorate #8 Division of PWR Licensing-B

SUBJECT:

SALP EVALUATION - MILLSTONE UNIT 2 Enclosed for your use is NRR's input for the SALP Evaluation for Millstone Unit 2 for the period March 1, 1985 to May 30, 1986. Comments received from the various divisions within NRR were used in developing this evaluation.

Enclosure 1 is a Detailed Review of Licensing Activities and Foclosure 2 is Supporting Data and Summary.

Dee B. Osborne, Project Manager

. PWR Project Directorate #8 Division of PWR Licensing-B

Enclosures:

As stated cc w/ enclosures:

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Enclosure 1 Detailed Review - Licensing Activities Facility Name: Millstone Unit 2 Licensee: Northeast Nuclear Energy Company, et al.-

Evaluation Period: March 1, 1985 to May 30, 1986 NRR Project Manager: David H. Jaffe I. INTRODUCTION This report represents the results of an evaluation of the licensee in the functional area of " Licensing Activities." It is intended to provide NRR's input to the SALP review process as described in NRR Office Letter No. 44 dated January 3, 1984, and NRC Manual Chapter 0516.

II.

SUMMARY

OF RESULTS NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance Category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of Northeast Nuclear Energy Company in the functional area of " Licensing Activities", is rated Category 1.

III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.

IV. METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort on Millstone Unit 2 licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the PM and each reviewer applied specific evaluations to the relevant licensee performance criteria, as delineated in Chapter 0516, and assigned an overall rating Category (1, 2, or 3) to each criterion. The reviewers included this information as part of each Safety Evaluation prepared for Millstone Unit 2. The PM, after reviewing inputs of the technical reviewers, combined this information with his own assessment of the licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee. This rating also reflected the comments of the NRR Senior Executive assigned to the Millstone Unit 2 SALP assessment. A written evaluation was then prepared by the PM and circulated to NRR management for comments.

The basis for this appraisal was the licensee's performance in support of licensing actions that were completed during the current rating period.

These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, as shown in Table 1 and in Enclosure 2.

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Table 1 Licensing Activities Completed During the SALP Period Issue Completion Date

1) Use of ASME Code Case 03/14/85

2) Environmental Qualification of Electrical Equipment Important to Safety 03/20/85

3) Masonry Wall Design 04/17/85

4) Detailed Control Room Design Review Program Plan 05/23/85

5) Control of Heavy Loads (Phase II) 06/28/85

6) Item 1.1 of Generic Letter 83-28 07/10/85

7) Steam Generator rube Inspection Tech Spec Change Request 09/10/85

8) Eddy Current Test Results on Steam Generator Tubes 09/12/85

9) Fire Protection Audits 10/21/85

10) Post Maintenance Testing (Items 3.1.3 & 3.2.3 of Generic Letter 83-28) 10/24/85

11) Degraded Grid Voltage Procedure 10/28/85

12) IST Program Relative to Pumps & Valves 10/31/85

13) Rev. 3 to Suitability, Training & Qualification Plan (Safeguards) 12/19/85

14) Energy Balance Technique to Qualify Masonry Walls 12/20/85

15) Containment Isolation Dependability 02/28/86

16) Post Maintenance Testing (Items 3.1.1&2 and 3.2.1&2 of Generic Letter 83-28) 03/18/86

17) Reactor Trip System Reliability (Items 4.1 and 4.5.1 of 03/18/86 Generic Letter 83-28)

18) Preventative Maintenance Program (Items 4.2.1&2 of 04/10/86 Generic Letter 83-28)

19) Appendix R Exemption Requests and Alternate Safe Shutdown 04/15/86 i

l Note: Other issues completed during this SALP review period are contained in

! Section 7 of Enclosure 2. (License amendments issued) j

V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the six criteria specified in NRC Manual Chapter 0516. These are:

Management Involvement and Control in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives Staffing Operational Events

-- Enforcement History In addition to the above, Housekeeping and Control Room Behavior, and Training are also discussed.

A summary of the SALP ratings for the six areas and the remaining topics is shown in Table 2 below.

Table 2 Summary of SALP Ratings Criterion Rating Management Involvement and Control in Assuring Quality 2 Approach t'o Resolution of Technical Issues 1 Responsiveness to NRC Initiatives 1 Staffing 1 Training 1 Housekeeping and Control Room Behavior 2 Operational Events 1 Enforcement History 1 Composite Rating 1

A. Management Involvement and Control in Assuring Quality The licensee's management and its staff have demonstrated sound technical understanding of issues involving licensing actions. For the majority of licensing actions, the licensee's submittals are technically sound, thorough, and well referenced. They generally exhibit conservatism when considering safety significance. However, additional attention should be focused on the quality of the submittal so as to minimize the number of staff hours necessary for the review. A recent example includes the licensee's submittal dated July 9, 1985, " Response to Generic Letter No. 83-43," wherein numerous editorial errors were present. A different type of example of a submittal causing expenditure of excessive staff time is Appendix R. Currently, after many years of deliberation, Appendix R exemptions for Millstone Unit 2 have all been approved, but the licensee intends to modify and add new ones. These modifications and additions could have been foreseen earlier by the licensee and incorporated into prior submittals, thus avoiding the additional future expenditure of staff hours. In recognition of the above factors, a SALP rating of Category 2 is assigned to the criterion, " Management Involvement and Control in Assuring Quality."

8. Approach to Resolution of Technical Issues from a Safety Standpoint As stated above, the licensee has demonstrated sound technical understanding of issues involving licensing actions. A good example would be the comments received from one reviewer on the rerack of the Spent Fuel Pool. He states that a technically sound and thorough approach was taken during conference calls with knowledgeable licensee personnel. Another reviewer comments that the licensee has conservatively calculated the decay heat loads and has provided detailed, technically acceptable, and complete information. Of the total reviews completed by the staff during this rating period, over 60% of the reviewers rated the licensee as Category 1.

Based on the above, a rating of Category 1 is assigned to the criterion

" Approach to Resolution of Technical Issues from a Safety Standpoint."

C. Responsiveness to NRC Initiatives Responsiveness to NRC Initiatives has improved significantly over the last rating period. A good indication of this improvement is contained in the SALP reports from individual reviewers. Over 76% of the technical reviewers gave a rating of 1. However, improvements are possible and necessary to maintain this rating. Two issues that are taking on excessive amount of time for response are concerning Generic Letter 83-37 and Reg. Guide 1.97.

The licensee, in a July 25, 1984 letter, planned to submit Technical Speci-fications concerning items such as Noble Gas Effluent Monitors (II.F.1.1.),

Containment High-Range Radiation Monitor (II.F.1.3) and Containment Pressure Monitor (II.F.1.4). To date, these specifications have not been received.

The other issue for which an excessive amount of time is being taken for response is our request for additional information on the Licensee's Emergency Response Capability Conformance to Regulatory Guide 1.97.

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Because the lack of responsiveness to these two issues is the exception rather than the rule and because the vast majority of reviewers judged the responsiveness to be Category 1, a rating of Category 1 is assigned to the criterion, " Responsiveness to NRC Initiatives."

D. Staffing The licensing group consists of a supervisor and eight degreed engineers.

Five of the eight hold advanced degrees and four have had plant experience.

The degrees represented by this group include Civil, Mechanical and Nuclear Engineering. The utilization of this personnel in dealing with significant issues has been excellent with personnel assigned to given issues based upon their own background and expertise. During the rating period, the NRC Project Manager has dealt with four different individuals within the group with most submittals being complete, timely, and of high quality.

Based upon the above, a SALP rating of Category 1 for the criterion

" Staffing" is appropriate.

E. Training Effectiveness Members of the licensing group have received training in the following areas:

Quality Assurance Departmental Procedures for Processing Technical Specification Changes and FSAR updates Nuclear Safety Ethics Professional Development Courses and Seminars Unresolved Safety Issues & Seminars Outside Licensing Familiarization Training and Seminars Besides the areas denoted above, licensing personnel are rotated to the site during refueling outages to provide additional insight into the operation of the facility. In addition, several licensing personnel have received a 2-week training course covering various plant systems. Personnel from both Licensing and Engineering are participating in various Industry Groups such as Station Blackout, Fire Protection, EQ, and IEEE.

All the above contribute to the effective performance of the Licensing Personnel and as such a SALP rating of Category 1 for the criterion " Training Effectiveness" is appropriate.

F. Housekeeping and Control Room Behavior Based on limited observations by the NRC Project Manager, the control room was clean and free of debris. The operating shift personnel conducted themselves in a professional manner with no loitering or horseplay.

Based upon the above, a SALP rating of Category 2 is assigned to " Housekeeping and Control Room Behavior."

G. Operational Events Millstone Unit 2 was in operation for 9-1/2 months of the 15 month SALP period.

The reactor was shutdown for a refueling and maintenance outage involving major maintenance work on the steam generators from February 16, 1985 until June 29, 1985 when the reactor heatup to operating temperature and pressure was successfully completed. A total of 14 Licensee Event Reports (LERs) were received per 10 CFR 50.73. Of these LERs, five involved equipment problems, while five covered events not reportable under the requirements of 10 CFR 50.72.

During the SALP reporting period, a total of seventeen 10 CFR 50.72 non-security 1 reports were filed.

Of 12 events involving safety systems, only one involved an unplanned reactor trip. The July 15, 1985 trip resulted from a design change made during the 1985 outage which improperly connected the pressurizer spray valves to the opposite spray valve's controller. There were no complications associated with the trip. The unit's one trip per year frequency compares very favorably to the current national average of 5.9 trips / plant / year even in light of the extensive outage during the SALP period. In addition to the trip, there were five actuations.of Engineered Safety Features (ESF). None of the ESF actuations occurred at power although four out of five were associated with personnel error.

One noteworthy event, not reportable under 50.72 or 50.73 requirements, was a September 28, 1985 Reactor Coolant Pump motor failure due to damaged stator windings. A generic failure mechanism required corrective action on all four motors. The unit was returned to full power operation on November 11, 1985 and has remained on-line since. Also of significance was the sizeable number of steam generator tubes requiring sleeving after the chemical cleaning performed during the 1985 outage. This problem was the subject of a May 5, 1985 Operating Events Briefing.

Events at Millstone 2 are generally reported within the required time period.

Reporting appears to be accurate and conservative. In addition, the licensee occasionally provides reports for general information. Based upon the above and particularly considering the performance for the past eight months, we recommend a rating of Category 1 for this attribute.

H. Enforcement History During the SALP period, there were no enforcement actions directly related *to licensing activities. As a result, a SALP rating of 1 is assigned to the criterion " Enforcement History."

VI. Conclusion The licensee's licensing activities are performed by a well staffed and well trained group resulting in an overall efficient operation. Significant issues were completed during this rating period such as the Radiological Effluent Technical Specification (RETs) and Appendix R exemption requests. In addition, the Safety Evaluation for the rerack of the Spent Fuel Pool was accomplished in a very efficient manner due, in part, to the quality of the licensee's submittal and the responsiveness to NRC questions. The Licensing Staff inter-faces with the Engineering Department and the Operational Personnel at the Plant in a very efficient manner so that the proper people are available to discuss issues.

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The licensee's greatest strength is in the following area:

Responsiveness to NRC Initiatives - The overwhelming majority of reviewers gave a Category 1 rating in this area. The licensee has excellent capability to respond to NRC initiatives and has demonstrated this capability for the vast majority of items. Improvement is still possible and necessary for a few items if this excellent rating is to be maintained.

The following area needs additional attention:

Management Involvement and Control in Assuring Quality -

Greater emphasis should be added to ensure that submittals are consistently of high quality. The technical quality is consistently present but administrative errors and revisions to the original

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submittals should be reduced.

Based upon the evaluation of the above criteria, an overall SALP rating of Category 1 for_the area of " Licensing Activities" is appropriate.

VII. Status of Licensing Backlog At the conclusion of the SALP period, the licensing backlog consisted of the following TMI-related, multi plant, and plant-specific actions:

THI-related - 10 items Multi plant - 11 items Plant specific - 5 items Additional information has been requested of the licensee for six items.

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Enclosure 2 SALP EVALUATION FOR MILLSTONE UNIT 2

1. NRR-LICENSEE MEETINGS _

March 28, 1985 Inservice Testing of Auxiliary Support Systems to the EDG May 1, 1985 Eddy Current Test Results for Steam Ganarator Tubes November 22, 1985 Exit Meeting Concerning EQ Qualification Inspection In-House Reload Capabilities March 20, 1986

2. NRR SITE VISITS March 28, 1985 Inservice Testing of Auxiliary Support Systems to the EDG November 22, 1985 Exit Meeting Concerning EQ Qualification Inspection

3. COMMISSION BRIEFINGS None

4. SCHEDULAR EXTENSIONS GRANTED None

5. RELIEFS GRANTED October 31, 1985 Relief granted on four Safety Injection ,

Tank Outlet Check Valves

6. Exemptions Granted April 15, 1986 Appendix R Exemption Requests

7. License Amendments Issued June 19, 1985 Amendment #99, Reload Cycle 7 Analysis June 19, 1985 Amendment #100, Control Room Habitability Modifications August 2, 1985 Amendment #101, Diesel Generator Test Requirements and other Miscellaneous Changes

August 6, 1985 Amendment #102, Organizational Change / Training Supervisor August 12, 1985 Amendment #103, Deletion of Environmental Qualification Section September 16, 1985 Amendment #104, Radiological Effluents October 3, 1985 Amendment #105, Typographical Error December 10, 1985 Amendment #106, Overtime Policy December 19, 1985 Amendment #107, Contingency Guard Force December 24, 1985 Amendment #108, Battery Service Tests January 15, 1986 Amendment #109, Reracking of Spent Fuel Pool February 4, 1986 Amendment #110, Fire Protection April 9, 1986 Amendment #111, Reportable Events

8. EMERGENCY TECHNICAL SPECIFICATIONS ISSUED None

9. ORDERS ISSUED July 27, 1985 Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability (Supplement 1 to NUREG-0737) e 6

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