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| {{Adams | | {{Adams |
| | number = ML20249B044 | | | number = ML20237C131 |
| | issue date = 06/12/1998 | | | issue date = 08/12/1998 |
| | title = Insp Rept 50-423/97-83 on 980413-24.Violations Noted. Major Areas Inspected:Readiness of Plant Hardware,Staff & Mgt Programs to Support Safe Restart & Continued Operation of Plant Unit 3 | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-423/97-83 Issued on 980612.Actions Will Be Examined During Future Insp of Licensed Program |
| | author name = | | | author name = Durr J |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| | addressee name = | | | addressee name = Bowling M, Loftus P |
| | addressee affiliation = | | | addressee affiliation = NORTHEAST NUCLEAR ENERGY CO. |
| | docket = 05000423 | | | docket = 05000423 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-423-97-83, NUDOCS 9806220008 | | | document report number = 50-423-97-83, NUDOCS 9808200235 |
| | package number = ML20249B041 | | | title reference date = 07-14-1998 |
| | document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE |
| | page count = 135 | | | page count = 3 |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION . | | {{#Wiki_filter:_ _ _ _ .- _ _. _ _ |
| OFFICE OF NUCLEAR REACTOR REGULATION SPECIAL PROJECTS OFFICE Docket Nos.: 50-423 Report Nos.: 97-83 License Nos.: NPF-49 Licensee: Northeast Nuclear Energy Company P. O. Box 128 Waterford. CT 06385 Facility: Millstone Nuclear Power Station, Unit 3 Inspection at: Waterford, CT Dates: April 13-24,1998 Inspectors: J. Cummings, Contractor G. Galletti, NRR A. Gibson, Contractor D. Loveless, Region IV L. Miller, AEOD K. Mortensen, NRR C. Petrone, NRR D. Rich, Region ll L. Scholl, Special Projects Office W. Schmidt, Region i J. Williams, Region i P. Wilson, NRR A. Vegel, Region ill Reviewed by: James.Trapp, Team Leader, Division of Reactor Safety Approved by: Jacque P. Durr, Branch Chief, Special Projects Office l:
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| l- 9906220009 990612 l PDR ADOCK 05000423 l; O PDR ,
| | August 12,1998 p Mr. M. L. Bowling, Recovery Officer - Technical Services l C/o Ms. P. A. Loftus, Director - Regulatory Affairs for Millstone Station NORTHEAST NUCLEAR ENERGY COMPANY PO Box 128 l |
| | Waterford, CT.06385 |
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| | SUBJECT: INSPECTION 50-423/97-83 |
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| | ==Dear Mr. Bowling:== |
| u_ _ _----- =-- - - - - - . _
| | This letter refers to your July 14,1M8 correspondence, in reponse to our June 12,1998 letter. |
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| | Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program. |
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| =EXECUTIVE SUMMARY=
| | Your cooperation with us is appreciated. |
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| BACKGROUND The objective of the Operational Safety Team inspection (OSTI) was to provide current information to the Restart Assessment Panel by evaluating the readiness of plant.
| | Sincerely, ORIGINAL SIGNED BY: |
| | | Jacque P. Durr, Chief Inspections Branch Millstone inspections Docket Nos. 50-245; 50-336;50-423 |
| hardware, staff, and management programs to support a safe restart and continued .
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| operation of Millstone Unit 3. The OSTI observed operations at Unit 3 over a 23 day i- period which included an intensive 2 week inspection activity conducted during April 13-L 24,1998. The 14 inspectors were selected from all 4 NRC Regional Offices, Office of i Nuclear Reactor Regulation (NRR), Office for Analysis & Evaluation of Operational Data -
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| . (AEOD),' and Special Projects Office (SPO). The OSTI (team) monitored licensee activities- during plant transition between operational modes,= both during normal and off-normal work hours. This inspection represents over 1500 hours of direct inspection effort. The OSTI performed an independent, broad scope assessment in the areas of management programs and oversight, operations, engineering and technical support, and maintenance and .
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| surveillance. The OSTl used selected sections of NRC Inspection Manual Procedure 93802, " Operational Safety Team inspection," to conduct this inspection.
| | l 9008200235 980812 PDR ADOCK 05000423 G PM , |
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| MANAGEMENT PROGRAMS & OVERSIGHT Mannaement Processes Appropriate standards and expectations for safety were established by senior management and were understood by subordinate managers and staff. Management's planning and direction for the restart and recovery of Unit 3 were effective, but planning and direction for post-restart activities were incomplete. Effective leadership was provided and management involvement in routine activities and emerging issues was adequate. Staffing was adequate for recovery and restart. The application of probabilistic risk assessment (PRA) insights to design and operation of the plant was adequate with one exception being the lack of risk assessments for removal of equipment from service during transitional modes of operation. This deficiency was adequately addressed by the licensee during the OSTl. Responsiveness to employee concerns was appropriate. Integration of quality assurance into the line organization was effective.
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| Management's expectations for safe plant operations were understood and followed.
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| Senior plant management used a variety of effective means to reinforce expectations.
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| Where expectations for communication or teamwork were not being met, plant management _took appropriate and timely actions to correct the weaknesses and reinforce expectations.
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| Corrective Action Program The overall corrective action program was adequate to support plant restart. The threp. .d
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| L for including identified plant deficiencies in the corrective action program was low and a
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| ' timely resolution of safety significant issues is generally being met. The team concluded
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| that the root cause evaluations reviewed by the OSTIidentified appropriate causes. Issues that should be addressed prior to restart were identified and being tracked for completion.
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| Self-Assessment Proarams The team concluded that the self-assessment programs are functioning well and are identifying and dispositioning issues which affect plant and personnel performance. The self-assessments were timely and self-critical. Management oversight ensured corrective actions initiated by the self-assessments were taken in a timely manner.
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| Self assessment performance indicators prepared by the line organization were generally consistent with those prepared independently by the Nuclear Oversight Organization and were consistent with NRC inspection findings.
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| Independent Oversicht The Nuclear Oversight Restart Verification Plan provides effective independent assessment and performance measures for resolution of the Key issues. The Nuclear Oversight Organization's involvement in operations, maintenance / surveillance and engineering has been satisfactory.
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| The Nuclear Oversight Organization's reporting mechanisms to line management provided an effective means of capturing conditions adverse to quality and ensuring that those conditions were corrected. The reports were critical assessments and adequately provided senior management with a useful " snapshot" of plant performance and areas requiring additional attention.
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| The operational startup support organization did not provide effective oversight of plant activities during the two events that occurred during plant heatups. The licensee independently reached a similar conclusion and took corrective action to improve the Startup and Power Ascension Plan.
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| Quality Review Committees The conduct of the Plant Operations Review Committee (PORC), Site Operations Review Committee (SORC), Nuclear Safety Assessment Board (NSAB) met regulatory requirements and provided appropriate oversight of plant operations. At the conclusion of this inspection, there were no outstanding PORC or SORC items that would adversely affect plant restart. The NSAB was providing effective independent oversight.
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| Trainino Proarams The overall implementation of the systems approach to training for the technical training programs has improved and is adequate to ensure continued qualification of technical and non-licensed personnel.
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| OPERATIONS Operational Events- Two operational events occurred during the initial plant'heatup to mode 3. The events were an inadvertent opening of a pressurizer power operator relief valve and an automatic initiation of the auxiliary feedwater system caused by a low-low steam generator level.
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| . There were also three. failures to meet Technical Specification requirements including: (11-not having the required number of operable reactor coolant system loops while in Mode 4;
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| - (2) the failure to record pressurizer temperature data during ~a plant heatup; and (3) the failure to complete a conditional surveillance requiring a dilution path valve alignment check
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| with one shutdown margin monitoring channel out-of-service. While there were no safety consequences as a reruit of these events, the performance by some plant operators during
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| ..the initial plant heateps was weak.
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| The team conducted an independent evaluation of these events. The team and the licensee deterrained that these events indicated ' weaknesses in several areas. These areas include a lack of specific operator knowledge, attention to detail, procedural adherence and control board awareness. - The licensee initiated an Event Review Team (ERT) to evaluate these events. Based on the ERT findings, several corrective actions were taken including _
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| additional classroom and simulator training, reinforcement of management expectations regarding the safe plant operation, a mentor for one Unit Shift Supervisor, and more clearly defined oversight responsibilities for the Startup Duty Manager. The team observed the
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| . implementation of many of the corrective actions during the inspection. A formal root cause evaluation of these events had not been completed at the conclusion of this inspection. The OSTI concluded that the formal root cause evaluation and corrective actions to address any additional weaknesses in operator performance should be completed prior to restart.
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| Conduct of Onorations During the periods of direct team observation, the licensee safely operated the plant.
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| Operation's staffing levels were adequate. Operators rarely worked excessive overtime; however, working overtime during the outage was routine with the operating crews afforded only a few days off. Operator log keeping was adequate; however, in two instances, incomplete logging contributed to operational events. The operators' threshold for identifying deficiencies was generally good with a few exceptions noted.
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| Procedures and Procedure Adherence The team concluded that the quality of plant operating procedures was generally good.
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| With a few exceptions,' the procedures reviewed by the team were technically accurate l and provided an appropriate level of detail. Risk significant operator actions were adequately proceduralized. However, the team identified two instances where the-administrative control of procedures was not in accordance with technical specifications
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| (TS). In one case, a procedural deficiency was a contributing cause to missing the TS iv i
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| requirement to have two operable reactor coolant system loops in Mode 4. The licensee took effective corrective action to address these issues prior to the conclusion of the OSTI.
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| While the team found that operators generally adhered to procedures, the team identified a few exceptions where procedures were not precisely followed. In one case, the failure to follow the procedure resulted in the inadvertent opening of the pressurizer power operated
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| ' relief valve (PORV). During the OSTI, plant management reinforced their expectations for procedural adherence with plant operators.
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| Ocarator Training The team concluded that requalification training was adequate to support plant restart.
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| Each licensed operator was current in completion of requalification training and had passed required examinations and evaluations. Operations management was effectively involved in training. A weaknesses in specific operator knowledge was noted as the cause for the inadvertent opening of the PORVs. The licensee conducted focused training for alllicensed operators to address this knowledge deficiency. Fire Brigade staffing and training were adequate.
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| Eauioment Configuration The team found that the licensee's corrective actions for past equipment alignment problems have not been fully effective. The team identified several problems with the administration and control of the plant equipment alignment program. These problems included components not properly aligned, inadequacies in the valve and breaker lineup process, and deficiencies in the locked valve program. The team concluded that corrective actions to address these deficiencies were necessary prior to plant restart. The licensee was developing corrective actions to address these deficiencies at the conclusion of the OSTl.
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| The team determined that the safety tagging process was adequate and functioned as designed to improve personnel and equipment safety. The existing operator work-arounds and control room deficiencies did not impact safe operation of the facility.
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| Command and Control The team found the quality of command and control to be generally good with a few occasionallapsss. Shift turnovers were typically comprehensive. The quality cf prebriefs was comprehensive with some variations . Operators were generally cognizant of plent conditions and control room annunciator status. Operators appropriately controlled access to the control room. Operations management was actively involved in operational
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| activities. Plant support to operations was generally good.
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| ENGINEERING AND TECHNICAL SUPPORT Plant Modifications v
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| The plant modification program was appropriately controlled and implemented. ' The team found the design control process provided a detailed and comprehensive method for -
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| implementing plant design change activities. Modification package content, including the screening and safety reviews, were generally appropriate. Post-modification testing encompassed verification of important design change attributes. The licensee had adequate commercial grade dedication and item equivalency evaluation (like-for-like equipment replacements) programs in place to support plant restart.
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| The number of installed temporary modifications (TMs) was low and plans existed to further reduce the number of TMs. The TM process provided adequate controls to ensure that TM installation would not adversely impact plant un.sration.
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| Plant Technical Suonort l The Engineering and Technical Support Departments were providing timely and effective support to the line organizations. The Engineering Department managed the day-to-day work activities well. Daily prioritization at the morning meeting and by the management review team (MRT) set appropriate priorities for system and design engineering resources.
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| The technical support organization was observed to provide good support for emergent plant hardware failures by leading Event Review Teams (ERTs).
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| The use of the Condition Reports (CRs) to document issues needing engineering evaluation was appropriate. A review of open CRs determined that the CRs had been properly screened and no additional items were identified as needing resolution prior to restart. The system readiness reviews, completed by the Technical Support Department, were comprehensive and did an effective job in identifying issues requiring resolution prior to restart.'
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| The team conducted several safety-related system walkdowns and discussed the system status with the appropriate system engineers. The team found the system engineers were knowledgeable and the material condition of plant equipment was generally good.
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| 'The OSTI also reviewed the open operability determinations and found them generally well developed and providing adequate justification for operability of the system or component affected degraded condition.
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| Enaineerina Proarams The team noted that the licensee was making improvements in several engineering admhntered programs such as setpoint control, operational expenience reviews and vendor manuals. The setpoint control process was adequate and meets industry standards. The operating experience program was functioning adequately to support restart. The licensee has initiated efforts _to maintain the accuracy of vendor manuals and is taking appropriate actions to upgrade the key safety-related manuals and review affected procedures prior to restart.
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| Nuclear oversight and engineering self-assessment activities, including engineering assurance, provided good observations to improve performance.
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| MAINTENANCE AND SURVEILLANCE Plant Material Condition The plant material condition was generally good. The housekeeping practices and equipment storage were observed to be good. The team determined that processes were in place to maintain a satisfactory level of plant material condition. The backlog of open maintenance work activities was trending down, had been prioritized, and the overall impact on operations was assessed and found to be acceptable.
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| Preventive Maintenance In general, the team found that the preventive maintenance (PM) program was acceptable.
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| However, the team noted a few minor deficiencies in the PM program that the licensee addressed during the inspection.
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| Conduct of Maintenance Activities The team observed that procedure adherence by the maintenance staff was good. The team observed several instances where work was stopped to clarify or revise maintenance procedures. The maintenance workers were knowledgeable of assigned maintenance tasks and had received appropriate training. Maintenance supervisory oversight in the field was strong. The Fix It-Now (FIN) team had a positive impact on handling emergent work and reducing the automated work order (AWO) backlog.
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| Plannina and Schedulino The adherence to plant schedules has been poor. On average, only 60% of work orders on the 3-day look ahead schedule were started and 54% were completed on schedule. The scheduled dates for achieving major milestones, such as mode changes, were rarely met.
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| The difficulty in meeting schedules was attributed to several factors including emergent issues, inability to identify work scope, and lack of accountability to meet schedules.
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| The team did not find any examples where inefficiencies in planning and scheduling resulted in degradation of safety system performance. In fact, the team concluded that the material condition of safety-related systems was generally good. The corrective
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| ; maintenance automatic work order backlog has been reduced to manageable levels and is | |
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| nearing the licensee's restart goal of 500 open work orders. The team also did not observe non-conservative decisions by plant management for the sole purpose of meeting l unrealistic plant schedules.
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| The surveillance testing program was adequate to support plant restart. The team concluded that the surveillance test procedure quality was adequate. Tests required for restart have been defined and satisfactory progress is being made to complete these tests.
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| OVERALL OSTI CONCLUSION The OSTI findings are one input of many to be used by the Nuclear Regulatory Commission (NRC) Hastart Assessment Panel (RAP) in making a restart recommendation to the Commission. The OSTI has determined that plant hardware, staff and management programs, at Millstone Unit 3, are ready to conduct a safe plant restart and continued operation. The OSTI conclusion is contingent upon the successful completion of the items identified by the licensee as required prior to restart and the implementation of appropriate corrective actions for the OSTI fincings regarding operator performance and system valve alignments.
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| i TABLE OF CONTENTS EX EC UTIVE SU M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii 1. Mannaement Proarams & Oversiaht . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 S1 M a n ag e m e nt Prog ram s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 S1.1 Manaamment Processes ................................... 1
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| t S1.2 Performance lmorovement Plans ............................. 3
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| S1.3 Organizational Communications and Teamwork . . . . . . . . . . . . . . . . . . . 4 l S2 ' Corrective Actions ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 S3 Self-Assessment ............................................. 9 .
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| S3.1 Performance Indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 S3.2 ' Self-Assessment Proarams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 S4 Independent Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 S4.1 Nuclear Oversiaht Restart Verification Plan (NORVP) and Nuclear Oversiaht Effectiveness
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| ................................................... 12 S4.2 Nuclear O versicht Reoorts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 S5 Quality Review Committees .................................... 14 S5.1 Plant Onerations Review Committee (PORC) and Site Ooerations Review Com mittee (SO RC) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 S5.2 Nuclear Safety Assessment Board (NSAB) ..................... 15 S6 Training .................................................. 15 S7 St a rt u p Pl a n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 I I . One r a tio n's . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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| . 02 Proc ed u re s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 03 Training and Qualifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
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| - 04 Plant Eq uipment St atu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
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| : 05 Command an'd Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
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| - I ll . Enain eerina . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 ix
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| E1. Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 i E1.1 Temocrarv Modifications ................................. 36 i l E1.2 PermaneDt Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37. )'
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| E1.3 Deferred Modification Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 E2 Plant Technical Support ....................................... 39 E2.1. Operability Determinations ................................ 39 E2.2. Enaineerina and Technical Sunoc;r Effectiveness . . . . . . . . . . . . . . . . . 41 E3 Enainee rina Proaram s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 ;
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| F3.1 Vendor Manual Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 E3.2 Setooint Co ntrols . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 E3.3 Eauioment Qualification .................................. 47 E3.4 Ooeratina Exoerience Proaram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 IV. Maintenance and Surveillance ..................................... 49 i M1 Conduct of M aintena nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 M2 Maintenance Planning and Scheduling ............................. 53 M3 Plant M aterial Condition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 M4 Preventive Maintenance Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 M5 ' Surveillance Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 V. M anagement Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 x
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| =REPORT DETAILS=
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| The objective of the Operational Safety Team inspection (OSTI) was to provide current
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| information to the Restart Assessment Panel by evaluating the readiness of plant-hardware, staff, and. management programs to support a safe restart and continued operation of Millstone Unit 3. The OSTI observed operations at Unit 3 over a 23 day period which included an intensive 2 week inspection activity conducted during April _13;-
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| 24,1998. ,The
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| ===.14 inspectors were selected from all 4 NRC Regional Offices, Office of ;===
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| Nuclear Reactor Regulation (NRR), Office for Analysis & Evaluation of Operational Data
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| .(AEOD), and Special Projects Office (SPO). The OSTI (team) monitored licensee activities during plant transition between operational modes, both during normal and off-normal work
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| : hours.- This inspection represents over 1500 hours of direct inspaction effort. 3 The OSTI
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| . performed an independent, broad scope assessment in the areas of management programs and oversight, operations, engineering and technical support, and maintenance and surveillance. The OSTI used selected sections of NRC Inspection Manual Procedure 93802, " Operational Safety Team inspection," to conduct this inspection.
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| 1. Management Programs & Oversight
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| $1' Management Programs S1.1 ' Manaaement Processes a.
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| Insoection Scone
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| - The team reviewed records, procedures and performance measures and interviewed -
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| licensee management and staff to determine the adequacy of the management team ]1 to provide direction, standards, and expectations to the plant staff.
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| Observations and Findinas Standar'ds and Expectations Efforts to raise performance standards were evident. Written safety standards were l revised and management conveyed expectations for meeting these standards by the statements they made and the examples they set at meetings and other interfaces ;
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| with the staff. A few practices tolerated by management were inconsistent with I established standards but overall, appropriate standards and expectations for safety were established by senior management, and these standards and expectations
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| were understood by subordinate managers and staff.
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| ;z Plannina and Direction i
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| Appropriate goals were identified in the Unit 3 Operational Readiness Plan (ORP) as key issues to be addressed prior to Unit 3 restart, individuals were assigned to manage corrective actions for each issue and assigned individuals were well aware
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| ]j of their responsibilities.' The Nuclear Oversight Restart Verification Plan (NORVP) j
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| was' established to independently assess performance in each key area on a I
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| i biweekly basis. Management effectively used this process to focus attention on areas needing improvement for restart.
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| | | - |
| ' Planning for post restart activities was incomplete. The focus of management was on recovery and restart of Unit 3 to the extent that the goals and oversight -
| | ' |
| processes needed to guide the organization following restart had not been developed. The Nuclear Group had not issued vision or mission statements nor completed the development of a strategic plan for Unit 3 operation. Post-restart performance measures had not been established and the amount of work in Unit 3 backlogs was not fully understood.
| | . |
| | | Mr. M. cc: |
| ! Probability Risk Assessment The Probability Risk Assessment (PRA) staff routinely reviewed each design change before it was accomplished and PRA insights from these reviews resulted in changes to reduce risk. A procedure was established for PRA review of scheduled on-line test and maintenance evolutions during shutdown and at power conditions.
| | B. Kenyon, President and Chief Executive Officer - Nuclear Group M. H. Brothers, Vice President - Operations J. McElwain, Recovery Officer - Millstone Unit 2 J. Streeter, Recovery Officer - Nuclear Oversight P. D. Hinnenkamp, Director - Unit 3 J. A. Price, Director - Unit 2 D. Amerine, Vice President - Human Services E. Harkness, Director, Unit 1 Operations J. Althouse, Manager - Nuclear Training Assessmeat Group F. C. Rothen, Vice President, Work Services J. Cantrell, Director - Nuclear Training (CT) |
| | | S. J. Sherman, Audits and Evaluation cc: w/ copy of Licensee's Response Letter L. M. Cuoco, Esquire J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN) |
| The team noted that the risk associated with maintenance activities was not assessed while the plant was in transitional modes (Modes 2-4). A risk assessment of scheduled off-line outage activities was begun for transitional modes during the OSTI inspection. The team determined the licensee had effectively incorporated PRA insights into some plant activities.
| | R. Bassilakis, CAN J. M. Block, Attorney, CAN S. P. Luxton, Citizens Regulatory Commission (CRC) |
| | | Representative T. Concannon E. Woollacott, Co-Chairman, NEAC |
| Involvement The Unit 3 Director was observed to be personally involved providing direction and feedback to subordinate managers on important activities. Operations and maintenance management interfaced frequently with subordinates through job-site tours and meetings. A Unit 3 Operations Department Work Observation Program assured that Operations Department managers performed regular observations of i ongoing work. Involvement of engineering management for a few observed activities, was less evident. For example, engineering management provided limited direction for addressing turbine-driven auxiliary feedwater pump problems encountered during startup. A new system engineer was assigned to resolve safety significant problems with little apparent direction or support.
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| | |
| The OSTI has determined that plant hardware, staff and management programs, at Millstone Unit 3, are ready to conduct a safe plant restart and continued operation.
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| | |
| molovee Concerns Managers expressed strong support for plant personnel identifying problems, and their subordinates expressed no reservations regarding their ability to identify problems . These findings were consistent with the low threshold for problem '
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| identification that was evident from the number and nature of problems documented in Condition Reports (CRs) and were also consistent with the findings in NRC Inspection Report 50-423/97 82.
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| _ - _ . - _ - _ _ _ _ _ _ _ _______ _ ____ _ __ _ | |
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| . _ _ _ - _ _ _ - _ _ - - - _ - - - - _ _ _ _ - _ _ _ - _ - _ - _ - - -
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| Staffing The amount of cvertime worked was not excessive and was controlled in accordance station procedures that were consistent with NRC guidelines. Licensed operator staffing in the control room met the requirements of Technical Specifications.' During recovery, the licensee relied heavily on contractor support
| |
| -
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| for engineering design and for oversight of recovery activities associated with NORVP, A plan was being developed for reducing contractor support as recovery work was completed. The backlog of NRC commitments and other work to be completed prior to restart was trending downward at a reasonable rate.
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| | |
| Integration of Quality Assurance To determine if quality assurance was effectively integrated into the line organization, the team reviewed licensee programs for self-assessment and !
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| corrective action, and evaluated the performance of quality review groups. As .
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| " discussed in more detail later in this report, performance in these areas was 1 satisfactory.
| |
| | |
| ====c. Conclusions====
| |
| . Appropriate standards and expectations for safety were established by senior management and were understood by subordinate managers and staff. Planning ') | |
| and direction for the restart and recovery of Unit 3 were effective. Effective
| |
| _
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| leadership was provided and management involvement in routine activities and g emerging issues was adequate. Staffing was adequate for recovery and restart.
| |
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| !
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| The application of PRA insights to design and operation of the piant were adequate.
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| Integration of quality assurance into the line organization was effective.
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| These findings provide the team's basis for the closure of Restart Assessment Panel j
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| '
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| (RAP) items C.2.1, a. Goals / expectations communicated to staff; C.3.1, c. Staff understands management expectations and goals; and C.1.4, f. Effectiveness of PRA usage.
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| -S1.2 Entformance Improvement Plane ,
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| a.
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| Insoection Scone l
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| The team evaluated the licensee's performance improvement process by assessing i i.
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| | |
| the adequacy of the various line organization Performance improvement Plans (PIPS).L The team reviewed a sample of the PIPS from Engineering, Operations, and Maintenance, and discussed the implementation of these plans with line management.
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| | .. .- _ _ . -- _ _ _ _-_ - ___ _ _ - _ _ _ _ _ _ |
| | * |
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| | .;; |
| | Mr. M. l Distribution w/cv of licensee ra=aanse letter: l t |
| | Region i Docket Room (with sney of concurrences) |
| | Nuclear Safety Information Center (NSIC) |
| | ! PUBLIC I |
| | . FILE CENTER, NRR (with Oriainal concurrences) i SPO Secretarial File, Region I i NRC Resident inspector i B. Jones, PIMB/ DISP - |
| | W. Lanning, Deputy Director of Inspections, SPO, RI H. Miller, Regional Administrator, RI - |
| | J.~ Andersen, PM, SPO, NRR |
| ' | | ' |
| , - b. . .. Observations and Findinas u
| | M. Callahan, OCA R. Correia, NRR ' |
| I ____________________________;
| | B. McCabe, OEDO |
| | | . S. Dembek, PM, SPO, NRR i E. Imbro, Deputv '0irector of ICAVP Oversight, SPO, NRR ; |
| _ _ _ - _ - _ _ - _ _ _ - _ - _ _ _ _ - _ _ .
| | D. Mcdonald, PM, SPO, NRR I W. Dean, Project Directorate, NRR |
| | | ..P. McKee, Deputy Director of Licensing, SPO, NRR S. Reynolds, Chief, ICAVP Oversight, SPO, NRR D. Screnci, PAO Inspection Program Branch (IPAS) |
| __ _ - _ - ___ _ _ _ ____ __ ___ ____-_-__ _ .-_ __- ._ --__-_- ___
| | ! |
| The team determined that the PIPS provided a useful framework for addressing performance improvements for the line organizations. Plant management's commitment to improving Unit 3 performance is evident from the performance
| | i l |
| ' improvement plans. = However, there does not appear to be an accountability for-completing these plan objectives within'a specified time frame. ' The implementation of PIPS with respect to the key restart readiness issues does not appear to be well defined. Overall the team determined that the PlPs are not a useful direct measure of plant restart readiness. In at least two instances (e.g., Engineering, Maintenance) the PIPS were not kept current or completed due to competing
| | l L DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\97-83.RPY l- To receive a copy of this document, indicate in the box: "C" = Copy without |
| ;. | | ! |
| | attrchment/ enclosure "E" = Copy with attachment / enclosure "N" = No copy |
| | ' |
| | l OFFICE Rl/DRP l Rl/DRP _ |
| | / l l |
| | ;. NAME BLUMBERG/db DURR % ), |
| | L DATE pfjg/f7 08/ /98 08/ /98 08/ /98 OFFICIAL RECORD COPY i |
| | I' |
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| priorities with the' other initiatives such as the Configuration Management Program
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| ( and changes in management focus. | | , |
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| | It Northeast none rerry na. (noot 136), witerrora, er 06383 l |
| | C ar beg Millstone Nu-lear Power Station Northeast Nuclear Energy Company P.O. Box 128 j Waterford. Cr 06385-0128 l (860) 447-1791 l Fax (860) 444-4277 |
| | 'Ihe %rtheast !!tilitics System JUL I 31998 Docket No. 50-423 B17261 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 3 NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83 Reply to a Notice of Violation |
| | * By letter dated June 12,1998 the Nuclear Regulatory Commission transmitted the results of the above referenced inspection. The letter included a Notice of Violation citing six areas where Northeast Nuclear Energy Company's (NNECO's) activities were not in compliance with Nuclear Regulatory Commission regulations. |
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|
| In lieu of the PIPS, the licensee's focus for ensuring restart readiness was centered around the implementation of the NORVP and the " Windows" Department Readiness Assessments. These assessment techniques appear to be providing a very useful direct measurement of plant restart readiness. The NORVP is the principle tool used by management to' ensure the key issues identified for restart are being satisfactorily accomplished. Each of the key issues are assessed based on a set of attributes derived from major source documents. Input for the assessment is based on the various Nucleur Oversight inspection and observation mechanisms. In addition to the NORVP, each line organization has implemented the windows readiness assessment tool to evaluate key performance criteria within their disciplines. The input for these readiness reviews is derived from the various self-assessment techniques employed by the unit.
| | Attachment 1 provides a summary cf NNECO's commitments cc.itained in this submittal. Attachment 2 provides NNECO's response to the Notice of Violation items. |
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| c.
| | As stated in the individual responses, corrective actions have been taken to restore ! |
| | compliance. The cause for the majority of the violations was due to the organization i being in a " recovery mode" for the past two years and not in an " operational mode". |
|
| |
|
| Conclusion The team concluded that the PIPS were not a very useful mechanism for assessing plant restart readiness. Due to competing priorities with the other initiatives such as the Configuration Management Program and changes in management focus, PIPS
| | The corrective actions that we have identified will provide the organization with the operational focus that is needed to safely operate the unit. |
| - were not always kept current or used as a direct measure of restart readiness.
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| Plant management implemented additional mechanisms, including the NORVP and Windows assessment tools, co s:sess restart readiness. The team concluded that these were effective mechanisms for nianagement to assess restart readiness.
| | ) |
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| These findings provide the team's basis for the closure of RAP item C.3.1, a.
| | Should you have any questions regarding the information contained herein, please ; |
| | contact Mr. David A. Smith at (860) 437-5840. |
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| Demonstrate commitment to achieving improved performance.
| | l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY |
| | $ |
| | Martin L Bowling, Jr.V , |
| | Recovery Officer - Technical Services l Attachments (2) |
| | oum. mum nM9 /1/51A Y lb)$ |
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| S1.3 Organizational Communications and Teamwork I a.
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| Insoection Scone in the areas of Organizational Communications and Teamwork, the team assessed
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| - the following:
| | l l U.S. Nucl=r Regulatory Commission B17261\Page 2 l |
| : (1) the effectiveness of organizational communications and
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| teamwork, including inter-departmental relationships and interfaces by evaluating meeting effectiveness including priority and goal setting, and assessing interdepartmental teamwork, and
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| : (2) ability of plant management to convey their
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| a ---- -- - - _ _ -----_-- _ - . , - - _ _ - - _ _ _ - _ _ _
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| expectations for safe plant operation by observing plam personnel performance and evaluating staff's understanding of both written and verbal expectations. The assessrr.ents were performed by conducting numerous interviews, attending meetings regarding management reviews, event review briefings, daily plant status briefings, plant restart readiness reviews, and observing plant personnel performing activities. Interviews were conducted with representatives from plant management-and supervisory levels and staff members within the organization.
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| b. Observations and Findinas Communications Licensee management used a variety of methods to communicate and reinforce their expectations for safe plant operation. For example, daily newsletters were published on items of current interest, posters outlining the management expectations underlying work activities were prominently displayed, and both formal
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| : pre-planned and impromptu meetings were conducted daily by individual line organizations and collectively by line organization managers and supervisors. In addition, managers and supervisors participated in routine observations of control room and plant activities.
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| I The information presented in the daily pre-planned management meetings was j prescribed by the Shift Managers and Planning and Scheduling Manager, with each additional department head presenting department specific information. - Senior Plant Management presence at these meetings was evident with their focus on goal setting and ensuring expectations for safe plant operations was reiterated. The team observed that management expectations were further reinforced by discussing condition reports (CRs) and human performance errors during the licensee management meetings and event review team debriefs. In addition to the management meetings, each line organization had separate debriefs to discuss the issues rais3d at the management meetings, review scheduled activities, and when needed, discuss events and operating experience reviews.
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| Generally communication and implementation of management expectations for coordination of activities, performance of evolutions, role of management oversight, and status coordination of pending issues was observed by the team as being accomplished in a manner consistent with those expectations. However, in a few instances, the team observed performance that was inconsistent with these expectations. For example:
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| .
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| . Managers and supervisors were not always providing timely status reports of work in progress to support the restart schedule. An example was the identification of the status of the Three Mile Island action item project as not meeting the scheduled completion date only two days prior to that scheduled
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| - date.
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| p u
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| .- -
| | cc: H. J. Miller, Region i Admir.istrator W. D. Lanning, Deputy Director, inspections, Special Projects Office J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 5 |
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| | ! W. D. Travers, Ph.D., Director, Special Projects Office |
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| >
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| - Management observations of control room operations during the mode
| | ! |
| . escalation was not performed per senior management expectations. This weakness was a contributing cause to the engineered safety feature actuation event on April 11,1998.
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| The team observed that plant management took appropriate and timely actions to correct these weaknesses, by reiterating formal written expectations for management observations of control room activities, and directing the required manpower resources to' support the Three Mile Island action item project.
| | L-_----____-__-______________________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ |
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| Intra- and inter-Organizational Teamwork The inter-department and intrwepartment communication mechanisms are generally good. A variety oi both formal and informal communication processes are in place to facilitate timely communications. The various line organizations appear to be employing teamwork strategies to address both emergent and long-standing issues at the site.
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| | Docket No. 50-423 B17261 j |
| | Attachment 1 Millstone Nuclear Power Station, Unit No. 3 |
| | ' |
| | Summary of Commitments NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83 |
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| The managers and supervisors meetings held each morning and afternoon were effective in assessing the progress made in the past 24 hours and establishing new priorities based on that progress. Assignments made during the meetings were clear and management expectations were frequently reinforced. Teamwork was stressed with significant efforts to coordinate interdepartmental activities, particularly in the morning planning meeting.
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| | July 1998 |
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| The team observed several meetings and found them well run, with the necessary personnel available to make key decisions in a timely manner. | | . . . i |
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| | . . |
| | U.S. Nuclerr Regul: tory Commission B17261\ Attachment 1\Page 1 List of Regulatory Commitments |
| | ) |
| | The following table identifies those actions committed to by NNECO in this document. |
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| During the inspection period, a few minor weaknesses in communication and teamwork were observed which created a challenge for planning and scheduling and plant operations. For example, a lack of coordination between Maintenance and Operations during the main feedwater pump startup caused a significant delay in returning this equipment to service. The team observed management taking appropriate and timely actions to address these weaknesses and reinforce the expectation for being prepared to support work, ensure adequate manpower is available, and establish realistic schedules for required plant activities.
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| c.
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| Conclusion The team concluded that management expectations for safe plant operations were communicated, understood and followed by the plant staff. Senior plant management used a variety of communication methods to reinforce expectations.
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| Whern expectations for communication or teamwork were not t og met, plant
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| ; management took appropriate and timely actions to correct the weaknesses and reinforce expectations for safe plant operation and teamwork was observed among
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| : organizations
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| _
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| __ _ _ _ _ - _ _ - - _ - _ _ - _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ . - _ _ - - _ - _
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| l:
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| i These findings provide the team's basis for the closure of RAP item C.3.1 b.)
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| Demonstrated safety consciousness.
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| Corrective Actions
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| ====a. Inspection Scope====
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| The team reviewed the corrective action program and subordinate procedures, audit reports, independent Review Team report on the effectiveness of corrective actions, the NRC 40500 Inspection Team Report (IR 97-82), and outstanding corrective action items. The team conducted interviews and evaluated condition reports to-verify the adequacy of the corrective actions programs. The team observed the Management Review Team (MRT) and the Management Review Council (MRC) to
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| ! assess the quality and effectiveness of the Event Review Team (ERT) and root cause investigations. ! The team evaluated completed root cause investigation packages to assess the root cause determinations and methodology.
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| b.
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| Observations and Findinas identification Processes The corrective actions program has a low threshold for condition report (CR)identification and initiation, and the plant staff has been adequately trained in implementing the corrective action program. The evidence for this lies in the total numbers of CR's submitted to the corrective actions program. The corrective action plan for a CR that identified failures and weaknesst., in the corrective actions program was reviewed and discussed in interviews with the_ Corrective Actions Department. It was determined that the identified failures and weaknesses were corrected and are complete. The corrective actions program has demonstrated that it can successfully evaluate and prepare appropriate corrective action plans.
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| However, the team did see isolated evidence of the MRT and the MRC not pursuing the root cause(s) of the auxiliary feedwater pump turbine failures adequately. This was evidenced by observing the MRC and MRT meetings and the continued failures after corrective action was taken.
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| Root Cause Processes The team reviewed a sample of both on-going root cause investigations and completed investigation reports. The team found the level of detail and analysis
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| . varied with the makeup of the investigation teams. Examples of some misapplication of the analyses are from the following:
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| = The CR-M3 97-4789, " Multiple Work Control Deficiencies Observed by Performance Evaluation During Shop Balancing of 3SWP'P1C Pump Impeller," root cause investigation was performed to determine the causes for multiple procedural noncompliance identified by Nuclear Oversight. The'
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| _- . - _ - _ - - - _ = _ _ _ _ _ - _ - _ _ _ _ _ -
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| events and causal. factor chart was ineffective. The sequence of events was forced into event boxes to make the chart. The events did not describe a single action or happening, were not precisely described, were not quantified, nor labeled with the approximate time /date they occurred. The events and causal factor chart did not entirely support the stated root cause, "the root cause was determined to be a lack of understanding and
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| ._
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| appreciation as to the quality assurance aspects associated with the balancing process along with a lack of familiarity.with the requirements of the work control and procedural processes."
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| The M3-97-4680, "SWP'P1 A/B/C/D Hydraulic Performance Test Program has identified Errors and Weaknesses," root cause investigation was performed as a result of inservice testing (IST) engineering research information concerning the turbine driven auxiliary feedwater pump (3FWA*P2). The IST engineer was researching information for a question posed by a previous NRC inspection that the turbine driven auxiliary feedwater pump had not been tested to American Society of Mechanical Engineers (ASME) Code requirements. The identified root cause and the failure mode were not supported by the analysis. Attachment "a" change analysis was improperly used. The change analysis was used to list documents and rmtements as to whether the documents contain a reference to a variable speed pump. The barrier analysis of Attachment "b" did not clearly support the identified rou cause.
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| The Corrective Actions Department conducted root cause analyses in the past and
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| is now in the process of supporting and mentoring other departments in performing i departmental root cause analysis. All root cause investigation reports are reviewed and graded by the Corrective Actions Department, but the team found the grading .
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| criteria to be subjective.
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|
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| Procedure RP17 " Event Review Teams (ERT)" details that the ERTs are dedicated to investigating the issue, determining the root cause(s) of the event and the extent of generic implications, and recommending corrective actions. The Root Cause Investigation Report which contains the analyses is not completed until after the
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| ERT makes its presentation to the Management Review Team. During interviews
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| ( with the Corrective Actions Department management, it was agreed that the root cause analysis raay be used to support a pre-determined conclusion in the equipment failure evaluations. Although a few root cause analyses were
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| misapplied, the team did not conclude that the root cause determinations were -
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| !: . incorrect.
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| Backloa Manaaement and Action item Trendina and Trackina System (AITTS)
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| The backlog of open Condition Reports and Action Requests from the Action item Trending and Tracking System was reviewed for issues that should be addressed prior to plant restart. The team reviewed a sample of open CR's using AITTS to
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| ' determine the appropriate level assigned to the CR's. All CR's reviewed were
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| _ - - .
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| - - - -- - _ _ _ - - - - _ - _ - _ - - _ _ -
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| assigned at the appropriate level. Millstone Unit 3 has maintained a working level of approximately 300 open CR's over the past six months. The constant level is .
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| not expected to decrease until the CR initiation rate decreases. The number of open level one CR's was 24 and the number of level two CR's was 327. The team determined that safety significant issues were tracked to completion.
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| On March 17,1998, the licensee submitted the list of issues to be deferred until after restart to the NRC. ;This was the fourth in a series of periodic updates and was inspected by the NRC as documented in NRC Inspection Report 50-423/98-207. - The OSTI eviewed the additional items that the licensee determined could be deferred since the last submittal. The team determined that the process used to establish deferrals for the backlog open issues was commensurate with safety. The team identified no deferred items that should be completed prior to plant restart.
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| ====c. Conclusions====
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| - The overall corrective action program is adequate to support plant restart. Plant _
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| deficiencies are being included in the corrective action program and a timely resolution of safety significant issues are generally being met. Issues that should be addressed prior to restart are identified and being tracked for completion. No items were deferred that could impact a safe plant restart.
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| The team's assessment of management's oversight and implementation of Event Review Teams was that they were effective and root cause analyses were adequate.
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| - These findings, supplemented by the findings of the NRC 40500 inspection (NRC IR 97-82) and other sections of this report, provide the team's basis for the closure of RAP items C.1.3, c. Control of corrective action item tracking; C.1.3, d. Effective corrective actions for the conditions requiring shutdown have been implemented; C.1.3, e. Effective corrective action for other significant problems have been
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| ,mplemented; C.1.3, f. Control of long-term corrective actions; C.1.3, g. Effective
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| ' | | ' |
| r.orrective action verification process; C.2.1, f. Management's ability to identify and t
| | Please notify the Manager, Millstone _ Unit No. 3 Regulatory Compliance at the Millstone Nuclear Power Station Unit No. 3 of any questions regarding this document or any associated regulatory commitments. |
| prhritize significant issues; C.2.1, g. Management's ability to coordinate resolution
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| of significant issues; C.2.1, h. Management's ability to implement effective corrective actions; C.1.4, d. Effectiveness of deficiency reporting system: C.3.1, d. | |
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| Understanding of plant issues and corrective actions.
| | i Commitment Description Committed Date Number or Outage B17261-01 Revise DC 1, " Administration of Procedures and Complete Forms", to address the use of the " Temporary Change" process as described in the Technical Specifications. |
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| l l; iS3 ' Self-Assessment
| | B17261-02 Revise DC 4, " Procedure Compliance" to ensure Complete a procedure change is processed, if required, prior to recommencing the performance of a task |
| - S3.1 Performance Indicators
| | ; or evolution that was stopped due to instructions appearing to be inadequate, the occurrence of unexpected results, or the task or evolution could not be performed as written. |
|
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|
| ====a. Inspection Scope====
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| Procedures and records were reviewed and members of the plant staff and management were interviewed to assess the validity of licensee performance n .
| | B17261-03 Revise Procedure RP-4," Corrective Action Complete Program", to ensure the proper level of apprc. val l is provided for the extension of any corrective actions to prevent recurrenca. |
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| . - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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| measures, and to assess the effectiveness of self-assessment and self-improvement programs.
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| b.
| | The following commitments were previously provided in re!ated Licensee Event ( |
| | Report (LER) submittals and are provided for tracking purposes only. |
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| Observations and Findinas The licensee measured performance using three sets of performance indicators: a
| | B17183-01 The Reactor Coolant Pump Operability Procedure |
| -weekly Unit 3 Key Performance Indicator (KPI) Report measured task status and organizational performance in key functional areas, the biweekly NORVP Report-measured restart readiness, and a quarterly Performance Annunciator Panel Report integrated much of the same data used for the weekly KPI Report.
| | ] |
| | Complete |
| | ; (OP3601D.1) and Surveillance Forms acceptance criteria have been revised. |
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| . As of April 3,1998, NORVP Reports indicated improving performance for most of the 22 key issues monitored and " improvement needed " in the four areas nf Engineering, Work Control / Planning, Materials, and Safety Conscious Work Environment. The licensee considered performance in all areas acceptable for restart.' The evaluations' appeared to have been made objectively and results were consistent with NRC inspection findings. Management attention was focused in areas where improvement was needed.
| | B17183-02 Training has been conducted for Operations Complete crews on Technical Specification 3.4.1.3 requirements. |
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| KPl Reports measured performance in about 50 functional areas against established
| | B17183-04 A briefing has been provided to the Operations Complete Procedure Group to provide management's expectations of clarity and level of detail in surveillance acceptance criteria. |
| - goals. Measurements were based on objective data and appeared to be valid. Most performance goals were appropriate but, a few were not sufficiently challenging to meet the high performance expectations expressed by senior management and, in a
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| . few cases, assessments of data appeared to rationalize performance which failed to
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| ' meet goals. For example, in the KPI Report dated April 9,1998:
| |
| * The goal for the number of Level one CR's open for 120 days or more was to have the number decline. The amount of decline was not specified and a very slight decline was judged to meet management's expectations.
| |
| * The goal for the timeliness of Level 1 and 2 CR evaluations was that the average time to complete evaluations was less than 30 days. The goal was met even though 16 percent of the CR evaluations were late.
| |
| * Performance in the area of CR identification was judged satisfactory even though the goal to have less than ten percent of CR's externally identified was exceeded and the trend was in the wrong direction.
| |
|
| |
|
| - The measurement and goal for overdue CR corrective actions did not take due date extensions into account.
| | B17183-05 A briefing has been provided to Operations crews Complete on expectations regarding verification of |
| | | , information and performance of electrical line-ups, proper use and satisfaction of acceptance criteria and the need for surveillance validation. - |
| *- Data and analysis for maintenance indicators was not current.
| | l |
| | | , |
| ;.
| | ;- |
| | |
| Managers were using KPl results to focus attention on the areas requiring the most
| |
| . improvement.~
| |
| -
| |
| .
| |
| - . - _ _ - - _- - - _ _
| |
| Performance Annunciator Panel Reports used criteria developed by the line organization to classify performance into one of four (red, white, yellow, or green)categories. Performance in over a hundred areas was integrated into 14 Department indicators and a single Restart Readiness indicator. Although many of the assessment criteria were somewhat subjective, the process was a useful self-
| |
| ,
| |
| assessment tool and, since performance was assessed in areas corresponding to organizational alignment, the process facilitated organizational accountability.
| |
| | |
| ) | |
| Appropriate issues were identified in the Unit 3 Operational Readiness Plan as key issues to be addressed prior to Unit 3 restart. Individuals were assigned to manage the development and implementation of improvements for each issue. Assigned individuals were well aware of their responsibilities. The NORVP was established and implemented to independently assess performance for each key issue. NORVP results indicated that improvement efforts were effective. As discussed above, NORVP results provided a valid measure of performance and indicated improvements for most of the 22 key issues monitored.
| |
| | |
| c.
| |
| | |
| Conclusion in general, the KPl and Annunciator Panel indicators prepared by the line organization, were consistent with those prepared independently by the Nuclear Oversight organization and the performance they reflected was consistent with that represented in NRC inspection findings. The KPl's provided management with objective information about management processes and were used to focus activities on areas requiring improvement. Managers interviewed were familiar with recent performance reports and said that they routinely used them to monitor the performance of their organizations.
| |
| | |
| S3.2 Self-Assessment Proorams a.
| |
| | |
| Insoection Scone The team evaluated the licensee's processes for performing self-assessments to ensure that they were effective in identifying and addressing safety significant issues which could impact plant restart. The team reviewed a sample of line organization self-assessments and recent line management observations, witnessed a management observation of maintenance activities, conducted various interviews with plant management, line organization supervisors, and the Unit 3 self-assessment coordinator, and' reviewed the data analysis methods in place to assess the self-assessment programs.
| |
| | |
| I b.
| |
|
| |
|
| Observations and Findinas The team determined that the self-assessment processes was functioning well. A wide variety of self-assessment tools are in place within line organizations, and assessments are being performed on a regular basis. The quality of self-assessments indicated that they were generally timely, critical of personnel l-E
| | _ - - - - - - |
| | _ _ - - _ - - _ _ _ _ - _ - _ _ - - - _ _ - - - _ - - - _ _ _ -___ _ |
| | , |
| | . |
| | . . |
| | U.S. Nuclecr Regulttory Commission B17261%ttachment 1\Page 2 Commitment Description Committed Date Number or Outage B17188-01 The Steam Generator Blowdown Sample Isolation Complete Valve 3SSR*CTV19C has been retumed to |
| | ' |
| | service so the normal path for sampling has been made available. |
|
| |
|
| __ _ - _ - - _ . - _ - _ _ - - _ _ .__ -_____ _ .
| | B17188-02 The Motor Driven Feedwater pump was re-tested Complete prior to heat-up. |
|
| |
|
| _ _ _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ _
| | B17188-03 Operating Procedure (OP3201), " Plant Heatup", Complete has been revised to place the Motor Driven Feedwater pump in service prior to exceeding 470 degrees F for the Reactor Coolant System. |
| l performance, and contained sufficient detail to be an effective tool for improving '
| |
| plant performance. The team verified that the self-assessments were conducted in accordance with administrative guidance (i.e., Unit 3 OA 11) and that condition l reports were initiated for significant issues identified through the self-assessment process.
| |
|
| |
|
| The program established to oversee the status and performance of self-assessment functions appears useful. The self-assessment coordinator routinely tracked the status of corrective actions associated with self-assessments. The team verified that the licensee was addressing the findings from their self-assessments in a timely manner. | | B17188-04 The Operations crews have received classroom Complete and simulator training on lessons learned from this event. |
|
| |
|
| '
| | B17188-05 The Unit Director and Assistant Unit Director Complete expectations for performing the heat-up/ start-up activities have been discussed with each Operating crew. |
| c.
| |
|
| |
|
| Conclusion The team concluded that the self-assessment programs are functioning well to identify and disposition issues which affect plant and personnel performance. The quality of the self-assessments was evidenced by the timely, self-critical nature of the reports. Adequate management oversight was provided to ensure that corrective actions were completed in a timely manner.
| | B17189-01 Shift personnel attended a training session with Complete Unit Management. Operations Manager emphasized his expectations for effective conduct of shift turnover / briefs, with an emphasis on heightened operator awareness and efficient time management associated with " active" Technical Specification Limited Condition of Operation action statement requirements. |
| | |
| S4 Independent Oversight S4.1 Nuclear Oversiaht Restart Verification Plan (NORVP) and Nuclear Oversiaht Effectiveness a.
| |
| | |
| Insoection Scoce The team reviewed procedures governing audits, surveillance and the NORVP process, reviewed NRC inspection findings and other performance data, and interviewed licensee representatives to assess the effectiveness of independent oversight provided by the Nuclear Oversight Organization. Nuclear Oversight audit findings were reviewed to determine that significant audit findings with potential plant restart implications have been resolved.
| |
| | |
| )
| |
| J b.
| |
| | |
| Observations and Findinas
| |
| !
| |
| Performance associated with each of several key issues was evaluated and j documented in oversight evaluation reports using a method that provided for consistency in measurements. Data from oversight evaluation reports were assessed using predetermined acceptance criteria and the results were provided to management in biweekly NORVP reports. Evaluations were made objectively and results were consistent with NRC inspection findings. Evaluation results were communicated orally and in writing to the line organization.
| |
| | |
| Through the NORVP process, the Nuclear Oversight Organization provided valuable independent feedback to station management on the status and quality of operations, maintenance, surveillance and engineering restart activities. Audits by l
| |
| _ _ _ _ _ _ _ _ . . _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
| |
| ;
| |
| Nuclear' Oversight provided comprehensive assessments in selected programmatic areas. Most produced performance-based findings that were of value for improving program effectiveness but, a recent audit of the corrective action program produced findings that were primarily compliance-based and thus of less value. Surveillance
| |
| : were typically performance-based and identified opportunities for improvement.
| |
| | |
| There was little evidence that managers of audit and surveillance programs worked together on a common oversight plan or strategy. Nuclear Oversight management said that this had previously been identified as a deficiency and that plans were being developed to improve performance in this area. Line managers from
| |
| . operations, maintenance and engineering seemed to respect the role of Nuclear Oversight and value their input as opportunities to improvement.
| |
| | |
| ' The team reviewed the Nuclear Oversight audit findings and determined that no .
| |
| findings with potential plant restart implications have been improperly dispositioned.-
| |
| | |
| ====c. Conclusions====
| |
| The NORVP provides effective independent assessment and performance measures for resolution of the Key issues. The Nuclear Oversight Organization's involvement in operations, maintenance / surveillance and engineering has been satisfactory. Line organization cooperation and support for Oversight activities was apparent. Nuclear Oversight audit findings are being properly dispositioned.
| |
| | |
| These findings provide the team's basis for the closure of RAP item C.1.4, h.
| |
| | |
| Review of applicable external audits.
| |
| | |
| S4.2 Nuclear Oversicht Reoorts a.
| |
| | |
| Scone of insoection The team evaluated the quality of the Nuclear Oversight reporting mechanisms to ensure that these reports were providing plant management with objective, critical assessments. The team reviewed a sample of Nuclear Oversight monthly reports, surveillance, audits, and Nuclear Oversight Restart Verification Plan (NORVP)reports, and conducted various interviews with line and senior management and Nuclear Oversight personnel.
| |
| | |
| l b.
| |
| | |
| Observations and Findinas
| |
| .The team determined that Nuclear Oversight reports are providing senior and line
| |
| !' management with useful information on plant performance and generally provide critical assessments. The Nuclear Oversight organization is employing a variety of assessment techniques (e.g., audits, observations, surveillance, reports) for gathering and communicating the plant performance. The team verified that adequate administrative controls (NOOP 4.02) were in place to direct performance of these assessment techniques. The team determined that the NORVP process w___= ___ _= - -
| |
| | |
| ,
| |
| was particularly effective in providing plant management with a useful indication of -
| |
| !!ne organization performance and identified areas requiring heightened management -
| |
| attention.
| |
| | |
| c.
| |
| | |
| . Conclusion The team concluded that the various reporting mechanisms employed by the Nuclear Oversight Organization provided an effective means of capturing conditions adverse to quality and ensuring that those conditions were corrected. The reports -
| |
| were critical assessments and provided senior management with a useful
| |
| " snapshot" af plant performance and areas requiring additional attention.
| |
| | |
| ,
| |
| S5 Quality Review Committees S5.1 Plant Ooerations Review Committee (PORC) and Site Ooerations Review Committee (SORC)a.
| |
| | |
| insoection Scone The quality and effectiveness of oversight provided by PORC and SORC was -
| |
| reviev.ed by the team. Open items for both committees were reviewed. SORC member qualifications and standards were reviewed.
| |
| | |
| b.
| |
| | |
| Observations and Findinos Plant Ooerations Review Committee PORC is responsible for the review of all Technical Specification (TS) required programs and procedures, except for common site procedures. The TS required programs include TS changes, plant modifications, TS violations, and reportable events. The PORC has been meeting several times a week rather than the TS minimum of once per month. The team observed PORC meetings comply with the TS requirements and the members were capable of conducting the TS required reviews. The PORC members were prepared for the issues on the agenda and asked technical questions of the presenters. The PORC meetings were conducted in a professional manner. Station expectations for the conduct of PORC were high, and during the inspection the station published management's expectations for conduct of presentations to PORC, A review of the PORC backlog indicated timely resolution of PORC issues. The team reviewed the PORC open items list and determined that, at the time of this inspection there were no open PORC items that would adversely
| |
| ,
| |
| _ affect plant restart.
| |
| | |
| Site Ooerations Review Committee SORC_ members were prepared for the issues on the meeting agenda and asked
| |
| , technical questions of the presenters. The members adequately represented the site-wide perspective of the SORC. The SORC is responsible to review all common
| |
| ~
| |
| t b -
| |
| , _ - - - - - - - - ----- ------_____ ______ ___________ _ _ __ _ _
| |
| | |
| _ - _ _ _ _ _ _ _ - _ _ _ _ - _ . . . . .
| |
| | |
| .
| |
| .
| |
| ..,
| |
| site programs and procedures including fire protection and proposed changes to TS Section 6.0. The SORC meets weekly rather than the TS minimum of once per every six months. The team reviewed and verified that the SORC member
| |
| . qualifications met the requirements. The team reviewed SORC backlog items and verified that there were no potential startup issues at the time of this inspection.
| |
| | |
| c..
| |
| | |
| Conclusion
| |
| .he PORC and the SORC meet the TS requirements. The PORC is capable of -
| |
| conducting the TS required safety reviews. At the time of this inspection, there were no outstanding PORC or SORC items that would adversely affect plant restart.
| |
| | |
| These findings provide th's team's basis for the closure of RAP item C.1.4, c.
| |
| | |
| Effectiveness of the licensee's Independent Review Groups.
| |
| | |
| S5.2 Nuclear Safety Assessment Board (NSAB)a.
| |
| | |
| Insoection Scone The quality of oversight provided by the NSAB was assessed by reviewing a sample of NSAB minutes, review of the backlog of recommendations, review of TS and applicable procedures, and attending several NSAB meetings.
| |
| | |
| b.
| |
| | |
| ' Observations and Findinas The team evaluated the effectiveness of the NSAB to provide independent oversight to the organization. The team verified that the NSAB met the requirements of Section 6.5.3, " Nuclear Safety Assessment Board," of the Millstone Unit 3 TS, and had procedures and processes in place to ensure continued compliance with those specifications. The team observed a NSAB full committee meeting, reviewed a sample of NSAB meeting minutes, interviewed the NSAB chairman and executive secretary, and reviewed a sample of the current NSAB action items. The team determined that the NSAB was maintaining an appropriate safety perspective, identifying safety significant issues, and had an adequate process to ensure these issues were being addressed. The team also verified the qualifications of the committee members with respect to the applicable procedures.
| |
| | |
| c.
| |
| | |
| Conclusion The team concluded that the NSAB was providing effective, independent oversight to the organization. Procedures and programs were established to' ensure the TS requirements for the NSAB would be fulfilled.
| |
| | |
| These findings provide the team's basis for the closure of RAP item C.2.1, d.
| |
| | |
| Effsetiveness of management review committees.
| |
| | |
| 86i . Training L
| |
| L>
| |
| !
| |
| L _ _ _ _ _ _ _ - _ - .__-_:___-__
| |
| 16 !
| |
| a. Insoection Scooe The team reviewed the non-licensed operator; electrical maintenance personnel; l mechanical maintenance personnel; instrument and control technician; chemistry technician; radiation protection technician; and engineering support personnel training programs to determine progress in the area of implementation of the systems approach to training (SAT). Also, communication and cooperation between the training and line organizations particularly in the area of program evaluation were examined. interviews were conducted within each area reviewed.
| |
| | |
| b. Observations and Findinos Trainina of Non-Licensed Plant Personnel The licensee has begun a process to ensure that trainers and supervisors understand the SAT process in sufficient depth to fulfill their implementation roles.
| |
| | |
| Additionally, the licensee has began training alignment validations, an effort to review all training materials for appropriate task links, learning objectives, performance standards, and test items before the next scheduled use.
| |
| | |
| The licensee also strengthened its communication and cooperation between the line organization and training organizations by revising their curriculum advisory committees to include training and the line organization down through the craft and technician level, interview results suggested that the attitude toward training has improved. Of particular note were the frequent comments related to the improved response from training on line comments related to improving training quality.
| |
| | |
| System Enaineerina Trainina 1 During the first week of the inspection, the team raised some potential concerns with the system engineering training program. Specifically, two issues regarding: (1)l the use of a SAT process for developing the system engineering program and the i
| |
| related Task Qualification Records (TORS), and
| |
| : (2) questions on the qualification of '
| |
| l system engineers to perform restart readiness reviews were identified. In response, the team conducted a detailed review of the issues by:
| |
| : (1) performing system
| |
| '
| |
| walkdowns and interviews with system engineers;
| |
| : (2) reviewing the TOR training j procedures, the system engineer's training qualification matrix, administrative controls governing the TOR process;
| |
| : (3) interviewing various engineering management and training department personnel;
| |
| : (4) reviewing the finding of on-poing root cause evaluation with the root cause team; and
| |
| : (5) verifying the approach the licensee used to align the TOR process to a SAT approach.
| |
| | |
| ,
| |
| The licensee had not conducted training alignment verification on the engineering program TORS because they believed TQRs are not considered on the job training or qualification since the level and complexity of the tasks for engineers are somewhat different from those of the various craft programs. The team reviewed the methods i used by the licensee to ensure the system engineering training was based on a SAT i
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ --
| |
| | |
| i approach. The team verified that the licensee had established and reviewed the TORS in accordance with Nuclear Training Manual NTM-7.202, " Engineering Support Training Program implementing Procedure," and had adequately verified that the TORS were based on the analysis of engineering support job tasks developed by the training organization via the use of the National Academy for Nuclear Training 91-017, Revision 1, " Guidelines for Training and Qualification of Engineering Support Personnel," dated December 1994. In addition, the licensee had initiated actions to address previously identified weaknesses in the system engineering program through various sources (NRC, NSAB, self-assessment) and has a long-term program for improvement of the training program which consisted of completion of the additional training modules for system engineering. The program will requira approximately one year for training material development and an additional two years for the system engineers to complete the training.
| |
| | |
| The licensee's Nuclear Oversight organization identified concerns related to the qualification of engineers who had been conducting system restart readiness assessments. A condition report, CR M3-98-0982, was issued noting that the qualification record of 4 of 5 engineers reviewed did not support that they were qualified to conduct the work they had been performing. In response to the CR, the '
| |
| licensee initiated a root cause analysis to determine current system engineering qualifications and to ensure that the restart readiness reviews were conducted by )
| |
| '
| |
| qualified individuals. The team verified that all of the system walkdowns were performed by the designated system engineers, and that they all had the requisite knowledge necessary to accomplish the associated tasks. The team interviewed various system engineers and determined that they were very knowledgeable about their systems and were generally well-aware of any condition reports or issues currently affecting their systems.
| |
|
| |
|
| l l | | l l |
| | r e |
| | ____ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ . - _ _ . . - |
|
| |
|
| ====c. Conclusions====
| | (,. |
| The overall implementation of the systems approach to training for the technical training programs at the Millstone site has improved and is adequate to ensure continued qualification of technical and non-licensed personnel to successfully perform in-plant work. Management has strengthened communicational teamwork between the line organization and the training organization.
| | ._ |
| | | . |
| S7 Startup Plans a. Snoan The team reviewed OP 3274, "Startup and Power Ascension Plan for Startup from Mid-Cycle 6 Outage," to verify that the plan included appropriate direction and
| | . I |
| '
| |
| oversight to support a safe plant restart and continued operation. The team also assessed the effectiveness of the startup and power ascension organization oversight during plant heatup activities, b. Observations and Findinas
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _
| |
| | |
| _ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _-
| |
| l OP 3274 described the approach and oversight planned for the startup and power ascension test program. In general, the plan provided detailed guidance on schedule, oversight, and startup organization staffing and responsibilities. However, the team l
| |
| determined that the management oversight provided by the startup organization I during the emergency safety feature actuation on April 11,1998 and the cycling of I the PORVs on April 12,1998 was ineffective in prevent:ng these events. The licensee had independently identified this weakness in the quality of oversight provided by the startup organization during their assessment of these events. The l
| |
| licensee's Restart Manager stated that the dual role of the Startup Duty Manager (SDM) being responsible for both schedule adherence and plant safety oversight
| |
| '
| |
| was not being effectively managed. In response to this concern, the licensee proposed splitting the responsibilities of the SDM into two positions. A new position of Senior Manager on Shift would be staffed during significant evolutions to focus solely on plant safety oversight. The scheduling and production responsibilities would be assigned to the Work Week Manager. These organizational changes had not been implemented at the conclusion of this inspection.
| |
| | |
| c.
| |
| | |
| Conclusion The team concluded that the licenses had developed detailed plans and an augmented organization for the plant startup. Nevertheless, the startup organization did not provide effective plant safety oversight during the two events that occurred during plant heatups. The licensee independently reached a similar conclusion and took effective corrective action to improve the Startup and Power Ascension Plan.
| |
| | |
| These findings provide the team's basis for the closure of RAP items C.4, g.
| |
| | |
| Adequacy of the power ascension testing program; C.4, c. Results of pre-startup testing .
| |
| II. Onerations Bsekaround The team observed operator actiona and reviewed operations plans to assure that plant operations were being conducted in a safe and controlled manner in accordance with approved plant procedures. Included in this review were evaluations of several operations management control processes to determine whether adequate operating practices, equipment status control processes, procedures, and training were in place to transition ;
| |
| '
| |
| from the current outage to power operations. The team assessed operations by observing the conduct of supervisors, operators, and staff in the control room and throughout the plant.
| |
| | |
| These observations were performed over a 23 day period that included over 100 hours of shif t observation including backshift and weekends. The team observed operator performance over three different periods. The first period was from March 7 through March 16,1998. The second period was from April 3 through April 8,1998. The third period was h
| |
| | |
| . - -- . - - _ - ___- _ _-_____-__ - - - - - _ - _ -
| |
| i from April.13 through April 24,1998. The team conducted a review of personnel'
| |
| ~
| |
| resources to determine that staff 5ng levels were adequate to support restart with overtime
| |
| ' being controlled in accordance with established guidelines. The management and
| |
| . administrative controls of operations were evsluated through inspections of equipment tagouts, log keeping practices, operator work arounds, control room deficiencies, supervisory oversight, control board awareness, and procedure adequacy and adherence.
| |
| | |
| Summarv of Plant Statum Durina the OSTI At the start of the team observation, Unit 3 was in cold shutdown (Mode 5). 'On April 7, 1998, the plant entered hot shutdown (Mode 4). Following testing and management .
| |
| review, the operators transitioned the plant into hot standby (Mode 3) on April 10. On April 12, the plant reached normal operating temperature and pressure (NOT/NOP). Operators '
| |
| commenced to Mode 4, on April 15, due to performance problems with the turbine driven auxiliary feedwater pump. The plant remained in Mode 4, for maintenance and
| |
| . troubleshooting activities, until April 23, when the plant transitioned back into Mode 3. The plant was in Mode 3 at the end of the inspection.
| |
| | |
| Plant Events There were 2 operational events and 3 failure to meet technical specifications during the plant heatup. Details of each instance including the OSTl's assessment of the causes for the events, are provided in Appendix A of this inspection report. The events included inadvertent openings of a pressurizer power operator relief valve, an automatic initiation of the auxiliary feedwater system, not having the required number of operable reactor coolant system loops while transitioning into Mode 4, the failure record the pressurizer temperature
| |
| . data during a plant heatup, and the failure to perform a surveillance test when required.
| |
| | |
| While there were no safety consequences as a result of these events, the performance by some plant operators during the plant heatup from Mode 5 to 3 was weak. Weaknesses were identified regarding specific operator knowledge, attention to detail, procedural adherence and control board awareness. The licensee initiated an integrated root cause investigation and had implemented some corrective actions by the end of the inspection.
| |
| | |
| This included additional classroom and simulator training for the operators, reinforcement
| |
| 'of management expectations, enhancement of the senior manager oversight role, and providing a mentor for one unit supervisor (US). The team observed the implementation for l
| |
| many of the corrective actions. A formal root cause evaluation of these events had not been completed by the conclusion of the inspection. The team concluded that the formal l root cause evaluation and corrective actions to address weak operator performance during
| |
| "
| |
| heatup should be completed prior to plant restart.
| |
| | |
| .
| |
| ~ Conduct of Operations -
| |
| a.
| |
| | |
| Inanection Scope J
| |
| ..
| |
| "L
| |
| | |
| - _ _ _ - _ _ - _ _ _ _ _ - - - _ _ _ _ - _ _____
| |
| The team assessed operator performance during plant evolutions; adequacy of staffing levels; overtime controls; log keeping practices; and operator identification of piant deficiencies.
| |
| | |
| b. Observations and Findinas Ooerator Performance Operator performance was generally good during the periods of direct team observations of both heatup and cooldown evolutions. The observed evolutions were generally well controlled with the appropriate supervisory oversight. During these observation periods, the operators conducted plant evolutions in a sa', and controlled manner, and exhibited a conservative approach to equipment manipulation. The team was not onsite and therefore did not witness the weak operator performance that occurred during the events described in Appendix A of this report.
| |
| | |
| The team accompanied several plant equipment operators (PEOs) on their rounds.
| |
| | |
| The team found that the PEOs were properly performing their rounds. The PEOs properly filled out their log sheets and any out of specification readings were appropriately documented and resolved.
| |
| | |
| Staffino Levels The team reviewed the operation's personnel staffing levels. The team found that operations department staffing levels were adequate to support the safe operation of the plant. There were six operating crews. At the start of the inspection, four crews were on shift operating the plant and two crews were assigned to the work control center. During the inspection, these two crews joined the other crews to establish a six shift rotation. Each operating shift had two licensed senior reactor operators (shift manager (SM) and US), two licensed reactor operators (COs) and at least two plant equipment operators (PEOs). Minimum shift complements were always met. During the outage, the desired number of qualified plant equipment operators were not always available. However, this shortage was in the process of being corrected. There was also a limited number of qualified shift technical advisors (STAS). There were only four qualified STAS. The team noted that four STAS candidates would soon be qualified at the completion of mandatory on-the-job training.
| |
| | |
| Overtime Controls The team reviewed operator time and attendance records from November 1997 through March 1998. The team found that the operators rarely worked overtime beyond established limits. The limits for overtime were delineated in Nuclear Group Procedure (NGP) 1.09, " Overtime Controls for All Personnel at Millstone Station." In those few instances where overtime limits were exceeded, the proper management prior approval was obtained and documented. However, the team found that
| |
| !'
| |
| !
| |
| l-l l
| |
| - - _ _ _ _ _ _ _ _ _ _ _ _ -
| |
| working overtime was routine. Operating crews would work about 50 percent overtime in a typical work week. In addition, operators were not afforded many days off. Interviewed shift managers all described their crews as being tired. During the inspection, the licensee transitioned to a six-crew shift rotation that should afford the operators more time off than the four crew shift rotation that was in place when the inspection started.
| |
| | |
| Loa Keaoma
| |
| ' perator log keeping was adequate. Operators used electronic logs in the control O
| |
| room. The electronic logs were available to the plant staff. Operators routinely logged limiting condition for operation (LCO) entry and exits, the starting and stopping of major plant equipment, and the completion of surveillance tests.
| |
| | |
| However, the amount of information being logged sometimes lacked sufficient details to recreate events or describe appropriate control room activities. In one instance, a contributing factor to a missed TS surveillance was an incomplete log entry regarding the entry into a LCO. In another instance, not documenting the continuous blowdown of the "C" steam generator (SG) as an abnormal condition or alternate configuration in the shift turnover log was a contributing cause to the automatic initiation of the auxiliary feedwater system that occurred on April 11, 1998. The team did not identify any problems with the shiftly and daily rounds log.
| |
| | |
| Deficiencvjdontification The operators threshold for identifying deficiencies was generally good. The operators documented deficiencies in either trouble reports or condition reports -
| |
| (CRs). The team identified a few instances where the operators were reluctant to initiate a CR. These are described below.
| |
| | |
| = A recirculation spray room air-conditioning unit failed to start from the control room. Troubleshooting found the cause of the failure was due to a relay that needed to be reset. The relay was reset and the air-conditioning unit was started. A CR was not initiated to document the failure nor was the failure logged into the control room log.
| |
| * The licensee did not initiate a CR after the team identified that operators did not maintain constant communications between operator conducting an auxiliary feedwater surveillance test.
| |
| | |
| ..
| |
| =- The licensee did not generate a CR after they found that OP 3260 D, " Lock Valve Checklist" had not been' performed as required.
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| | |
| c..
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| | |
| Conclusion
| |
| : ' During the periods of direct team observation, the licensee safely operated the p plant. Operation's staffing levels were adequate. Operator overtime was properly L controlled in accordance with established requirements; however, working overtime l l L
| |
| l J.
| |
| | |
| _
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| _ _ _ - _ _ _ _ - _ _ _ _ _ _ - - _ - _ - _ - _ __ _ _ _ _ __ - _ - _____ - _ - __ _ ____-_ - _-_ _ _
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| e
| |
| 'during the. outage was routine with the operating crews afforded few days off.-
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| Operator log keeping was adequate; however, in two instances incomplete logging contributed to operational events. The operator threshold for identifying deficiencies was generally good with a few exceptions noted.
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| | |
| These findings provide the team's basis for the closure of RAP items C.3.3, a.
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| | |
| -Licensed operator staffing meets requirements and licensen goals; C.3.3 g. Log keeping practices.
| |
| | |
| ===.02 Procedures===
| |
| | |
| i' '
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| a.
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| | |
| Innosction Scone l' The team reviewed selected plant and system operating procedures; observed operators' implementation of procedures; assessed temporary procedure changes; and assessed whether risk significant operator actions had been adequately proceduralized.
| |
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| b.
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| Observations and Findinas Procedure Quality The quality of operating and administrative procedures was generally good. The team reviewed several operations surveillance, administrative, and system operating procedures. Generally, the procedures reviewed were technically accurate and provided an appropriate level of detail.
| |
| | |
| - Most operations procedures had been recently revised as part of a procedure upgrade program (PUP). Approximately 400 operations procedures had been upgraded by the PUP process that included verification and validation of the procedures. The team noted that the revised procedures followed the procedure writer's guide that the licensee developed as part of the PUP. There were only three operations procedures which had not been completed by the upgrade process.
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| These were scheduled to be completed in May 1998.
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| | |
| The licensee identified 14 " risk significant" operator actions based on the Millstone 3 Probabilistic Risk Assessment (PRA). The operator actions identified represented those having a measurable impact on core damage frequency. The team verified that the licensee had appropriately proceduralized these operator actions in the appropriate emergency operating and abnormal operating procedures.
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| The team found a few problems with procedure quality and the administrative controls for approving procedures and procedure changes. These are described below:
| |
| * Most operations procedures and procedure changes were approved by a single individual who was not assigned or delegated management
| |
| -,
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| | |
| __-_ _ -_ _ _ _ - _ - _ - _ - - _ - - _ _ -_
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| . responsibilities. This was contrary to Millstone 3 administrative TS 6.8.2 and 6.5.4.1 which required that procedures and procedure changes be approved by the cognizant manager. In renponse to this observation, the Operations Manager performed a review and approved all operating procedures and procedure changes that had previously been inappropriately approved. No 3 procedure changes were required as a result of the Operations Manager's ]
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| '
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| . review. The team considered this a minor violation and is not subject to formal enforcement action.
| |
| * During the onsite preparation week (February 16-20,1998), the team noted that operators routinely deviated from procedures by inappropriate administrative processes. Procedure steps and entire sections were omitted or ignored by invocation of "N/A," or Not Applicable. In several instances observed, the affected step or section should have been addressed by a one-time procedure change or an even more formal change process instead or
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| ' being noted as N/A. Examples of procedure non-intent changes where -
| |
| required reviews were not completed, included not isolating a residual heat removal (RHR) loop from the reactor coolant system as required _when aligning the RHR loop for safety injection (OP 3310A, Residual Heat Removal System), exceeding the guidance of a procedural caution statement (SP '
| |
| 3606.4, Containment Recirculation Pump 3RSS*P1D Operational Readiness
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| . Test), performing procedure steps out of order and not removing vent rigs (OP 3301D, Reactor Coolant Pump Operation).
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| The licensee's administrative procedure Document Control (DC) 4,
| |
| " Procedural Compliance," permitted the use of N/As provided that the use of the N/A did not constitute a change of procedure intent. This was contrary to TS 6.8.3 that requires the change to be approved by two members of the plant staff with at least one of them holding a SRO licensee and that the change be reviewed by the PORC, SORC or Station Qualified Reviewer as appropriate within 14 days. In addition, DC 4, step 1.6.3.f required that the reason a step was N/A'd be documented. The team found that this documentation was routinely not performed. The failure to correctly implement procedure changes is a violation of TS 6.8.3 (423/97-83-01).
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| | |
| During the inspection period the licensee took effective action to correct this y problem. The licensee revised DC-4 and conducted remedial training for all the operators. The team did not observe any further instances where
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| '
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| operators inappropriately N/A'd procedure steps.
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| * Incomplete acceptance criteria in a reactor coolant systern (RCS) surveillance test SP 36010.1, " Reactor Coolant Pump Operability Check," contributed to an eperationti event where operators conducted a plant heatup to Mode 4 l with less thrn the TS. required RCS loops operable (See Appendix A for details). The failure to have two operable (RCS) loops in Mode 4 is a violation of TS 3.4.1.3 (423/97-83-02)e___- - - ..
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| .- . .
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| _.
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| . .. ..
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| .
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| = Two deficiencies were found in Operating Procedure OP 3260, " Unit 3
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| .
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| .
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| Conduct of Operations," Revision 10. These deficiencies were:
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| : (1) The
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| ;
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| procedure allowed the SM to assume the Shift Technical Advisor (STA)
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| ; duties in lieu of having a dedicated STA which is contrary to Millstone Unit 3's commitment to the NRC to have a dedicated STA; and
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| : (2) the procedural requirements for the allowed location of the US were conflicting and vague.
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| | |
| The licensee planned to revise the STA requirement before reaching Mode 2 and was evaluating the unit supervisor's location requirements at the close -
| |
| of the inspection. While the licensee is addressing these weaknesses, implementation of the procedure as written would not have resulted in a -
| |
| violation of NRC requirements.
| |
| * The team reviewed selected modification packages to verify that operating procedures had been revised, where necessary, to reflect changes made by the modifications. The team determined that operating procedures had been revised to reflect these modifications with one exception. Due to the Nuclear Training Evaluation being incorrectly marked, temporary modification 3-97-075, " Temporary Differential Pressure Indication Across 3CHS*FLT3A," was installed but the appropriate procedures were not adequately changed to reflect the changes to the reactor coolant pump (RCP)seal water filters. The licensee initiated a CR to address this problem. The team considered this a minor violation and is not subject to formal enforcement action.
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| | |
| Procedure Adherence During the inspection, the team observed implementation of numerous operating procedures, including procedures for starting reactor coolant pumps, securing the residual heat removal (RHR) system, and controlling plant heatup to Modes 4 and 3.
| |
| | |
| - While the operators generally adhered to procedures, the team identified a few instances where the operators failed to follow procedures. TS 6.8.1 requires that written procedures be established, implemented and maintained covering activities such as plant operation and surveillance activities. In addition,10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be accomplished according to procedures. Additional details regarding the first three examples of failurs to follow procedures are provided in Appendix A of this report. The instances where operators failed to follow procedures are violations of NRC requirements as stated below:
| |
| * Operators did not follow OP 3301G, " Pressurizer Pressure Control," step
| |
| : 4.1.6 when placing the pressurizer pressure master controller in automatic.
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| | |
| This resulted in two inadvertent openings of tha pressurizer power operated
| |
| - relief valves while the unit was at normal operating pressure and temperature. The failure to implement procedure requirements is a violation of TS 8.8.1 (423/97-83-03).
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| _.
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| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ __ _ __ __ _ - __ _____ __ - _ _
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| * Operators did not maintain the "C" SG generator level between 45% and 55% as required by OP 3201 " Plant Heatup". The failure to implement procedure requirements is a violation of TS 6.8.1 (423/97-83-03).
| |
| * During a plant heatup, an operator did not record pressurizer temperature every 15 minutes as required by SP 3601G.2, "RCS and Pressurizer Heatup and Cooldown Rate," step 4.3.3. The failure to determine pressurizer temperature is within limits every 30 minutes is a violation of TS 3.4.9.2 (423/97 83-04).
| |
| * During performance of Surveillance Procedure SP 3622.3, " Auxiliary Feedwater Pump 3FWA*P2 Operational Readiness Test," Section 4.3, on April 13,1998, licensee personnel did not maintain constant direct communications as required by Step 2.1.6 which stated that when in Mode 1,2, or 3, the local operator must be in direct communication with the Control Room Operator to restore normal operation if needed. As part of the test, the turbine driven auxiliary feedwater pump (TDAFW) pump manual discharge isolation valves were closed, a condition which would require actions by the local operator to restore the plant to norrnal. With the auxiliary feedwater system (AFW) in this abnormal lineup, the operator removed his headset so that he could move around more freely to locate valves. The team considered this a minor procedure violation and is not subject to formal enforcement action.
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| | |
| c. Conclusion i The team. concluded that the quality of plant operating procedures was generally good. With a few exceptions, the procedures reviewed by the team were technically accurate and provided an appropriate level of detail. Risk significant operator actions were adequately proceduralized. While the team found that operators generally adhered to procedures, the team identified a few exceptions where procedures were not followed. In addition, the team identified two instances where the administrative control of procedures was not in accordance with TS. The licensee was addressing these issues as part of the root cause evaluation for the operational events that occurred during plant heatup.
| |
| | |
| These findings provide the team's basis for the closure of RAP items C.2.1, b.
| |
| | |
| Demonstrated expectation of adherence to procedures; C.3.3 f. Procedure usage / Adherence.
| |
| | |
| 03 Training and Qualifications l
| |
| ; a. !nsoection Scone The team examined operator training and qualifications records to verify that required training was complete and training records were properly maintained.
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|
| |
|
| | Docket No. 50-423 B17261 i |
| | L Attachment 2 i |
| | Millstone Nuclear Power Station, Unit No. 3 |
| | ' |
| | , NRC Operational Safety Team Inspection (OSTI) Report No. 50-423/97-83 l Repiv to a Notice of Violation |
| ! | | ! |
| I l | | I l |
| L I t_.
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|
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| __ ]
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|
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| .
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| b. Observations and Findinas Reaualification Trainina The team reviewed licensed operator requalification training records to verify that all required training was performed. Alllicensed operators had attended and passed requalification training for the startup procedures. The team reviewed lesson plans and simulator scenarios and found lesson plans to be adequate and sirquiator scenarios to be challenging. Management involvement was evident from comments in simulator evaluation records. The team found that operators returning to shift from administrative or other assignments satisfactorily regained proficiency.
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|
| |
| Restart Trainino The effectiveness of restart training was lessened by ongoing delays between training and startup. Operations management had scheduled operator heatup and reactor startup training to coincide with the anticipated dates for these evolutions.
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|
| |
| However, due to plant schedule changes the plant heat up training was given over a month before the actual plant heat up occurred. The operations manager stated thet the operating crew that would initially restart the reactor would receive extensive restart training just prior to reactor startup.
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|
| |
| Not withstanding the completion of all required training, the team identified specific operator knowledge deficiencies, two of which contributed to plant events.
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|
| |
| .
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|
| |
| The lack of understanding of the operation of the RCS pressurizer pressure controllers contributed to two inadvertent lifts of a pressurizer power operated relief valve while the unit was at NOT/NOP.
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|
| |
| - The unfamiliarity of a TS contributed to the plant transitioning to Mode 4 with less than the required number of operable RCS loops.
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|
| |
| Post Heatuo Event Trainina l
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| l The team evaluated specialized classroom and simulator training to ensure that the
| |
| !
| |
| operators were adequately prepared for a safe plant restart. The team observed operator classroom training provided on recent events and startup procedures and witnessed control room simulator training. Classroom instruction was adequate to ensure that the operators were cognizant of recent problems experienced by the plant. Senior management was present and participated by reenforcing goals and operating policies. During the conduct of simulator training scenarios, the SM and US appropriately monitored and directed crew activities. Overall, the operators demonstrated good knowledge of plant systems and effective use of the startup and supporting system operating procedures. Shift management reenforced good operating practices and communications.
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|
| |
| Modification Trainino
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|
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| _ __- _ _____- _ ___ ____ _ _-__ _ _-___ --__-___
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| !
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| l The team found that the licensee had provided adequate operator training on i recently completed plant modifications with one minor exception. Due to the
| |
| '
| |
| Nuclear Training Evaluation being incorrectly marked, Temporary Modification 3-97-075, " Temporary Differential Pressure Indication Across 3CHS*FLT3A," was installed but operator training was not provided (See Section E1.1 for additional details).
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|
| |
| Ejre Briaade Trainina The team reviewed the staffing and' training of the dedicated site fire brigade and reviewed fire watch manning. Other aspects of fire protection were reported on in NRC Inspection Report 50-423/98-81. The team verified that fire brigade staffing was adequate to support each shift and that required fire drills were being conducted. Each fire brigade member had participated in at least one of the two required drills for the current year. Assigned fire watches were interviewed and found to be knowledgeable of required duties.
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|
| |
| The fire brigade provided fire protection for all three Millstone units and was independent from the plant operations departments, with the exception of the operations advisor. The advisor was an experienced plant equipment operator or licensed operator assigned to the fire brigade to assess the safety consequences of a fire. A review of the Millstone 3 licensing basis identified that Branch Technical Position (BTP) CMEB 9.5-1 required the fire brigade leader to be competent to assess the potential safety consequences of a fire, either by possession of an operator's license or equivalent knowledge of plant safety related systems. The ;
| |
| licensee's Fire Protection Report required an operations fire team advisor I knowledgeable in plant safety-related systems operation. The Fire Protection Report requirement was a result of a change in fire brigade composition made in 1997 from a team of operations personnel from all three Millstone units to a dedicated site team with operations advisors. A safety evaluation was performed to analyze this change and was documented as final safety analysis report (FSAR) change request 97-MP3-47. However, the licensee found that a commitment change request had
| |
| )
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| j not been submitted to the NRC and documented this fact on CR M3-98-2131. The l team held discussions with the licensee's regarding the practice of meeting the BTP 1 CMEB 9.5-1 requirement by assignment of non-licensed pl ant equipment operators as fire brigads advisors. The issue of fire brigade safety system knowledge requirements is an open inspector follow-up item, pending NRC review and acceptance of FSAR change request 97-MP3-47. (423/97083-05)
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|
| |
| ====c. Conclusions====
| |
| The team concluded that requalification training was adequate to support plant restart. Each licensed operator and senior operator was current in completion of requalification training and had passed required examinations and evaluations.
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|
| |
| Operations management was effectively involved in training. Some weaknesses were note in specific operator knowledge. Fire Brigade staffing and training was adequate.
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|
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| l i
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| . _ . - .___________________________ a
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|
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| ..
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|
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| _ _ _ _ _ _ _ __ _ _- -
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| These findings, in addition to the findings in Section S6 of this report, provide the team's basis for the closure of RAP item C.3.1, e. Qualification and training of staff.
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|
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| 04 Plant Equipment Status a. Insoection Scone The team assessed the safety tagging process, work control activities in progress, operator challenges (i.e. work-arounds and control room deficiencies) and system equipment alignments.
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|
| |
| b. Observations and Findinos System Alianment Historicel Performance The licensee has a history of system alignment control problems. Some of these problems were documented in the licensee's common cause investigation report, Configuration Control of Valves / Switches / Breakers, CR M3-97-0485. This report documented that in 1995 and 1996 eighty-five CRs had been generated directly related to the Operations Department for valve, switch, and breaker misalignments.
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|
| |
| Licensee trending of this problem after the report was issued indicated that the number of component misalignment occurrences was declining. However, the number of component misalignments which have occurred recently (identified by the licensee and the OSTI) indicated that the licensee's corrective actions for past occurrences had not been fully effective and system alignment control at Millstone 3 was still a problem.
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|
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| .
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| The failure to estal;lish measures to assure that conditions adverse to quality, such as deficiencies, are promptly identified and corrected is a violation of NRC requirements. The team identified system alignment deficiencies described below, including valves not aligned in accordance with the alignment sheets, independent verifications not performed, and system alignment procedures not completed, are a violation of 10 CFR, Appendix B, Criterion XVI (423/97-83-06)
| |
| Identified Valve Alianment issues
| |
| ,
| |
| The team identified several problems with the administration and control of plant l equipment alignments. Problems identified included: components not aligned properly, inadequacies in the valve and breaker lineup process, and deficiencies in the conduct of the locked valve program.
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|
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| The following valve alignment issues were identified during the OSTl:
| |
| - The team identified charging pump 3CHS*P3C ( a swing pump between trains) manual suction valve 3CHS*V707 was not in the position described in the valve lineup procedure. The licensee wrote a CR to document the condition and performed a valve lineup to align the pump to the"B" train. The
| |
| _ _ . _ _ _ _ _ _ _ _ _ _ .
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|
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| -
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|
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| 3CHS*P3C charging pump was in standby and was not required to be
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| '
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| operable when the team noted this discrepancy with the position of the manual suction isolation valve.
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|
| |
| =' The team identified that a "B" emergency diesel generator (EDG) lube oil strainer drain valve, 3 EGO *V188, a 90 degree ball valve, was mid-position in
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| '
| |
| lieu of being closed. The Wensee initiated a CR to address this problem. This discrepancy did not advere,ely affect the operability of the EDG because a pipe cap was installed downstream of the hall valve that prevented a loss of .
| |
| lobe oil.
| |
| * The licensee identified that an emergency diesel generator starting air receiver drain valve 3EGA*V7 (3EGA*TK1 A Air Receiver) was cracked open vice closed and allowing air to escape from the 1 A air receiver. The licensee initiated a CR to address this problem. The air leakage was small and did not adversely affect the starting capability of the EDG.
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|
| |
| Review of Valve and Breaker Linnuns The team reviewed completed valve and breaker lineups that the licensee had performed to support plant heatup and identified several problems. The licensee initiated a CR to address these problems.
| |
| * The position of high pressure safety injection throttle valves was not verified during the valve lineups. The valve lineup sheets noted that the valves were throttled per surveillance procedure SP 3712Z, " Setting Position of High Pressure Safety injection Throttle Valves." An example of this was the valve lineup for train "A" high pressure safety injection, OPS Form 3308-3, completed August 19,1997.
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|
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| .
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|
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| A clear procedure link did not exist in some instances which would ensure valves not positioned as required by the lineup sheets would get positioned H correctly. An example of this was: "High Pressure Safety injection Common," OPS Form 3308-2, performed November 1997, Note 3 stated that valve 3SlH'V885 is closed and the blind flange not installed. It was not
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| ,
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| clear how this valve would be verified closed and the blind flange would be installed.
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|
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| l | | l |
| ' | | ' |
| .
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| | |
| Valves were N/A'd on valve lineup sheets without any justification being I provided. An example of this was: " Train' A Service Water System," OPS Form 3326-1, performed December 23,1997, valves 3SWP*V84,
| |
| . 3SWP*V85,3SWP*V997,3SWP*V78, and 3SWP*V994.
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| | |
| [
| |
| <
| |
| * Valve positions designated on lineup sheets were changed without a i procedure change being written. An example of this was: "EDG B - Starting Air Valve i.ineup," OPS Form 3346A-6, performed August 12,1997.
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| i-
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| .- .
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| . - _ _ _ _ _ -
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| . | | . |
|
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| . Valve lineup " Control Building A/CA Service Water System Supply," OPS Form 3326-9. Note 1 on sheet 2 required valve 3SWP'V 13 to be throttled
| |
| ' 35 degrees open; however, a handwritten note on the valve lineup cover sheet stated that valve 3SWP*V13 was throttled at 39 degreesi flows between 520-540 gallons per minute (gpm). The licensee initiated a CR to address this problem.
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|
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| .
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|
| |
| independent verification was not done on some safety-related instrument lineups as required in Work Control Procedure WC-6, " Determination and Performance of Independent and Dual Verification," Revision 0; Attachment 3 which requires independent or dual verification for initial system lineup l
| |
| following an outage where the system status was not maintained in the normal operational lineup. Examples of this were: " Service Water System -
| |
| Instruments," OPS Form 3326-4, performed August 8,1997; " Auxiliary Feedwater instrumentation," OPS Form 3322-4, performed on September 9, 1997.
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|
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| ,
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| .
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|
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| The team found that the licensee had not performed required instrument root valve and instrument block valve alignment verifications. The licensee could not verify that the following safety-related instrument valve lineups had been performed as required by Procedure ACP-QA-2.12, " System Valve Alignment Control," Revision 12. Procedure step 6.4.1.2 required that a root stop -
| |
| lineup be performed prior to start-up if the plant is in cold shutdown for greater than thirty
| |
| : (30) days; step 6.4.2.1 required that instrument isolation stops that are not on scale normally or during surveillance testing be checked for proper alignment at least quarterly. This procedure required an instrument isolation stop lineup verification to be performed prior to start-up if the plant is in cold shutdown for greater than thirty
| |
| : (30) days.
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|
| |
| System Walkdowns The team performed reviews of system valve lineup sheets and piping and instrument drawing (P&lDs), and also performed walkdowns of selected portions of the quench spray, EDG, and safety injection systems. During the reviews and walkdowns, the team verified that: system lineup procedure requirements matched plant drawings and as-built configuration; valves in the flow path were in the correct positions; electrical breakers were properly aligned; and the condition of the components and equipment observed was acceptable. Problems identified by the team during the reviews and walkdowns included:
| |
| - Some electrical breakers did not have component identification labels.
| |
| * The position provided in the electrical checklist for components did not
| |
| ' match the position information found on the components in the field. (i.e.,
| |
| Form 3308-6, required position on the form was " Closed" and the position information on the component was "Off").
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| - - - - _ . _ - _ - . - _ _ - - _ _ _
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|
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| - _ _ _ _ _ _ - - _ . _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - - _ _ _ . - _ _ _ _ _ .__
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| .
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| L
| |
| * Component descriptions were provided in some of the electrical checklists but not in others. (i.e., OPS Form 3308-6).
| |
|
| |
| * ' Handwritten information was on some of the components (i.e, Electrical L Panel 3SCV'PNL25P hand written label "MCC-181-1FT, 3SCV-PNL25P"and L Panel 3EGS*PNL1B had handwritten stickers (i.e., KAP, GSH) below some
| |
| ! circuit breakers).
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|
| |
| ..
| |
| * Some of the breaker alignment sheets were incomplete. Some component
| |
| "
| |
| electrical breakers and switches were not included in the electricallineup sheets for the emergency diesels and quench spray systems.
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|
| |
| t
| |
| * The team found that drain valves on the air start distributor filters 3EGA*FLT3B(B), 3EG A'FLT3D(B), 3EGA'FLT3A(A), and 3EGA'FLT3C(A) in the 'A' and 'B' emergency diesel generator air start systems were not labeled, not shown on the P&lDs, and not included in the valve lineup procedure. Starting of the emergency diesel generators could be affected if these valves were improperly positioned.
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|
| |
| Locked Valva Proaram The team identified the following problems with the licensee's locked valve program. These problems are described below;
| |
| * The required locking devices were not installed on some manual valves in the main process flow paths in some safety related systems as required.
| |
|
| |
| Operating Procedure 32600, " Equipment Control," Step 1.5.1, Criterion 3, required that manual valves in main process flow paths for accident mitigation be locked in position. However, the team determined that the licensee did not use locking devices on emergency diesel generat a air start isolation valves 3EGA'V45,3EGA*V46,3EGA'V18,3EGA*V19; and charging pump manualisolation Valves 3CHS*V49 and 3CHS*V51.
| |
| * The licensee could not demonstrate that locked components had been _ . .
| |
| verified secured in the correct position as required by OP.32608. OP 3260B,
| |
| " Equipment Control," Rev. 2, Change 3, Step 1.5.7 required that at least once each refueling cycle each locked component listed in OPS Form 32608-1 be verified ' secured in the correct position by an approved restraining device.
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|
| |
| ,
| |
| EnAlamant Taoalna Proaram The team reviewed the licensee'requipment tagging program. The licensee had l implemented a computerized tag out process which provided printouts of clearances and tags. The team randomly selected equipment isolation and control tags hung in
| |
| .the plant and verified that the information on each of the tags agreed with information on the _ clearance sheet, the tag was installed on the correct component,
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|
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| . . .
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|
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| -- _ _ - . _ - _ _ _ - _-_ - _-____ . ---
| |
| and the component was in the required position. The team also selected and walked down active equipment clearances and verified that the information on the clearance and tags agreed, tags required by each of.the clearances was on the correct component, and the component was in the correct position. No problems were identified.
| |
|
| |
| Ooerator Work-arounds and Control Room Deficiencies The team reviewed the licensee's operator work-around and control room deficiency programs. The licensee had developed a good operator work around program. The operator work-around program was formalized in OP 3260E, " Program for Resolution of Operator Work-Arounds." At the time of the inspection,' the licensee had identified 20 operator work-arounds. The team did not identify any operator work arounds that had not been appropriately included in the program. Where
| |
| . appropriate, the licensee proceduralized the work-arounds in plant procedures. The team determined that the safety impact of the identified work-arounds was minimal.
| |
|
| |
| The licensee had an adequate program to highlight important control room deficiencies. The team noted that the program guidance contained in common operating procedure (COP) 200.9 " Operational Performance Status," was limited.
| |
|
| |
| The licensee had captured 12 deficiencies in the program. The team identified two additional control room deficiencies that the licensee had inappropriately screened as not being control room deficiencies. This included a broken pen in a post accident monitoring recorder and a faulty switch position indication light. The safety impact of the identified deficiencies was minimal.
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|
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| c.
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| Conclusion The team found that the licensee's corrective actions for past equipment alignment problems have not been fully effective. The team identified several problems with the administration and control of the plant equipment alignment program. These problems included components not properly aligned, inadequacies in the valve and breaker lineup process, and deficiencies in the locked valve program. The team concluded that actions were necessary to address the issue of plant equipment alignments prior to plant restart.
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| ' The team determined that the safety tagging process was adequate and functioned as designed to improve personnel and equipment safety. The existing operator
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| work-arounds and control room deficiencies did not impact safe operation of the facility.
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| These findings provide the team's basis for the closure of NRC Significant item List item 31, Work Arounds and Use As-Is Deficiencies.
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| l The team was unable to close RAP item C.4, d. Adequacy of system lineups.
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| -05 Command and Control
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| ====a. Inspection Scope====
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| The team assessed the control board operator's awareness of plant equipment status, control room conditions and the quality of their annunciator response practices. The team also assessed the quality of the SM and US command and control of plant evolutions. ' Communications between plant management, shift supervisors, and reactor operators regarding plant status and evolutions, and the ability of the operators to control plant maintenance and surveillance were
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| ; evaluated through extensive control room observations. ' The adherence to operations administrative procedures regarding shift turnover and control. room access control were also verified in addition, the team evaluated operations management involvement in day-to-day plant operation.
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| b.
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| Observations and Findinas Communications The team observed communications on all shifts. Communications between operators and between the control room and other site organizations were generally good with some minor exceptions. Management's expectations regarding three way oral communications were generally met.
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| The team observed several pre-evolution briefings. The quality of pre-evolution briefings varied. Some prebriefings consisted of only the reading of procedure precautions and others were detailed and thorough. For example, on March 10, the probriefing for the reactor coolant pump start evolution consisted of reading the procedure precautions to the participants. One participant did not attend the briefing. There was no discussion of expected plant response or contingencies. In
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| = contrast, the prebriefing for the transition into Mode 4 was good. In this prebriefing, there were detailed discussions on responsibilities, precautions, expected plant conditions, and contingencies. In addition, there was a strong emphasis given on plant safety and the need to take the time to do the evolution correctly.
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| Shift Turnovers The shift turnovers observed by the team were generally comprehensive, in that necessary information concerning plant systems status was discussed and appeared to be understood by the oncoming shift. A shift turnover briefing for the oncoming
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| ' shift was held after the individual station watchstanders had done their station
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| : turnovers. During the briefing, each station watchstander gave an update on f activities related to their station.
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| c The team observed a plant cooldown from Mode 3 to 4 where the turnover was well controlled even with a shift change that occurred during the cooldown. To avoid disruptions in the cooldown, operators conducted shift relief one station at a i
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| time over,an extended period. The control operators on the main control boards were held over to complete the cooldown and the relief crew assisted with plant operations not related to the cooldown.
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| However, in one instance, the upcoming expiration of a TS LCO on the shutdown margin monitor instrumentation was not clearly communicated, and a required valve position verification surveillance was not done when required (See Appendix A for details). The failure to verify potential dilution path valve position with a shutdown margin monitoring channel inoperable is a violation of TS Table 3.3-1, Functional Unit 21, Action 5(a) (423/97083-07).
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| Control Room Access The team observed control room operating area access control on all shifts. Access control on all shifts was pood. The team did not identify any instances where personnel entered the control room without permission. The unit supervisor routinely limited control room access to only those persons that needed access to c=
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| the control room. During periods of high activity, operators piaced signs on the control room access doors to further restrict access.
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| Suoervisorv Oversiaht The team found that the quality of command and control of shift activities was generally good. However, there were some instances of weak performance by shift supervision. These included the following.
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| = Inappropriate direction from a unit supervisor resulted in two inadvertent lifts of the pressurizer power operated relief valves.
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| Weak oversight of a control operator who was standing a proficiency watch contributed to missing the required recording of pressurizer heatup data.
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| Self Checkina and Control Board Awareness The operators'self-checking methodology was not always a strength. While all the operating crews used the " STAR" methodology, the shift crews sometimes performed evolutions without benefit of careful consideration and discussion of expected parameter changes or corroborating indications. For example, during the pressurizer fill evolution and approach to solid plant operation, the operators had not calculated the total volume to fill the pressurizer. There was no predicted transfer calculated or an established method of corroborating that the evolution was proceeding as planned. Operators were unaware of the volume in the pressurizer above the level indicator, and were unable to predict when solid plant should be expected.
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| Operator awareness of control board indications was generally good. However, on l one occasion operators " forgot" that a continuous blowdown of the "C" steam
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| generator was in progress while conducting a plant heatup. Failing to isolate the blowdown resulted in a low level condition in the steam generator and an automatic start of the auxiliary feedwater system.
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| The t'eam found that the control room operators were cognizant of control room annunciators. When unexpected siarms annunciated, the control room operators reviewed the correct alarm response procedure and took appropriate actions according to the procedure.
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| The team found that operations management was actively involved in operations activities. The team frequently observed operations management in the control room
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| - providing guidance to the shift. Operations management participated in shift '
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| turnover meetings to reinforce their expectations. The licensee assigned a senior .
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| . management representative to each shift to help coordinate heat-up and power ascension activities.
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| Plant Sunnort The team also reviewed the ability of operations to solicit support from other plant organizations. The team found that support of plant operation from other site and -
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| - plant organizations was typically good. However, some weakness was noted associated with the event that resulted in the automatic initiation of the auxiliary feedwater system. The lack of plant support delayed the starting of the motor driven main feedwater pump during a plant heatup. Similarly, conservative interpretation of TS and unclear testing requirements for the turbine driven auxiliary feedwater pump placed undue pressure on the operating crews during the same plant heatup. Both of these contributed to an automatic initiation of the auxiliary
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| feedwater system, c. Conclusion The team found the quality of command and control was good with only occasional lapses. Shift turnovers were typically comprehensive and the quality of prebriefs ranged from very good to marginal. Operators were cognizant of plant conditions,
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| = control room annunciators and appropriately controlled access ts the control room.
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| [ Operations management was actively involved in operation activities. Plant support
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| - to operations was generally good.
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| L .These findings provide the team's basis for the closure of RAP items C.2.1, e.
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| ! Management's demonstrated awareness of day-to-day operational concerns; C.3.3, b. Level of formality in the control room: C.3.1, g. Attentiveness to duty (staff);l C.3.1, b. Level of attention to detail (staff); C.3.3, d. Control room / plant operator
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| - awareness of equipment status.
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| lit. Engineering E1. Plant Modifications E1.1 Temocrarv Modifications a.
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| Inanection Scor,e The team evaluated the adequacy of the temporary modification (TM) administrative requirements and verified that existing TMs were installed in accordance with these requirements. Interviews were conducted with the TM program manager, system engineers (SEs), and design engineers to assess their knowledge of the TM process.
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| An assessment of the roerational impact for all TMs, currently intended to be installed at the time of plant restart, was performed by the team. The team also conducted walkdowns to identify the existence of potential modifications to station equipment not properly controlled by the TM process.
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| b.
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| Observations and Findinas Administrative procedure WC-10, " Temporary Modification," provided clear and comprehensive administrative requirements for controlling TMs. Strengths noted were the use of detailed design engineering screening forms to evaluate 29 different program areas and detailed guidance for evaluating for design basis impact. The TM coordinator, SEs, and design engineers were knowledgeable of the TM process.
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| J The team found that the licensee's initiatives to reduce the total number of TMs had been effective. Several SEs also discussed plans to further reduce the number of installed TMs on there assigned systems. Based on a review of all 18 TMs currently installed in the plant, the team determine that the TMs did not adversely affect plant operations. Field walkdowns did not identify temporary changes to plant equipment not being properly tracked by the TM process or by an approved plant procedure, la general, the TMs had thoroughly documented and adequately reviewed safety analyses. Procedures and drawings were properly updated. When observable, the TMs were verified to be installed in accordance with the documented installation instructions. A few minor problems were identified in two TMs regarding the quality of safety evaluation and design engineering screenings. These urors were readily apparent and should have been identified during independent management reviews.
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| The licensee initiated a condition report to address the team ioentified weaknesses.
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| The team noted two omissions in the design engineering screening for TM 3-97-075, " Temporary differential pressure indication across 3CHS*FLT3A." The design engineering screening failed to identify that a setpoint database review was required due to the TM removing a pressure indicating switch (3CHS-PIS140, RCP seal water injection filter 3A differential pressure) from service. The design engineering screening also failed to recognize that a nuclear training evaluation was required due l l
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| | July 1998 L--_-_-__---------------------- |
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| to the impact of the TM on plant equipment and operating procedures. Specifically, the TM removed a pressure indicating' switch (3CHS PIS-140) from service that .
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| affected control room annunciators and associated procedures.
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| | U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 1 Nuclear Reaulatory Commission Violation "A" (50-423/97-83-01) |
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| The team aI'so noted omissions in documentation of the design engineering review and safety evaluation screening for TM 3-98-004, "ARCOR on 3SWP*TV35A." The TM documented the installation of ARCOR on the service water outlet valves of the control room chiller. The design engineering screening failed to identify that a mechanical design review was required due to the TM affecting the control room ventilation system. The 10 CFR 50.59 safety evaluation screening failed to identify that the TM did affect components described in the final safety analysis report (FSAR). The outlet valve consisted of a master / slave valve assembly that directs
| | Restatement of the Violation Technical Specification (TS) 6.8.3 requires, in part, that temporary changes to procedures of Specification 6.8.1 (including Appendix A of Regulatory Guide 1.33) may be made provided (a) the intent of the original procedure is not altered; (b) the change is approved by two members of plant management staff, at least one of whom holds a Senior Operator license on the unit affected; and (c) the change is documented and reviewed by the Plant Operations Review Committee (PORC) or Site Operations Review Committee (SORC) or Station Qualified Reviewer, ... within 14 days of implementation. |
| ! flow to eithec the discharge canal or recirculates flow back to the inlet of the chiller.
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| The FSAR, Section 9.2.1.2, System Description, states, in part, that a control building chiller condenser recirculation valve is provided in the service water discharge line. The team identified that the potential existed for the ARCOR to delaminate from the recirculation valve and potentially clog the chiller condenser.
| | Contrary to the above, as si February 20,1998, administrative procedure Document Control (DC) 4, "Procedun I Compliance" allowed operators to make non-intent changes to procedures without being approved by two members of plant management staff or reviewed by PORC or 609f' a Station Qualified Reviewer, ... within 14 days of |
| | ' implementation. Examples of procedure non-intent changes where required reviews were not completed included not isolating a residual heat removal (RHR) loop from the reactor coolant system as required when aligning the RHR loop for safety injection (OP3310A, Residual Heat Removal System); exceeding the guidance of a procedural caution statement (SP 3606.4, Containment Recirculation Pump 3RSS*P1D Operational Readiness Test); and performing procedure steps out of order and not removing vent rigs (OP 3301D, Reactor Coolant Pump Operation). |
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| The licensee did conduct an engineering evaluation of the TM as documented in Engineering Evaluation M3-EV-98-OO9, Revision 0, dated January 16,1998; however, the avaluation did not consider the potential impact of the ARCOR coating failure on the recirculation function of the valve.
| | NNECO's Response NNECO does not dispute the cited violation. |
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| c.
| | Reason for the Violation The reason for this violation is attributed to a lack of understanding of the administrative requirements for non-intent changes to procedures and the application of "Not Applicable" or "N/A" when not performing steps. |
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| Conclusion The administrative process for installing TMs required adequate documentation and review. The number of installed TMs was low and the licensee was monitoring and controlling the total number of installed TMs. The team conducted a sample, reviewing all safety-related TMs and identified no adverse impact on safe plant operation.
| | Corrective Actions That Have Been Taken and Results Achieved Operating procedures, and a sampling of surveillance procedures were reviewed for improper use of the term "N/A". Deficiencies identified were corrected through procedure changes or by adding additional documentation to the forms DC 1, " Administration of Procedures and Forms", no longer refers to a non-intent change process and specifically addresses the use of the " Temporary Change" , |
| | process as it is described in the Technical Specifications. |
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| The licensee initiated a CR baseci on team questioning of engineering screenings and safety evaluations on two TMs. In these cases, the issues were not safety significant, but pointed to possible lack of rigor in evaluating the screening questions.
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| | U.S. Nucisar R gulttory Commission B17261\ Attachment 2\Page 2 DC 4, " Procedure Comp!iance" was . revised to ensure a procedure change is i |
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| | processed, if required, prior to recommencing the performance of a task or evolution i that was stopped due to the instructions appearing to be inadequate, the occurrence of unexpected results, or the task or evolution could not be performed as written. |
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| These findings, and those provided on operability determination in Section E2.1 of this report, provide the team's basis for the closure of NRC Significant item List item 69, Review of all Operability Determinations and By-Pass Jumpers Before Restart.
| | Presentations were given to the Millstone Unit No. Unit 3 Shift Managers in order to |
| | ! provide clarification regarding this practice. These presentations addressed "The Use j of 'N/A' to Indicate Non-Performance of Procedure Steps" and " Determining if a l~ Modification Alters the Original Intent". This included a discussion with the Manager, l Station Procedure Group regarding the proper use of N/A and documentation required. |
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| E1.2 Permanent Modifications a.' Scone The team reviewed the administrative controls for initiating and installing plant modifications. . Several modifications, installed during the current outage, were reviewed to verify that the modifications were installed in accordance with
| | This presentation was also shared with the Millstone Unit Nos.1 and 2 Shift Managers. |
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| | This material was also posted on the Millstone Web Site and communicated to the organization through our daily communications newsletter. |
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| requirements. The team verified that the engineering approach of the modifications was technically sound and safety evaluations provided an adequate basis to determine that the change did not involve an unreviewed safety question. In addition, the team verified that modification closeouts were complete, drawings were revised, appropriate post-modification testing was performed, and vendor information manuals were updated.
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| | l Additionally, a lessons learned memorandum was provided to each member of the |
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| Observations and Findinas The design control manual (DCM) provided comprehensive guidance on implementing the modification process from initiation of the engineering work authorization (EWA) through turnover of the modified system to operations. The following strengths were noted in the design control process:
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| The use of proceduralized forms and checklists, which result in the engineer performing thorough 50.59 and overall design change impact reviews.
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| - Proceduralize independent review format, which ensure a detailed independent review,
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| Good proceduralized method for calculation documentation and review.
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| The team completed a detailed review of modification implementation documentation and installation on twelve modifications completed during the outage. The modifications were generally well prepared, contained adequate )
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| documentation and references to design inputs and followed the DCM process. The l team found that engineering of the modifications was technically sound and safety evaluations provided an adequate basis to determine that the change did not involve an unreviewed safety question. The modification closeouts were complete, drawings were revised, appropriate post-modification testing was performed, and vendor information was updated. The team did not identify any weaknesses in the l I
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| technical adequacy or closeout for the plant modifications reviewed.
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| The team attended the Resource Allocation Committee (RAC) meeting that was held on April 14,1998. The agenda for the meeting included a review of 1998 projects that required RAC approval for funding. The team noted that the RAC properly dispositioned items from a plant safety and regulatory perspective.
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| ====c. Conclusions====
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| The team found the design control process provided a detailed and comprehensive method for evaluating the entire scope of plant change activities. Modification package content, including the screening and safety reviews, was appropriate. Post-modification testing appeared to encompass verification of important design change attributes.
| | Operations Department and required to be reviewed prior to the next time they stood a Control Room shift. |
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| | ' Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
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| | Date When Full Compliance Will Be Achieved |
| | : Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
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| ' E1.3 - Deferred Modification Review
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| ====a. Scope====
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| The team assessed the ranking of proposed modifications and the completion of items necessary for plant restart, including review of the deferred modifications' and open engineering work requests (EWRs). The team reviewed the deferred EWR backlog and selected several issues for detailed review to assess plant impact of -
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| not completing these items before testart.
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| | U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 3 ( . Nuclear Reaulatory Commission Violation "B" (50-423/97-83-02) |
| | l Restatement of the Violation TS 3.4.1.3 requires, in part, that at least two of the reactor coolant system loops (from among 4-reactor coolant system loops and/or 2-residual heat removal loops) shall be OPERABLE in Mode 4. |
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| | Contrary to the above, on April 7,1998, at 22:54 hours, only one reactor coolant system (RCS) loop was OPERABLE with the plant in Mode 4. This violation continued until April 8,1998 at 18:10, when a second RCS loop was made OPERABLE. |
| b.
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| Observations and Findinas
| | NNECO's Response NNECO does not dispute the cited violation. |
| . The team selected approximately 140 of the deferred EWRs for an initial review,-
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| following this, the team selected approximately 50 for a detailed review, based on potential safety significance. In review of these EWRs, the team did not identify any restart issues. The EWRs reviewed all had adequately developed and well written deferral justifications.
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| ====c. Conclusions====
| | Reason for the Violation The cause of the event was human error. The Shift Manager used surveillance information without validating that the Technical Specification requirement for the |
| ' | | ' Reactor Coolant System loops OPERABLE in Mode 4 was satisfied within the heat-up procedure. A contributing cause was insufficient detail in the surveillance acceptance criteria. (This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event Report (LER) 98-022-00, dated May 8,1998. (Reference Northeast Utiliiies letter to USNRC, B17183). |
| The licensee had adequate controls in place to screen deferred work to ensure
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| - deferred work was properly evaluated to provide a safe plant restart.
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| E2- Plant Technical Support E2.1 Operability Determinations a.- Scone
| | Corrective Actions That Have Been Taken and Results Achieved The following corrective actions have been completed and are described in Millstone Unit No. 3 LER 98-022-00: |
| ' The team assessed the adequacy of the operability determination (OD) proc'e ss and
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| - all open ODs at the time of this inspection.
| | A briefing has been provided to Operations crews on expectations regarding verification of information and performance of electrical line-ups, proper use and satisfaction of acceptance criteria, and the need for surveillance validation. |
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| ====b. Observations and Findings====
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| The OD process provided a clear format for documentation of issues and justification of operability conclusions. The process was consistent with the | | The Reactor Coolant Pump Operability Procedure (SP3601D.1) and Surveillance Forms acceptance criteria have been revised. |
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| guidance provided in NRC Generic Letter 91-18, "Information to Licensees Regarding NRC Inspect!on Manual Section on Resolution of Degraded and
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| ' Nonconforming Conditions."
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| The ODs were generally thorough and provided sufficient detail to establish operabilityiThe team reviewed all the open ODs and determined that they were acceptable as documented with OD 41-98 being the only exception. The team i conducted extensive reviews of three ODs as described below:
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| | Training has been conducted for Operations crews on Technical Specification 3.4.1.3 requirements. |
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| OD 41-98'- 41'60, 6900. ar.d 480 Volt Breaker Overhauls Not Performed in Accordance Within Vendor Recommended Frequencies.
| | A briefing has been provided to the Operations Procedure Group to provide Management's expectations of clarity and level of detail in surveillance acceptance criteria. |
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| -This OD was generated based on a CR and the fact that the licensee did not plan to complete all vendor recommended breaker overhauls before restart from the current
| | Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
| - outage. While the team did not question the technical acceptability of not completing the overhauls, the OD did not provide suitable justification to establish operability. The team noted that Nuclear Oversight had also questioned the suitability of the OD documentation and appropriately issued a CR. Following identification of the issue by Nuclear Oversight and the team, the licensee completed an adequate rewrite of the OD that provided adequate additional detail to support continued breaker operability OD 97-98 - Failed Surveillance on Residual Heat Removal Pumo RHS*P1 A In December 1997, the licensee conducted an inservice test (IST) on the "A" residual heat removal pump. During the test, the required flow rate could not be achieved. The lower flow rate for the pump was recorded in the test procedure, the pump was declared inoperable, and a CR was written. Subsequent to the test, the licensee determined that the cause for the lower flow rate was a modification that limited the full open stroke of the recirculation mini-flow valve by installing a collar on the valve stem.
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| The CR written in response to the test failure recommended removing the collar on the mini-flow valve stem, opening the valve to it's previous full open position, conducting the IST at the old reference value, and then close the valve and establish a new reference flow value with the collar installed. The licensee chose not to follow these suggested recommendations and wrote an OD to justify that the pump had performed adequately, in that it met the TS required differential pressure on recirculation:.
| | Date When Full Compliance Will Be Achieved ~ |
| The OD stated that "... Since no test was performed prior to the modification, and the modification impacted the recirculation flow, the pump failed the IST due to flow violating the trending requirements. However, minimum recirculation requirements for this pump is recommended to be not less than 550 gpm. Since the actual recirculation flow of 583 exceeds the minimum requirements and the pump meets the TS differential pressure requirements, the pump is OPERABLE."
| | Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
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| The licensee also reviewed the IST program requirements to assure compliance with American Society of Mechanical Engineers /American National Standards Institute (ASME/ ANSI) OM-1987 through the 1988 Addenda, Part 6, Paragraph 4.4. The licensee submitted a code inquiry to the ASME Operations and Maintenance (O &
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| | U.S. Nuclocr Regulatory Commission |
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| | B17261\ Attachment 2\Page 4 Nuclear Reaulatory Commission Violation "C" (50-423/97-83-031 Restatement of the Violation TS 6.8.1 requires, in part, that written procedures sha!I be established, implemented and maintained covering the activities referenced in Appandix A of Regulatory Guide ! |
| | 1.33, Revision 2, February 1978. ) |
| | Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, item 2a, requires general operating procedures for cold shutdown to hot standby, item 3j requires procedures for startup operation and shutdown of safety related pressurized water reactor (PWR) systems for pressurizer pressure and spray control systems, and item 1d requires that administrative procedures covering procedure adherence and temporary change method be developed. |
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| M) Committee for help in interpreting the Code (Letter NNECo to O & M Committee, '
| | Contrary to the above, written procedures were not implemented as evidenced by the following examples: |
| l dated February 9,1998). Specifically, the licensee's objective was to determine if an IST was required to be conducted in the pre-modification condition, using the previous reference values, as described in the CR recommendations. In response to 4
| | ' Example 1 Operating Procedure OP 3301-G, step 4.1.6, requires the operators to place the pressurizer master pressure controller in automatic. |
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| the licensee's inquiry, the O & M Committee response (Letter O & M Committee to I l
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| | On April 12,1998 operators deviated from the operating procedure and did not place the master pressure controller in automatic in accordance with step 4.1.6. Instead they manually lowered the master pressure controller in an attempt to match the automatic and manual signals. This failure to follow procedures resulted in two inadvertent openings of the pressurizer power operated relief valve. |
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| | NNECO's Response NNECO does not dispute the cited violation. |
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| | Reason for the Violation The reason for this violation was the Unit Supervisor and the Reactor Operator did not operate the Pressurizer Master Pressure Controller properly due to a lack of understanding of the controller. Prior to taking the Master Pressure Controller from the manual mode to the automatic mode of operation (in accordance with step 4.1.6), the operator was instructed to adjust the controller (in accordance with step 4.1.5) to clear an annunciator that was lit. This caused the Pressurizer Overpressure Relief Valve (PORV) to open. This condition then resulted in setting up the controller to an output that would open the PORV for a second time wnen the 2200 psia interlock reset. |
| e NNECo, dated March 18,
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| ===.199 8) indicated that it is not the intent of ASME/ ANSI===
| | Personnel were performing the steps in accordance with the procedure, however, due to a lack of knowledge as a result of inadequate training on an infrequently performed evolution, the event occurred - |
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| OM-1987 through the 1988 Addenda, Part 6, Paragraph 4.4, to require an inservice .
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| test at the previous reference values whenever new reference values will be :
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| established due to system modification. Therefore, the O & M Committee position supported the licensee's decision net to remove the collar and conduct the IST at -
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| ~t he previous test conditions.
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| | 'U.S. Nucinar Regulatory Commission B17261\ Attachment 2\Page 5 Corrective Actions That Have Been Taken and Results Achieved Following the events, the l&C department was contacted to provide guidance on the operation of the Pressurizer Master F. essure Controller. Personnel verified that the controller was functioning properly and that the settings were appropriate. Once this determination was made and adjustments completed, automatic pressure control was achieved using procedure OP3301G. |
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| -The team determined that the RHR pump performance satisfied TS surveillance requirements, in addition, the licensee took appropriate action to verify that the ASME/ ANSI Code requirements were met.
| | Classroom training was provided to each of the operating crews to address both the lessons leamed from this event, as well as more specific details regarding the proper operation of the Pressurizer Master Pressure Controller under normal, abnormal and emergency operating conditions. The training session commenced with an introduction from line management which explained the purpose of the training, as well as a clear understanding of management's expectations regarding the safe operation of the plant through conservative decision making. Following the classroom training, simulator sessions were conducted where the terminal objective was for the operators to demonstrate their ability to transfer pressurizer pressure control between automatic and manual operation. This included hands-on training for the operation of the Master |
| | ' Pressure Controller as well as the Spray Valve Controllers. |
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| OD 45-98 - Excess Main Steam Bvoans Valve Flow.
| | Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
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| L The licensee identified that the steam flow rate through the main steam bypass valves , under certain conditions, could exceed the values described in the FSAR.
| | Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
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| The team noted that the licensee had not done a safety evaluation to determine if an unreviewed safety question existed. The cognizant engineer stated that it had been determined that the main steam line break analysis bounded this condition and therefore it was acceptable. The licensee plans to revise the FSAR to reflect the steam flow capability of the affected valves and a 50.59 evaluation will be performed as a part of the change process. The team determined that this was an acceptable resolution of this issue,
| | Example 2 Operating procedure (OP) 3201, Plant Heat-up", step 4.4.9, requires that steam generator level be maintained between 45-55%. |
| | On April 11, 1998, operators failed to maintain the level in the "C" steam generator between 45-55% during a plant heat-up. The level in the "C" steam generator dropped to the low-low level setpoint (18%) before level was automatically restored by the motor-driven auxiliary feedwater pumps. |
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| ====c. Conclusions====
| | NNECO's Response NNECO does not dispute the cited violation. |
| The OD process was comprehensive and provided thorough guidance on assessing the operability of plant systems. The team reviewed all open ODs and found, with one exception, that they were technically sound and documented an adequate basis for establishing operability of the degraded component or system. The one J exception was an OD regarding electrical breaker preventive maintenance ]
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| frequencies which was subsequently revised. This deficiency was also self- 1 identified by the licensee's Nuclear Oversight Organization.
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| The team concluded that the licensee has adequately addressed the OD aspects of SIL ltem 69. These findings also provide the team's basis for the closure of RAP items C.4, a. Operability of TS systems; b. Operability of required secondary and support systems; f. Significant hardware issues resolved (i.e. damaged equipment, | | Reason for the Violation The cause of the event was the failure of Control Room Operations personnel to diagnose that the Steam Generator "C" level loss was the result of an abnormal sampling blowdown lineup. Controlling the level in Steam Generator "C", was * |
| - equipment ' aging, modifications).-
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| E2.2. Enoineerina and Technical Suonort Effectiveness a.
| | cddressed by providing additional feedwater flow rather than placing a hold on the heatup and determining the cause of the level control problem. |
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| Scone l
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| i' The team evaluated the effectiveness of management of engineering work relative to the backlog. This included a review of open CRs and associated Action item Trending and Tracking System (AITTS) items to ensure they are properly prioritized and evaluated to support plant restart. The team also assessed System and Design
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| | U.S. Nucl:er R:gulatory Commission B17261\ Attachment 2\Page 6 An associated cause was insufficient planning and several delays during the initial i stages of heatup which challenged the shift's ability to meet a 24-hour surveillance criteria (Technical Specification 3.0.3 action) for Response Time Testing of the Turbine : |
| | Driven Auxiliary Feedwater Pump. Also contributing to the event was lack of testing of I the Motor Driven Feedwater Pump prior to use. The start of the Motor Driven Feedwater Pump occurred relatively late in the heat-up evolution providing a relatively , |
| | short period to recover from the Motor Driven Feedwater Pump startup problems. |
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| | i This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event l Report (LER) 98-C23-00, dated May 9,1998. (Reference Northeast Utilities Letter to USNRC, B17188). |
| Engineering's response to emergent (day-to-day) plant technical problems including an assessment of communications and interfaces, timeliness, and technical adequacy of the support. The system readiness reviews and quality of independent oversight of engineering activities were also reviewed.
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| | Corrective A Gons That Have Been Taken and Results Achieved The following corrective actions have been completed and are described in Millstone Unit No. 3 LER 98-023-00: |
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| Observations and Findinas Technical Suonort for Emeroent lasues The engineering department adequately controlled the work backlog and provided good support for day-to-day activities. The team attended many meetings where.
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| | | . The Steam Generator Blowdown Sample Isolation Valve 3SSR*CTV19C has been retumed to Service so the normal path for sampling has been made available. |
| management and engineering department supervision discussed plant issues and new CRs generated. The team found these meetings led to a good understanding by the engineering staff of priorities. The daily engineering morning meeting provided good discussion of possible upcoming issues and daily CRs and plant issues. The .
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| MRT meeting conducted after the daily morning meeting provided good focus on CR activities. System Engineers (SEs) maintained a good working knowledge of open AITTS items on their systems.
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| The team screened the list of open CRs that required engineering actions to close.
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| From this list the team selected approximately 150 for additional review, including CRs generated during the two week inspection period, and of these, the team reviewed approximately 100 in detail, and identified no restart issues.
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| The team also reviewed several issues, documented on CRs, for which the licensee generally took appropriate corrective action. The following two technical issues are representative of the type of review conducted by the team.
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| Boric Acid Transfer System Gas Pockets /Pumo Gas Bindina During the recent Corrective Action inspection (40500) the NRC identified that the licensee's actions to correct gas binding and accumulation in the boric acid transfer (BAT) system had been less than adequate. The'OSTl team reviewed the licensee's actions to address repeated air binding of the boric acid transfer pumps due to accumulations of air in the BAT piping. The team also reviewed the licensee's actions to address identified hydrogen accumulation in the BAT gravity boration lines.
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| The licensee conducted an adequate root cause analysis following the instance of air binding of the BAT pumps in March 1998, using appropriate tools to determine the causes of pump air binding following batch additions to the boric acid storage tanks. The same team developed a special procedure (SP) that allowed testing to establish the best way to make the batch additions from the boric acid mixing tank
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| to the boric acid storage tanks. Following the successful completion of this test, the operating procedure (OP) was revised to reflect the improved method. The team attended a pre-evolution briefing for tV first set of batch additions to be completed l^
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| ===.43 following the SP and revision to the'OP. The team found that engineering and===
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| operations worked well in coordinating these evolutions.
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| Following the first set of batches, operators started the "B" transfer pump and quickly secured it after observing indications of air flow through the pump.
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| Following this, engineering directed additional ultrasonic test measurements of piping to determine the extent of any gas accumulation. There was no specific indication of gas accumulation in the BAT pump suction piping. However, the licensee discovered gas, that was later verified to be hydrogen, downstream of the "B" system gravity boration block valve. This finding suggested the possibility that dissolved hydrogen from the volume control tank (VCT) was coming out of solution in the charging pump recirculation line.
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| In response to this issue, the licensee reestablished an ERT comprised mainly of the people who conducted the previous root cause analysis to continue the review of this issue. The team attended several meetings and discussed this issues with ERT members. The ERT meetings were well coordinated and appropriate assignment were made. The initial review showed that the running of the BAT pump after a batching operation along with the previous actions taken should be sufficient to ensure that the piping is vented.
| | . The Moto: Driven Feedwater pump was re-tested prior to heat-up. |
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| At the close of the inspection period the licenses recognized tnat the issues with respect to the gas binding of the BAT pumps and the gas accumulation in the gravity boron line needed to be addressed prior to restart and had appropriately included this issue as a restart item. The team assessed that the licensee was
| | . Operating Procedure (OP3201), " Plant Heatup" has been revised to place the Motor |
| ;taking adequate corrective actions to address the issue of BAT pump air binding and the gas accumulation in the BAT gravity boration lines. The licensee has appropriate short term actions in place to monitor and correct air binding of the BAT pumps and gas accumulation in the boric acid gravity drain lines. The licensee is evaluating long term actions to ensure the ability to makeup to the boric acid tanks and the ability to supply a gravity boration flow path to the charging pumps for safety-grade cold snutdown.
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| Svstem Readiness Reviews The system readiness review process was determined by the team to be a strength.
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| The system readiness reviews required the SEs to conduct a broad review of several aspects that contribute to system readiness. The team reviewed seven Mode 4 system readiness reviews. The system readiness reviews were comprehensive. The system deficiency backlogs had been appropriately reviewed and dispositioned. The l team determined that the SEs were knowledgeable of the system readiness reviews 1
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| and were aware of plans to address those issues needing corrective action prior to i Mode 2.
| | Driven Feedwater pump in service prior to exceeoing 470 degrees F for the Reactor Coolant System. |
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| l System Walkdowns l
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| The team walked down several safety systems and conducted discussions with SEs regarding system status. The SEs were very knowledgeable of the open issues and thoroughly involved in issues related to their systems and Mode 2 readiness. The technical support department was nearly fully staffed and used a small number of contract engineers. Engineering personnel at all levels shared the philosophy that problems needed to be fixed rather than justified by engineering evaluation. Also, there appeared to be a common goal to minimize the number of temporary modifications.
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| During plaint walkdowns, ti e team raised numerous issues, which the licensee provided adequate information to address. These walkdowns confirmed the status of these systems with respect to restart readiness. The team identified one issue regarding post accident system leakage that requires additional action to properly characterize the significance of this issue.
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| Residual Heat Removal System Leakace The team found that the licensee had not fully addressed the effect of possible post accident water leakage from the recirculation spray system (RSS) into, and then from, the RHR components known to leak during unit cooldown operations. In review of the RHR system, the term noted that an EWR to replace the pump seals was deferred and that a CR identif ed leakage from the heat exchanger during initial shutdown cooling operations. The team also noted catch containments installed around the heat exchangers, directing any leakage to the floor drains. While the RHR heat exchangers will be pressurized following some design basis accident, they are not used as part of the emergency core cooling system for heat removal.
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| The team questioned if this leakage had been accounted for in the assessment of possible offsite doses and minimized according to TS 6.8.4. The licensee stated that while they believed the leakage only occurred during the initial phase of plant cooldown (approx. 350 psi); however, they had not specifically developed any pressure to leakage relationship or docarund this perception. The licensee stated that they planned to monitor leakage darirg de upcoming cooldown to Mode 5 and, if necessary, address the leakage. The team considered this an Unresolved item pending results of the RHR system leakuge assessment ralative to TS 6.8.4,
| | . The Operations crews have received classroom and simulator training on lessons learned from this event. |
| " Primary Coolant Sources Outside Containment" (423/97083-08).
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| Independent Oversiaht of Enaineerina The team reviewed the Nuclear Oversight Restart Verification Plan for engineering and discussed performance with the asse:ssors. The team found that the assessors were involved and knowledgeable of potential issues and problems. The team found that the NORVP meetings were well orgtnized and presented the information to appropriate levels of management.
| | . The Unit Director and Assistant Unit Director expectations for performing the heatup/startup activities have been discussed with each Operating crew. |
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| ( The team also found that the key perfortnance indicators for engineering provided good self-assessment information. This quarterly self-assessment provided clear
| | Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
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| | Date When Full Compliance Will Be Achieved |
| k methods of measuring and assessing engineering performance in areas such as the overall conduct of engineering, system readiness reviews, temporary modifications, .
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| ' adequacy of design changes, and the effectiveness of the modification process.
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| . The tearn noted that the engineering assurance group had conducted several audits of the modification process within the last year. These audits provided good detail -
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| and recommendations to improve performance.
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| ====c. Conclusions====
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| The engineering department managed the observed day-to-day work activities well.
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| Daily prioritization of emerging issues at the morning meeting and MRT set the
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| . priorities of the system and design engineering. The CR and AITTS systems supported tracking of open items. The MRT appropriately screened CRs on a daily basis and implemented ERTs and sponsored root cause investigation as needed.-
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| iThe use of the CR system appropriately' captured issues. The team did not identify.
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| any CR issues that had not been properly screened for deferral until after the -
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| restart. However, the team identified one issue regarding post accident RHR heat exchanger leakage that requires additional evaluation to properly assess the significance of this issue.
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| . Nuclear oversight and engineering self assessment activities, including engineering
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| assurance, provided good observations and methods for tracking recommendations made to improve performance.
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| These findings provide the team's basis for the closure of NRC Significant item List item 39, Review of Engineering Backlogs. These findings also provide the team's basis for the closure of RAP item C.2.2, c. Adequate engineering support as demonstrated by timely resolution' of issues; C.3.2, s. Corporate staff understanding of plant issues; C.3.2, b. Corporate staff site specific knowledge: C.3.2, c.
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| Effectiveness of the design / plant interface meetings; C.3.2, d. Corporate involvement with plant activities.
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| E3- Engineering Programs E3.1 .
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| Vendor Manual control
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| ====a. Scope====
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| -The team reviewed the licensee program and procedures for the ' control of vendor equipment technical manuals to verify the measures are in place to provide current information regarding safety-related equipment. Licensee self-assessments in this area were also reviewed to assess adequacy of the reviews and corrective ' actions.
| | Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
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| Observations and Findinas
| | Example 3 l i Condition Based Maintenance Procedure CBM 105, "PM Program Changes and l Deferrals for U3", states that, " deferral requests are required if a PM ... cannot be performed within its grace peiiod." |
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| On June 30,1997, the licensee issued procedure DC16, " Vendor Equipment.
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| Technical information Program (VETIP)," to provide instructions for the controlling the receipt,~ distribution, and revisions of vendor technical manuals. The team found
| | On April 10,1998, a preventive maintenance task (automated werk order 96-12561) for |
| .the procedures thorough, containing good instructions for maintaining the vendor manual information and affected plant procedures current. One key point of the -
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| procedure was that it contains directions for upgrading key safety-related vendor technical manuals. The upgrade procedure was thorough and resulted in up-to-date, i . well-organized manuals, all assembled in the same format. At the time of this inspection, the licensee was comparing the upgraded manuals to plant procedures to determine if any procedure revisions were necessary because of any added vendor information. The team interviewed maintenance personnel reviewing the procedures and examined a sample of their findings. The reviews were thorough and comments well documented. Resolution of the comments was in progress at the time of this inspection and was scheduled to be completed before plant restart.-
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| The licensee had not identified any issues during these reviews that would have affected equipment operation.
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| The team also determined that the January 1998 VETIP Self-Assessment, documented in report PES-97-O38, was thorough and provided several
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| recommendations to improve the program. The engineer responsible for the upgrade program was revising procedure DC-16 to include the appropriate '
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| recommendations. Following the issuance of the procedure revision, training will be conducted for the affected plant staff.
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| Upgrades of the remaining safety-related equipment manuals will also be done as part of an ongoing program that will continue after restart.
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| ====c. Conclusions====
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| The licensee established a program to maintain the accuracy of vendor manuals, including appropriate actions to upgrade the key safety-related manuals and review affected procedures before restart.
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| E3.2 Setooint Controls r
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| Scone The team assessed the setpoint control process for safety-related plant equipment.
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| The team selected several setpoints for safety-related functions and assessed their adequacy relative to the parameter of concerns and its safety function basis.
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| Observations and Findinas
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| ' The team found that an adequate process was in place to control setpoints. The team reviewed Specification SP-ST-EE-329, " Standard Specification for Use and Control of Master Setpoint Index," Rev. 2, and Sections 1.5.8,1.8 and 1.13.3 of F the Design Control Manual. In the Design Control Manual, changes to setpoints are E _
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| '47 treated as design changes and receive the same controls. Additionally, the Master Setpoint index (MSI) provides a listing of setpoint databases and documents that contain controlled setpoints, it can be used to locate specific setpoints and applicable databases or documents. Following a setpoint change, the MSI helped to ensure the updating of appropriate databases and documents.
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| The team reviewed two setpoint calculations and found that each conformed to the .
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| . procedures and was acceptable.
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| * The team reviewed calculation 12179-SP-3HVP-5, dated August 18,1997,.
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| which documented the change of the setpoint for the emergency diesel-t generator (EDG) enclosure temperature from 100 to 75 degrees Farenheit : ..
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| L (*F) and found the calculation to be acceptable. The original calculation was
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| !" done by the architect engineer and consisted of a statement of engineering judgement to set the controller to 100*F to open dampers to maintain -
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| maximum temperature under 120*F. The decision to go to 75'F was based upon the intent to maintain the EDG enclosure at a more desirable environment for equipment and personnel. The setpoint for control of the >
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| ' dampers in the EDG enclosure is not subject to the requirements of NRC Regulatory Guide 1.105, " Instrument Setpoints for Safety Related Systems,"
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| because it is not used to initiate automatic protective action or alarms.
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| .- The team reviewed calculation 12179-SP-3SWP-1, " Service Water System
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| Intake Strainers." Operating experience dictated the evolution of the setpoint for actuation of backflush from 1.5 to 4.0 pounds per square inch differential pressure (psid). The setpoint for the annunciator in the control room is set at 4.5 psid to avoid spurious alarms in control room. The team interviewed the engineer responsible for the strainers and examined a strainer. The strainers are sturdy and not subject to perforation during backwashing. The strainers are designed to withstand 8 psid without collapsing. The team found the calculation to be acceptable,
| | the turbine auxiliary feedwater pump govemor had not been deferred or performed , |
| | within its grace period. |
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| ====c. Conclusions====
| | NNECO's Response NNECO does not dicpute the cited violation. |
| The licensee implemented an adequate setpoint process that met industry standards. The several setpoints selected for review by the team were properly documented, reviewed, and supported by appropriate calculations.
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| : E3.3 Equioment Qualification a.
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| Scann The team reviewed common station procedure, " Commercial Grade Dedication,"
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| NUC MPM 3.01, Rev. 2, and interviewed the engineer responsible for the dadication of electricalitems.
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| | 'U.S. Nuclxr Regulatory Commission B17261\ Attachment 2\Page 7 Reason for the Violation The reason for this violation is attributed to personnel error in performing scheduling activities. Within the Millstone Unit No. 3 power ascension schedule there were three ascension to Mode 3 activities which represented: 1) the first heat up to Mode 3, 2) the repair contingency window, and 3) a contingency repair window that followed the turbine generator overspeed testing. The responsible individual incorrectly scheduled the Preventive Maintenance for changing the oil in the Turbine Driven Auxiliary Feedwater pump governor during the third ascension to Mode 3 which was scheduled for May,1998. The " Preventive Maintenance Change and Deferral Request" submitted , |
| | by Work Planning for this component was properly approved for deferral with the intent that the maintenance would be completed prior to steam admission. The individual did not self check his performance when scheduling this activity. |
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| | Corrective Actions That Have Been Taken and Results Achieved in response to this scheduling error, the individual's supervisor reviewed the details of i the "Stop - Think - Act - Review" (STAR) program with him. The individual was also I |
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| | ' counseled regarding management's expectation to take the necessary time to assure f that the work is perfonned properly. ' |
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| | Corrective Actions to Avoid Future Violations , |
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| | No additional corrective actions are deemed necessary. |
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| | Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
| The team reviewed the licensee program and procedures for conducting item equivalency evaluations (IEEs). This process provided for performing administrative item evaluations, cross-reference evaluations, and alternate item evaluations. The purpose of this program is to perform a techaical evaluation of replacement items for which a design change was not required, b.
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| Observations and Findinas The team found that the commercial grade dedication procedures were technically sound and provided adequate controls. This procedure provided reasonable assurance that a commercial grade item selected for use in Category I applications would perform its safety-related function. The engineer demonstrated knowledge and understanding of the requirements and process for commercial grade dedication. Team members reviewed the packages for two commercial grade items, observing adequate use of procedures. Packages reviewed were: MP3-05-0220 which dedicated a 2N2920 dual NPN transistor and evaluation 00216856, which dedicated an indicating assembly used in the main control room.
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| The IEE procedures clearly delineated when the particular types of evaluations may be used and when the design change process must be applied instead of an item equivalency evaluation.
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| | 'U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 8 Nuclear Reaulatory Commission Violation "D" (50-423/97-83-04) |
| | Restatement of the Violation Technical Specification (TS) 3.4.9.2 requires, in part, bat pressurizer temperature shall be determined to be within the limits at least once per 30 minutes during heat-up or cooldown. |
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| The team reviewed the referenced procedures, interviewed a member of the procurement engineering group involved in performing evaluations and reviewed a sample of completed IEEs. The team found the procedures to be of good quality and the engineer was very knowledgeable of the process. The evaluations reviewed were thorough and applicable data bases and documents were properly updated.
| | Contrary to the above, on April 1,1998, pressurizer temperature was not determined to be within the limits at least once per 30 minutes during a plant heat-up. The pressurizer heat-up rate was not compared to Technical Specification Limits between 0400 and 0445 hours as required. |
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| The program effectively involved the appropriate departments, such as design engineering, in the evaluation review process and in the implementation of evaluation results such as updating of procedures or specifications. Required actions associated with the evaluations were entered into the AITTS system for tracking to completion.
| | NNECO's Response NNECO does not dispute the cited violation. |
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| | Reasort for the Violation The cause of this event is attributed to human error. The Operator was aware that |
| | * Reactor Coolant System and Pressurizer heat-up surveillance were in progress. The Operator recorded the Reactor Coolant System heat-up rate as required, but inadvertently did not take the Pressurizer heat-up rate data, which was on a second data sheet. Historical computer point data were extracted from the plant computer to verify Technical Specification limits were not exceeded. |
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| ConclusiDD The licensee implemented effective commercial grade dedication and item Equivalency Evaluation programs to support plant restart.
| | Corrective Actions That Have Been Taken and Results Achieved The operator was counseled regarding this event and his performance. The individual was reminded of the importance of proper turnovers and performing surveillance when required. A lessons learned summary was developed and shared with the Operations Department. |
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| E3.4 Ooeratino Exoerience Progtam a.
| | A training session was provided to the on-shift members of the Operations Department which incided a specific section in the lesson plan regarding this event. Discussion during the lesson included the event, the apparent cause, review of the lessons learned, and a question and answer period. An Operations Briefing Sheet was also provided to the department detailing the importance of pre-job briefs, understanding the i task at hand, and the individual roles and responsibilities required when performing the task. |
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| Scong The team reviewed the licensee operating experience program and procedures to assess the adequacy of the program. The team also reviewed a sample of operating experience evaluations to assess their adequacy and timeliness. The status of open l- operating experience issues was also reviewed to determine if the licensee had
| | Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
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| ' addressed all issues necessary to support plant restart.
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| ' | | ! Millstone Unit 3 is in full compliance with respect to the cited violation. |
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| Observations and Findinas The Nuclear Safety Engineering (NSE) Group administers the operating experience assessment program as described in procedure NOOP-3.04, " Nuclear Safety Engineering Group Functions and Responsibilities -Independent Safety Engineering
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| ' Group and Operating Experience Assessment." A new procedure, NSE 1,
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| | 'U.S. Nucl=r Regul: tory Commission B17261\ Attachment 2\Page 9 Nuclear Reaulatory Commission Violation "E" (50-423/97-83-06) |
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| | Restatement of the Violation Criterion XVI of 10CFR 50, Appendix B, requires, in part, that measures must be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. For significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. |
| " Implementation of Operating Experience," became effective on April 4,1998. This procedure supplements NOOP-3.04 and incorporates a multi-discipline review of NSE evaluation recommendations. The procedure also contains expectations for the day to-day ute of operating experience by other plant departments. The team also noted that in addition to providing recommendations, NSE also tracks and verifies implementation of recommended actions before closeout of an evaluation.
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| ~ The team reviewed a sample of operating experience evaluations, and found them .
| | Contrary to the above, as of April 13,1998, appropriate corrective actions were not taken to prevent recurring system alignment deficiencies that were identified in an investigation report, " Configuration Control of Valves Switches / Breakers, CR M3-97-0485". These deficiencies included valves not properly aligned, inadequacies in the implementation of the valve and breaker alignment process, and deficiencies in the implementation of the locked valve procedure. |
| to be thorough, well documented, and provided appropriate recommendations. The | |
| - team reviewed the backlog of open evaluations and found that the licensee had reviewed each item for its potential effect on Unit 3 restart. The licensee had a sound basis for those items that could remain open following plant restart.
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| | NNECO's Response NNECO does not dispute the cited violation. |
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| Conclusions The team concluded that the operating experience program was functioning adequately to support restart. The backlog of reviews was not excessive and had been evaluated by the licensee to identify those issues requiring review before restart. The licensee has also taken actions to increase the use of operating experience information by all plant departments.
| | Reason for the Violation The reason for this violation is attributed to management's failure to establish and implement a comprehensive program to adequately document and track component alignment deviations controlled by existing processes / procedures. Although existing i processes / procedures are in place to control the individual aspects of component ! |
| | alignment, there has been inadequate integration of these processes / procedures into an effective common program with a single owner. |
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| . These findings provide the team's basis for the closure of RAP items C.2.2, e.
| | Specifically, at the time that Condition Report M3-97-0485 was being investigated, management did not recognize that the existing program was not adequate. On the contrary, the investigation determined that the program / process / procedures in place at the time were adequate and that it was a matter of individuals not implementing the program correctly. The investigation into these recent examples recognized that the existing program / process / procedures are not well integrated and that thic was the cause of the event. |
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| Effective information exchange with other utilities; C.1.4 b. Effectiveness of industry experience review program.
| | Corrective Actiorr, That Have Been Taken and Results Achieved |
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| | Numerous corrective actions have been taken to address the items noted in the |
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| | inspection Report regarding Configuration Control at Millstone Unit No. 3. These items are detailed as follows: |
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| IV. Maintenance and Surveillance M1 . Conduct of Maintenance a.
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| | 'U.S. Nuclur Regulatory Commission B17261\ Attachment 2\Page 10 Procedure RP4, " Corrective Action Program", has been revised to ensure that the proper level of approval is provided for the extension of any corrective actions tn prevent recurrence. |
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| Insoection Scone The team evaluated the effectiveness of the plant maintenance program. A sample ~
| | Each of the mispositioned valves identified in the OSTI Inspection Report were verified to be placed in their proper alignment. |
| of maintenance procedures and work packages.was reviewed to evaluate their
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| . quality. The team assersed the conduct of maintenance, including management -
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| involvement and procedur's ^ adherence, by observation of maintenance work-
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| - activities. The team also reviewed the licensee's process for evaluating risk when
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| : taking equipment out-of-service for maintenance. An assessment of the Fix-It-Now '
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| (FIN) team'and the control of ~ measuring and test equipment was also performed.
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| The team also reviewed the post maintenance test failure rate and the maintenance rework rate to assess the quality of maintenance. | | The Millstone Unit No. 3 Operations Manager reinforced procedure compliance with Operations Department personnel with respect to the procedure requirements in DC4 (Procedure Compliance) that allow the use of "NA's" on procedures and forms. |
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| | Additionally, there was a discussion regarding where to document the bases for each use of a "Not Applicable" statment, and that pen and ink changes to component configuration on forms are not allowed. (DC 1) |
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| | The locked valve program was audited by the line organization to Operations Procedure OP 3260B " Equipment Control" and discrepancies resolved. An evaluation ' |
| b. Observations and Findinos Maintenance Procedures and Adherence During the field observations, the team evaluated the performance of maintenance personnel including quality of, and adherence to work instructions, and procedures.
| | of systems not presently included in the locked valve program was performed against |
| | . the criteria'in OP 32608.- |
| | Completed valve lineup forms required to support the startup of Millstone Unit No. 3 were reviewed in order to identify deviations from approved lineups. The deviations t identified in the completed lineup forms were resolved by making procedure changes as necessary. Valves in the lineups that were repositioned after the date of valve lineup completion had their pc.,sitions verified. |
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| - The team concluded that workers were following procedures, that procedures were appropriate to the circumstances, and that work packages and procedures were being revised when appropriate. Work activities observed by the team included
| | OperatinD Procedure line-ups were reviewed to identify references to throttle valve positions, and appropriate procedure changes entered to provide necessary guidance for their settings. Throttle valve positions were verified in the field to assure that components were properly positioned. |
| . effective pre-job briefings and shift turnovers. The maintenance staff was knowledgeable of their assigned tasks and had received adequate training to conduct these tasks in a competent manner.
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| Observations of Maintenance Activities Dj.gsel Buildina Ventilation When problems occurred during an activity, the workers stopped work and contacted their supervision to resolve the problem. For example, while attempting to install a Hydramotor actuator on the emergency diesel generator (EDG) building inlet damper, the electricians stopped work and asked for further instructions when they found that the support bracket did not fit properly.
| | Procedure OP 3260B was revised to clarify requirements for verifying positioning of locked throttle valves and criteria for independent verification selection requirements. |
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| In another example, when an unexpected problem arose the licensee's maintenance, planning, and engineering departments worked together to quickly resolve the problem. Following the installation of the EDG inlet damper Hydramotor actuator, the electricians accidentally damaged the actuator. Since the completion of this job was critical path, the licensee decided to repair the actuator in place. While the engineering department was evaluating the actuator damage, the electricians used a spare actuator as a mockup to practice the replacement of the broken part. By the time engineering and planning had made the necessary procedure changes and obtained the replacement part, the electricians had practiced the replacement several times and the repair went smoothly.
| | Procedures were reviewed to determine if independent reviews were properly documented on the valve line-up sheets. Valve line-up sheets were reviewed and field walk-downs conducted to verify proper positioning. |
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| Valve Reoair On April 21,1998, the team observed work performed in accordance with 1 automated work order (AWO) M3-97-20166, " Pressure Indicator 90A lsolation l
| | The surveillance schedule was updated to include the audit of locked valves in accordance with OP 32608. In addition, the other 3200 series procedures were |
| Valve Leaks by Seat." Procedure MP 3718AB, " Repair of Bonnet Type Valves," was i
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| | reviewed for frequency based performance requirements. This effort identified two enhancements that were incorporated into existing tracking programs to assure proper scheduling and performance. |
| l used effectively by the maintenance personnel. Clearance 3-0861-97 was I determined by the team to be adequate for personnel protection, properly j established, and well understood by the mechanics performing the job. A foreign l materials exclusion area was properly established while the system was breached.
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| During the evolution, the mechanics determined that new packing was needed for a l l proper repair of the valve. The work package designated the packing type, amount, and part number, but it was not available in the shop. Administrative activities i
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| required to draw the new packing from the warehouse took more than a shift, significantly delaying the completion of the job.
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| | 'U.S. Nucirr Regulatory Commission B17W%ttachment 2\Page 11 The Engineenng Department evaluated the criteria for labeling of valves for vendor supplied skid mounted equipment. The program was determined to be adequate from the viewpoint that valves that are acaally positioned by the operators in the field are labeled, and those that are not labeled were determined to be maintenance convenience valves (e.g., valves such as petcocks are used to avoid having to remove a pipe cap). |
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| Breaker Repair While using AWO M3-98-03133 to troubleshoot a 4160 Volt circuit breaker, the electricians stopped work and requested a work order change, when it became apparent that the breaker would have to be disassembled which was outside the approved work scope. Operators had requested maintenance on the breaker because it couid not be charged after being racked in. The electricians determined that the cause of the malfunction was a roller shaft that did not return to its fully released position which was necessary for the electrical contacts to close and -
| | Two systems were reviewed to determine if the proper level of electrical components were included on valve line-up sheets. The Emergency Diesel and Quench Spray Systems were both reviewed and determined to either have the appropriate components listed or they were addressed in other Operating Procedures. |
| supply power to'the charging motor. The problem was caused by lack of lubrication or hardening of the grease on the roller shaft bearings. The breaker ha.d not -
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| undergone an overhaul under the preventive maintenance (PM) program (discussed in Section M4 of this report) and therefore, still had the old type grease. The licensee planned to revise the work instruction for all the affected parts to be disassembled, cleaned and lubricated. The breaker will also be scheduled for overhaul as part of the licensee's PM program.
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| Resistance Thermal Detector (RTD) Replacement The team also observed the troubleshooting of the recently installed wide range hot leg RTD and associated circuit. Post installation meggering of the circuit revealed
| | A Multi-Discipline Configuration Control Task Force has been established to evaluate, trend and recommend improvements in the configuration control processes. This task force is intended to conduct review of configuration control incidents identified through unit generated condition reports, Nuclear Oversight audits, and regulatory inspection reports. The task force examines the programmatic aspects of both valve and electrical |
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| | . configuration control including but not limited to tagging, position verification, inaccessible valves, locked valves, and work practices. Results of the review are periodically sent to the Unit Director and the Vice President of Operations with reymmended actions to improve performance. The task force is chaired by a senior i manager with members that represent various departments from all three Millstone l Units. |
| that the resistance to ground was one megohm which was below the minirnum required 10 megohms. The RTD was determined to be the problem and not the circuit. The RTD was replaced and tested satisfactorily. The team noted that the instrumentation and controls (l&C) supervisor, I&C manager, and the maintenance msnager monitored this activity.
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| Fix-It-Now Team The team reviewed the FIN team activities. The FIN team was formed about 16 months ago and has 11 members, including two planners, and one parts person.
| | Active tag clearances were field " ified prior to restart to assure that components were properly positioned. No problems were noted. ' |
| | Peer checks have been implemented for operator actions during power ascension to increase assurance of the proper performance of sufety related operational procedures and surveillance. |
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| The FIN team works primarily on emergent work. They use the same procedures and processes that are in place for " normal" work; however, their work is not
| | Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
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| ' scheduled in the same manner as other work. For the period March 16,1998 through April 16,1998, the FIN team worked 78 AWOs,118 minor work items and 22 tool pouch items. Based upon a list of items worked and the guidance in procedure WC 1.1, Minor Maintenance Process Controls, the team determined that the work classification made by the FIN team supervisor for tool pouch and minor -
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| work was. conservative. For the past month, the FIN team has worked 218 Jobs with no rework. The team concluded that the FIN team had a very positive effect on
| | Date When Full Compliance Will Be Achieved l Millstone Unit No. 3 is 'n full compliance with respect to the cited violation. |
| < handling emergent work and reducing the backlog of AWOs.
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| Measurina and Test Eaulomant L
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| 52-The NRC 40500 inspection (NRC Inspection Report 97-82) noted that several issues associated with the Measuring and Test Equipment (M&TE) program were described in adverse condition report (ACR) M-1-96-0614. The team reviewed procedure WC 8, Revision 2, Change 1, " Control and Calibration of Measuring and Test Equipment," and ACR M-1-96-0614. The team discussed the changes in the M&TE program with the new director of the M&TE laboratory, interviewed technicians and toured the new facilities. Based on these inspections the team concluded that the licensee had:
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| e implemented a new procedure to centralize calibration of M&TE.
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| e Set up a central location for calibrations. In the past, each shop calibrated -
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| M&TE used in their shop.
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| e Established a centralized process for tracking M&TE Adverse Condition Reports (ACRs).
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| -e Established a training program for persons who check out M&TE for use in the plant, in addition, the M&TE lab personnel did a self-assessment and determined that the following three issues needed to be addressed:
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| : (1) adding staff to reduce work backlog;
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| : (2) a satellite contact at Unit 1 similar to those at Units 2 and 3 should be established; and
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| : (3) bar code readers should be purchased to expedite handling M&TE. The team determined the MT&E program was acceptable.
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| Risk Assessments The team reviewed the licensee's safety assessments made when removing equipment from service for maintenance activities. The licensee had a good program in place to assess safety while the plant was in cold shutdown. The licensee monitored time to core boiling, avai! ability of shut down cooling systems, injection sources, electrical power sources, and the status of containment closure.
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| However, the team found that the licensee was not performing safety assessments of maintenance activities after the plant exited Mode 5. The licensee did not have a process to perform these safety assessments while conducting maintenance activities in Modes 4,3, and 2. The licensee documented this concern in CR M3-98-1977 and directed that a safety assessment be performed by the licensee's PRA group prior to all planned maintenance.
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| l The team also identified a weakness in the licensee's process for assessing the l '
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| safety impact of performing maintenance activities while online. This process was
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| ; described in Work Control Procedure (WC) 14, "On-Line Scheduling." The team
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| - found that after the maintenance schedule freeze date, additions to the schedule
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| would not require safety assessments if the component being removed from service was not on a list of maintenance rule risk significant components. However, the
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| team noted that the risk of removing a component from service depended on the plant's configuration at the time of the mair.tenance activity and therefore the list in WC 14 may not be adequate. The licensee wrote CR M3-08-1978 to address this
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| I Maintenance Rework Rate
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| -The team reviewed a listing of all mechanical maintenance AWOs completed within the last six months that were determined to be rework. The rework rate for the last "six months averaged 1.4%. Data on all rework for safety and nonsafety-related AWOs for the period January 1996 through January 1998 indicated that rework was a relatively low percentage (less than 1 %). During the time period the team was on site the rework rate appeared to be above average.
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| The team concluded that procedure adherence by the maintenance staff.was good.
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| l The team' observed several instances where work was stopped to clarify or revise -
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| assigned maintenance tasks and had received appropriate training. Maintenance supervisory oversight in the field was strong.
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| The FIN team activities were considered an improvement to the maintenance program and had a positive impact on addressing emergent work and reduction of the AWO backlog. The team determined that the M&TE program was satisfactory.
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| The licensee's performance regarding assessing the safety of planned maintenance was mixed. Safety assessments for maintenance activities while the plant was in Mode 5 were good. However, the licensee did not perform safety assessments of maintenance activities after exiting Mode 5. The team also identified a weakness in the licensee's process for assessing the safety impact of performing maintenance activities while online.
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| The quality of maintenance activities varied. Rework was normally a small percent of the total work load; however,. rework was observed to be much higher than normal during the inspection period.
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| These findings provide the team's basis for the closure of RAP item C.4 h.
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| j Effectiveness of the maintenance program, i:
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| .M2 ~ ~ Maintenance Planning and Scheduling a.
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| Insoection Scone
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| - The team assessed the maintenance work planning and scheduling processes to j assure that they were adequate to track, prioritize and resolve safety significant plant equipment deficiencies in a timely manner.
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| Observations and Findinas Work Plannina The trouble reporting process was utilized by the licensee as the principle method of -
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| ' documenting material deficiencies in the plant. Once identified and documented a trouble report was evaluated by the FIN team. The condition was classified as minor maintenance or tool-pouch work or an AWO was issued. The team reviewed the
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| . trouble report backlog. The licensee tracked trouble reports greater than one week old. The backlog was averaging approximately 40 reports. The licensee had a goal of zero backlog trouble reports. The team found that trouble reports were being properly prioritized and resolved. The team determined that the backlog of trouble reports was being effectively managed.
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| The team reviewed the licensee's definition of maintenance backlog, associated goals, and maintenance work load not associated with the backlog. The definition was appropriate and consistent with industry standards. The licensee was making a reasonable attempt to meet their backlog goals. Completion and initiation rates for AWOs remained fairly constant throughout the inspection period. The online AWO backlog was decreasing at a reasonable rate,
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| The team reviewed 30 work packages. The work packages were found to be satisfactory. The work instructions were sufficient for the scope of work. Changes in the work packages or procedural steps had been performed in accordance with the appropriate administrative controls. Several self-identified deficiencies were noted in the work packages and were subsequently corrected by the licensee. For example, a number of work packages included a post-maintenance testing checklist that had not always been completed. The licensee identified problems with the use of this checklist and implemented corrective actions. The corrective actions taken appeared to be appropriate, and no examples of blank checklists were identified in the work packages reviewed after the date of the corrective action completion.
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| The work packages contain a feedback form to monitor the quality of the work planning. The team reviewed over 1700 planning feedback forms for work completed over the last year. Most of the 1700 feedback forms reviewed did not identify any work package problems. A few forms noted problems with procedures, locations, parts, tagging, post maintenance testing (PMTs) and job descriptions. For example,34 forms described parts problems (22 safety-related and 12 non safety-related) and 65 forms noted problems with job descriptions. In general, the j feedback forms indicated that the work packages were of acceptable quality.
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| Schedule Adherence The adherence to' plant schedules has been poor. On average, only 60% of work orders on the 3-day look ahead schedule were started and 54% were completed on schedule. The scheduled dates for achieving major milestones, such as mode changes, were rarely met. The difficulty in meeting schedules was attributed to
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| several factors including emerging issues, inability to identify work scope, and lack of accountability to meet schedules.
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| There was little discipline applied to freeze the schedule or to control the addition of items to the schedule. For example, over a hundred last minute items were added to the schedule one week before the first 12-week schedulod window. This occurred-even though several meeting had been held to develop the schedule.
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| - Plant staff members stated that there was a lack of commitment for meeting schedules and lack of accountability for missing them. For example, attendance at i~ the 12-week rolling schedule varied from week to week and so ne organizations did
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| not send representatives at all; some representatives did not come to the meetings with information needed to make informed scheduling decisions; and excuses regarding delays were accepted and supervisors were not held accountable for missing schedule dates.
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| A self-assessment by the Work Control and Outage Management staff in November 1997 identified a number of deficiencies in the scheduling process and in the management of this area. Based on the self-assessment findings,29 deficiencies and issues were defined and plans were developed to address each issue. The corrective actions were scheduled to be implemented through the summer of 1998.
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| One corrective action, to transition to a 12-week rolling schedule, began while the team was onsite.
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| in spite of the' problems noted, the team determined that the licensee's work schedule adherence was improving. The team noted that maintenance work backlogs had been decreasing since the beginning of the year.
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| The team did not find examples where inefficiency in planning and scheduling resulted in degradation of safety system performance, in fact, the team concluded that the material condition of safety-related systems was generally good. The corrective maintenance automatic work order backlog has been reduced to manageable levels and is nearing the licensee's restart goal of 500 open work ;
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| orders. The team also did not observe non-conservative decision by plant management for the sole purpose of meeting unrealistic plant schedules.
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| c. - Conclusions ,
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| Performance in the area of planning and scheduling during the current outage has been poor. Planning and scheduling deficiencies can indirectly impact safety when inefficiency diverts resources from safety-related work and when rushing to meet deadlines causes human error. The licensee has identified apparent causes of poor performance and corrective actions. The use of the 12 week rolling schedule should help stabilize and improve planning and scheduling performance. However, most corrective actions had not been completed at the time of this inspection. The team found no examples of where safety-related or maintenance rule equipment was not being maintained because of planning or scheduling problems. Therefore, the team
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| k concluded that the work planning and scheduling process was adequate to support plant restart.
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| These findings provide the team's basis for the closure of NRC Significant item List item 32, Work Planning and Control. Closure of this SIL item also include the team's review of NRC violation 94-16-05 and associated corrective actions. The team determined that the corrective actions were adequate and consider the violation closed.
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| l M3 Plant Material Condition a.
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| Scoon The team assessed the adequacy of the material condition of the plantiincluding a review of identified maintenance deficiencies to verify that plant equipment is acceptable to support a safe plant restart. The team reviewed identified deficiencies to ensure they were prioritized and corrected commensurate with their safety significance.-
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| Observations and Findinos Eauinment Monitorina The team reviewed a Unit 3 Quarterly Component Profile Report, dated November 6,1996, written by the Condition Based Maintenance (CBM) group in accordance with CBM-UNIT-403, " Component Diagnostics". The data used for this report was taken when the plant was in operation. About 180 components were included in the report, which listed the results of tests such as vibration, lube oil analysis, and motor current analysis. If conditions were abnormal, additional information was provided such as monitoring summary and maintenance recommendations. The
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| ' team noted that this effort provided valuable information regarding the condition of plant equipment.
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| Maintenance Backloa Manaaement Licensee management has reviewed the maintenance backlog for impact on operations, and any effect on equipment reliability. Each day, a meeting is conducted, with senior management in attendance, to assess the impact of all new trouble reports on plant operations. In addition, a scope control committee has been established to review all new trouble reports and AWOs to ensure that the affect of the work item on plant operation is assessed. The team attended meetings of these groups and determined that the process resulted in appropriate categorization of AWOs and trouble reports.
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| All corrective maintenance (CM) AWOs that were deferred beyond restart were reviewed by the team. The team selected 17 AWOs for detailed review. The licensee demonstrated that all 17 AWOs documented deficiencies that were appropriate to defer until after restart. The team concluded that the process for
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| ' deferral of AWOs was appropriate'and the deferred AWO resulted in no challenge to I safe plant operation.
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| The backlog was 762 AWOs (as of April 21,1998) with an additional 127 scoped for work in the current outage. The backlog continues to trend towards the licensea's startup goal of no more than 500 open AWOs. The total backlog of trouble reports has remained near 50 for the current year and does not have a significant impact on the backlog.
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| The licensee goal for overdue PM tasks was set at zero, although the licensee does allow procedurally defened PM tasks. Only 26 PM tasks scheduled for completion prior to restart had been deferred. These tasks were evaluated by the licensee and a change was made to the PM frequency. The total number of PM tasks were estimated at about 10,000 items. The team concluded that the licensee was placing a high priority on maintaining the PM backlog low, and that the tasks were being properly managed.
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| System engineers had conducted system readiness reviews on each of 146 '
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| i systems. These reviews evaluated each AWO in the backlog and assessed the
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| . aggregate impact of the total backlog on the system.
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| Plant Housekeenino and Eoulomant Storaae The licensee has published a " Maintenance Performance Handbook" that was {
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| distributed to all maintenance department workers. This handbook delineates i management's expectations regarding plant material condition. The items in the handbook were covered in an all day, off-site training program provided to all maintenance department employees. In addition, monitoring of housekeeping and
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| . equipment storage is covered under the maintenance department work observation program. Continued improvement is reinforced through daily department briefings and monthly department all hands meetings that discuss management expectations and problem areas.
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| Licensee audits reports indicate that plant housekeeping and equipment storage continue to improve at the site. Nuclear oversight, plant management, and operations department personnel observations report satisfactory performance in this area. The team independently verified these findings through plant tours, field observations, and system walkdowns.
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| - During field observations, tools and equipment were properly controlled and stored upon leaving the work area. Signs were placed at each job site to identify the work order, shop, and person responsible for the job. Foreign materials exclusion areas were maintained whenever open system equipment was unattended. Large components and tools were properly secured for seismic considerations. Rigging was tied off to prevent potential impact on safety-related equipment. Temporary staging was properly designated and scaffolding was erected in accordance with
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| p procedures. Maintenance personnel cleaned' work areas arid removed all parts and tools when jobs were completed.
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| .While witnessing jobs in the service building, the auxiliary building, and the EDG building the team found these areas to be clean, painted, well maintained, free of oil or water leaks and well lighted. System components including pipes, valves, relays, and electrical cables were clearly labeled. Following completion of w ork activities the workers cleaned up their work area and inspected it for obvious signs of damage. For example, when the technician finished the calibration of the chemical -
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| ' service building, he inspected the general area and found a loose grounding wire on a nearby cable which was subsequently tightened.
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| ====c. Conclusions====
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| The team determined that maintenance backlogs were being appropriately managed and the impact on operations was routinely assessed by licensee. The team found
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| - that the plant material condition and housekeeping were generally good.
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| These findings provide the team's basis for the closure of RAP items C.4, l.
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| Maintenance backlog managed and impact on operation assessed; C.4 J. Adequacy of plant housekeeping and equipment storage.
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| M4 Preventive Maintenance Program a.
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| Insnection Scone The team verified the adequacy of the preventive maintenance (PM) program, including selected verification that the preventive maintenance and PM frequency -
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| for safety-related equipment was appropriate based on vendor recommendations and equipment f ailure history.
| |
| | |
| b.
| |
| | |
| Dhantystiens and Findinas PM Proaram
| |
| '
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| , ,
| |
| i The PM program includes a set of regenerating work orders that were entered into production maintenance management system (PMMS). The team noted that the system may be' prone to human errors because it requires the planner to manually regenerate a PM during AWO closure or the PM would not be rescheduled. A CR (M3-98-2021) was written to address this potentici process weakness. The team -
| |
| (did not identify any cases were this potential process weakness manifested itself in
| |
| = inadequate scheduling of PMs.
| |
| | |
| J The team found 'that in some ' cases PM deferrals were not well documented or
| |
| - easily recoverable.' As a result of the team's concerns the licensee reviewed all PMs deferred over the past two years having a completion date after April 17,
| |
| '
| |
| , .c 1998. The licensee wrote a CR (M3-98-2058) to correct a few isolated cases where PMs were deferred without the proper deferral forms. The licensee revised the frequency of the 26 PMs to allow performance at the next refueling outage. The team reviewed the licensee's actions and found them acceptable.
| |
| | |
| Following the inspection, the licensee also reviewed PMs scheduled for the refuel outage to verify that the present two year outage had no adverse impact on the refueling outage frequency PMs. The licensee identified a few isolated cases where it was prudent to perform the PM. The PMs on these components was completed.
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| | |
| ' Manual Valves Used in Emergency Operating Procedures (EOPs)
| |
| The team questioned how the manual valves used in the EOPs were effectively maintained to ensure they would function. It was determined by the licensee that no PM task on these manual valves existed. A CR (M3 98-1564) was written to address this concern. The corrective action plan requ' ired that these valves be-identified and cycled prior to Mode 2. Approximately 50 valves were identified as needing a PM task or other means of test or inspection.
| |
| | |
| 4160 Volt Circuit Breakers PMs The team reviewed the preventive maintenance program for 4160 volt. General Electric (GE) Magna Blast circuit breakers. Detailed instructions for performing each step are provided in maintenance procedure (MP) 3783AA, "4160 Volt Breaker Preventive Maintenance." MP 3783AA-1 contains a list of inspections, adjustments, measurements, and electrical checks that are required to be performed every 18 months. The team reviewed the activities required by these procedures and found them to be very comprehensive for an 18 month PM. However, recently identified problems with hardened grease in circuit breakers elsewhere in the industry have highlighted the need to completely disassemble all moving parts, inspect for hardened grease and wear, and relubricate using a new non-hardening grease. GE recommended this overhaul every 5 to 7 years. The licensee was aware of these concerns and was participating in industry working groups to resolve the problems, including the appropriate overhaul interval. The known problems have occurred on breakers with 25 to 28 years of service. The Millstone Unit 3 breakers have been in service for about 18 years.
| |
| | |
| The licensee instituted an overhaul program for GE 6900 and 4160 Volt breakers in mid 1997, when they began sending the breakers to GE for overhaul. This overhaul included disassembly, cleaning and inspection of all moving parts, lubrication with a non-hardening grease (Mobil 28), and reassembly and testing. The 6900 Volt circuit breakers were sent first because they contained two heaters and were more likely to have age hardened grease. As of April 1998, overhaul had been completed on 30 out of 100 circuit breakers. The licensee plans to overhaul the remaining 70 breakers by December 1999._The licensee did an operability determination (OD
| |
| ; MP3-091-98) and concluded that it was safe to use the breakers awaiting overhaul.
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| l-q n --- -- -__________________ _ ____
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| . _ _ - _ .
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| _. - _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ -____
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| This conclusion was based upon the existing PM and surveillance testing programs and the long time period before the observed failures occurred.
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| | |
| Turbine ' Driven Auxiliarv Feedwater Pumo PM Turbine Trio / Throttle Valve
| |
| . On April 13,1998, the TDAWF pump trip throttle valve (3 MSS *MSV5) had
| |
| " hesitated, or stuck,' after traveling approximately 75% of full stroke," during cold start testing. The licensee was not able to identify a definite cause for the trip valve hesitation during closing. During several additional trip tests, the valve stroked satisfactorily. Based on this information and consultation with the valve vendor, the licensee determined that a valve disassembly was not required and that the valve -
| |
| was operable with no additional actions. The team noted that this action was not consistent with the vendor manual which recommended valve disassembly and cleaning for this type of failure.
| |
| | |
| On April 14,1998, the team observed the performance of Surveillance Procedure SP 3622.7, Auxiliary Feedwater Check Valve Operability Check. While preparing the system for operations and testing, the trip throttle valve failed to trip using the manual overspeed device as required by Operating Procedure OP 3322, " Auxiliary Feedwater System," step 4.4.12.b. The test was stopped pending an investigation of the failure. The licensee performed a preventive maintenance task on the emergency trip linkage spring and determined that the spring was out of adjustment. The as found preload was 11.5 lbs and the acceptable criteria is 30 to 34 lbs. Maintenance personnel adjusted the spring preload to an acceptable value.
| |
| | |
| The emergency trip linkage spring PM was conducted on a refueling basis vice the quarterly period as recommended in the vendor manual. During a records review, the team determined that the spring tension had failed to meet the acceptance criteria four out of five times it was measured, with no corrective action except to return the tension to within tolerance. The licensee wrote a CR and initiated actions to change the frequency of the preventive maintenance activity to check the spring from annual to monthly. The purpose of the trip / throttle valve is to assure equipment and personnen protection. The failure to properly adjust the emergency trip linkage spring would not adversely affect the TDAFW pump's ability to perform L it's intended safety function. The team considered this a minor violation and is not subject to formal enforcement action.
| |
| | |
| Oversoned Trio Also during Mode 3 testing, the turbine overspeed and tripped when operators secured AFW flow to the steam generators. The licensee determined that the cause of the overspeed trip was likely due to an incorrect adjustment of the compensating
| |
| . needle valve in the governor. The licensee replaced the governor oil and reset the compensating needle.
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| | |
| l'
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| ____ _ _
| |
| On July 29,1996, and again on September 9,1997, the preventive maintenance task controlled by AWO 96-12561 to change the governor oil on the turbine driven
| |
| ~
| |
| auxiliary feedwater pump was deferred. The September 9 deferral request clearly stated that the work order was deferred until " prior to steam admission." On April 13,1998, steam was admitted to the turbine during a cold start test of the pump.
| |
| | |
| The failure to perform the deferred PM task was not identified until April 15, when the governor failed to properly respond during testing. Failure to perform the PM task may have contributed to a turbine over speed trip at that time. The failure to perform PM Task 96-12561 within its pace period or to have a valid deferral at the time of steam admission is a violation of Procedure U3 CBM 105, "PM Program Changes and Deferrels for Unit 3," which states that deferral requests are required if a PM... cannot be performed within its grace period (423/97083-03).
| |
| | |
| Failure Historv The team reviewed previous problems with the operation of the TDAFW pump. Due to the current extended outage, the system has not been in operation since March 1996. Before that time three additional failures had occurred between September 1994 and March 1996 that resulted in licensee event reports (LERs). In September 1994 (LER 94-011-00), the AFW pumps started following a plant trip and the turbine driven pump tripped on overspeed approximately 8 seconds later. The cause was attributed to sticking in the control valve stem and/or linkage between the cor, trol valve and the governor, in November 1994 (LER 94-014-00), the TDAFW pump failed to start during a cold start surveillance test. The licensee determined that the likely cause of this failure were discrepancies with the trip valve linkage causing the trip valve to close before the turbine start. In May 1995 (LER 95-014-00), the TDAFW pump did not start and accelerate to normal speed within one minute as required by the TS. The pump actually required about three and a half minutes to reach normal speed during that test. The licensee attributed the failure to the position of the governor valve at the start of the test along with condensate in the steam supply line.
| |
| | |
| During the review of plant information reports associated with the above LERs the
| |
| -
| |
| inspector noted that there have been ongoing problems associated with the TDAFW pump since plant startup, including other instances of failures of the trip mechanism and overspeed trips.
| |
| | |
| Following the completion of the OSTI inspection, the licensee experienced additional problems with the trip throttle valve and overspeed trips.
| |
| | |
| The team concluded that the TDAFW pump has a history of poor performance as evidenced by the failure rate during testing and automatic starts of the pumps.
| |
| | |
| Although the licensee has taken many actions to resolve specific failures, these
| |
| ; actions have not resulted in sustained periods of satisfactory performance. The most recent ERT again focused on the immediate problems and did not factor in the full history of this pump. The team noted that the maintenance rule requires reliability and availability performance criteria to be established for this pump. If the L _ _ _ - . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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| y-- _ _-___________ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
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| o
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| '
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| performance of this pump fails to satisfy the performance criteria, corrective actions will be required to improve pump performance.
| |
| | |
| ====c. Conclusions====
| |
| ' The licensee implemented several actions in response to team findings in the area of preventive maintenance. These actions included verifying PMs were not inappropriately deferred, revising PM frequency for the TDAFW pump, and verifying
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| '
| |
| the function of manual valves used in the EOPs. The team concluded that, in general, the preventive maintenance program was being appropriately implemented and was acceptable to support restart.
| |
| | |
| The team concluded th$t the licensee has not'yet developed and implemented a l
| |
| comprehensive monitoring, testing and a maintenance program to improve the pump reliability. The team found that the turbine driven auxiliary feed pump, while -
| |
| addressed by.the MRT and an ERT for short term issues, needed additional attention l
| |
| to improve reliability and availability. The team considered the short term corrective action adequate. The team also acknowledged that routine required surveillance testing and the licensee's implementation of the maintenance rule should continue to monitor and make necessary system improvements M5 . Surveillance Test Program a.- Insoection Scone The team evaluated the adequacy of the surveillance test / test programs.
| |
| | |
| b.
| |
| | |
| Observations and Findinas The team reviewed surveillance tests required for restart. PMMS listings of surveillance tests required prior to mode change for each mode were reviewed. The performance record for completing surveillance tests was also reviewed. Schedule adherence for the surveillance test program was good. The licensee has a goal to complete over 90% of the surveillance tests prior to entering the grace period. For the past 12 weeks, they have been running between 93-100%, except for one week (week of 3/11/98) where performance fell to 86%. About 100 to 220 surveillance tests are scheduled each week. The team found the scheduling of tests to be appropriate. Based upon the good record of completing these tests, the team concluded that surveillance tests required for restart were being done. No problems
| |
| : with the evaluation of the tests were identified. The reviews indicated that past problems with surveillance test backlogs were corrected and the program is being properly managed.
| |
| | |
| The' team reviewed data packages from previous surveillance tests on auxiliary feed '
| |
| water (AFW) and quench spray system (OSS) and found no discrepancies. The team also reviewed task lists for QSS and AFW pumps and found that procedures were
| |
| ,
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| )
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| __ .___m___ . _ _ _ _ _ _ _ _ . _ _ _ __
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| ______ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ - _ __ - ___ - _ _ _ - _
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| L adequato and implemented inservice test (IST) and TS 4.0.5 requirements. The team found the IST requirements to be satisfied in the sample of work reviewed.
| |
| | |
| The Master Test List was updated and validated for Unit 3 by the licensee. Both TS and technical requirements manual testing requirements were provided the same controls. The team spot checked the master test list and no discrepancies were noted.
| |
| | |
| The team observed pretest briefing and start of the TDAFW pump testing. There
| |
| . was good coordination of three surveillance test procedures. The tests were stopped when termination criteria were met.
| |
| | |
| ! The team reviewed the basis for a licensee determination that the technical adequacy of l&C procedures were not adequate for restart. This determination was made in the December 1997/ January 1998 time frame based upon two problems with methods used to calibrate radiation monitors. The problems were resolved and the l&C procedures were determined to be adequate since early in 1998.
| |
| | |
| Containment Laak Rate Testina The team reviewed the containment leak rate testing performed in accordance with 10 CFR 50, Appendix J. The team found that six of the seven tests performed over the life of the plant for "as found conditions" for the measured combined leakage rate for all penetrations and valves subject to Type B and C tests failed to meet the .
| |
| 0.6 La TS acceptance criteria. Corrective actions taken were adequate to return the j worst leaking valves to an operable status. As left local leak rate tests were always j well within the TS requirements. The containment isolation system (system 3312A) 1 is an (a)(1) system under the maintenance rule. The team reviewed the licensee's corrective action plan and found it to be adequate.
| |
| | |
| J During a November 2,1997, revision of calculation CTS-CALC-010, "MP3
| |
| . Conversion of Containment Maximum Allowable Leakage Rate, La (wt%/ day) into La (scfh) Units," the licensee identified that previous revisions of the calculation had nonconservatively rounded the design input for containment free volume. Using more significant digits for the containment free volume resulted in a lower, more conservative, containment leak rate limit. Several surveillance test procedures required revision, prior to the next use, to reflect the lower containment leak rate limit. The team noted that the licensee had not yet changed the acceptance criteria for these surveillance procedures nor had a CR been written to track this change. To j address this concern, a CR was written to track revising the appropriate surveillance <
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| procedures.
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| c. - Conclusions
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| .
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| >
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| The team' determined that adequate controls were in place to schedule required l
| |
| - surveillance tests. Tests required for restart have been defined and satisfactory l
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| - - - _ _ _ _ . _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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| _ - _ - _ . _ _ _ _ - _ _ _ - _ _ _ _ ____- _ _ _ - -
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| progress is being made to complete these tests. The team concluded that the surveillance test procedures reviewed were adequate.
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| These findings provide the team's basis for the closure of RAP item C.4, e.
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| Adequacy of surveillance tests / test program.
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| V. Management Meetings The team held an exit meeting that was open for public observation, on May 5,1998. The ,
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| slides used by the NRC to conduct presentations during the exit meeting are provided as ,
| |
| 1 of this inspection report. The data base used to track inspector's requests / questions and licensee responses will be placed in the Public Docket Room.
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| I
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| . - _ __________-___-____Q
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|
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|
| PARTIAL LIST OF PERSONS CONTACTED Licensee B. Beckman, Maintenance Director M. Bonaca, Chairman, NSAB
| | ..,e |
| .'J. Chiarizia, Nuclear Training D. Cook, l&C Supervisor P. Dillon, Technical Support Supervisor C. Drane, Maintenance Supervisor W. Gambin, Nuclear Training -
| | , |
| T. Gilbert, Senior Engineering Technician P. Grossman, Director Unit 3 Engineering J. Harris, Unit 3 Self-Assessment Coordinator.
| | ' |
| | 'U.S. Nucirr Regul: tory Commission B17261\ Attachment 2\Page 12 Nuclear Reaulatory Commission Violation "F" (50-423/97-83 d} l Restatement of the Violation TS Table 3.3-1, Functional Unit 21, Action 5(a), requires, in part, that with a Shutdown Margin Monitoring channel inoperable, restore the inoperable channel to operable status within 48 hours, or verify valves as per Specification 4.1.1.2.2 (potential dilution |
| | { |
| | { |
| | paths), are closed and secured in position within the next four hours. |
|
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|
| P. Hinnenkamp, U3 Assistant Director D. Hicks, Unit 3 Director T. Houghton, Consultant R. Kacich, Director Special Projects
| | j |
| -W.-Kropp, Nuclear Oversight J. Langon, Operations Supervisor
| | ! |
| ' M. Noniewicz, Operations Engineer M. Pallin, Sr. Instructor
| | Contrary to the above, on April 8,1998, at 21:15 hours, 52 hours after declaring a { |
| . C. Schwarz, Unit 3 Planning and Scheduling Manager J. Streeter, Director Nuclear Oversight G. Swider, Unit 3 Technical Support Manager R. Young, Electrical Engineering Supervisor.
| | Shutdown Margin Monitor channel inoperable, the valves identified in Specification ' |
| | 4.1.1.2.2 had not been verified to be closed and secured in position. On April 9,1998, upon discovery of this deficiency by the licensee, the valves were verified closed and j secured in place. |
|
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|
| M. Covell, Director Corrective Actions S. Scace, Director Unit 3 Engineering INSPECTION PROCEDURES USED IP 93802: Operational Safety Team inspection (OSTI)
| | NNECO's Response NNECO does not dispute the cited violation. |
| ITEMS OPENED, CLOSED, AND DISCUSSED Qoened 50-423/97083-01 VIO failure to control operations procedure changes i: 50-423/97083-02 VIO failure to have 2-loops of RCS operable in Mode 4 l1 50-423/97083-03 VIO procedure adherence s/g level & master press. cntrl &
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| PM deferral 50-423/97083-04- VIO failure to log press. temperature 50-423/97083-05 IFl qualification of fire brigade advisor 50-423/97083-06- .-. VIO corrective action / system alignments
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|
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|
| ===.50 -423/97083-07===
| | Reason for the Violation The cause of this condition is attributed to human error in that the shift managers failed to recognize the need to complete the required surveillance in the allowed time. This oversight was due to poor prioritization of the required tasks during the shift which resulted in not assigning a responsible individual to perform these tasks. |
| VIO failure to surv. valves with SDM inoperable 50-423/97083-08 URI RHR heat exchanger leak rate
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| _
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| -_______m_ __ _____--_________-___e_--.__- _ __
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|
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| - _ - - _ _ _____ _ _ _ _ _ _ - _ - - _ - _ _ _ _ _ - _ _ - _ _ _ _ -_ -___ -
| | This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event Report (LER) 98-024-00 dated May 1,1998. Reference Northeast Utilities Letter to USNRC, B17189. |
| Closed Significant items List SIL 31 Work Arounds and Abuse of Olse-as-is Deficiencies SIL 32 Work Planning and Control SIL 39 Review of Engineering Backlogs .
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| SIL 69 Review of all Operability Determinations and By-Pass Jumpers before Restart -
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| Restart Assessment Panel items Management Programs and Oversight RAP item C.2.1, s. Goals / expectations communicated to staff RAP item C.3.1, c. Staff understands management expectations and goals.
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|
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|
| RAP item C.1.4, f. Effectiveness of PRA usage.
| | Corrective Actions That Have E>een Taken and Results Achieved The following corrective actions have been completed, some of which are described in Millstone Unit No. 3 LER 98-024-00: |
| | . Actions were taken to verify that the boron dilution pathways were secured. |
|
| |
|
| RAP items C.3.1 a. Demonstrated commitment to achieving improved performance, b.
| | . Shift personnel attended a training session with Unit Management where the I Operations Manager emphasized his expectations for effective conduct of shift turnover / briefs, with an emphasis on beightened operator awareness and efficient time management associated with " active" Technical Specification Limited I Conditions of Operation action statement requirements. |
|
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|
| Demonstrated safety consciousness (staff).
| | . Additional detail has been added to the Shift Daily Status Report in order to assure that Limited Conditions of Operation rewive the proper focus. These have been added up front in the report and are also discussed during the Shift Manager's |
| | | ' |
| RAP items C.1.3, c. Control of corrective action item tracking, d. effective corrective actions for the conditions requiring shutdown have been implemented, e. Effective corrective action for other significant problems have been implemented, f. Control of long-term corrective actions, g. effective corrective action verification process RAP items C.2.1, f. Management's ability to identify and prioritize significant issues, g.
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| | |
| Management's ability to coordinate resolution of significant issues, h. Management's ability to implement effective corrective actions RAP item C.1.4 d. Effectiveness of deficiency reporting system RAP item C.3.1 d. Understanding of plant issues and corrective actions (staff)
| |
| RAP item C.4 g. Adequacy of the power ascension testing program RAP item C.4 c. Results of pre-startup testing.
| |
| | |
| RAP items' C.1.4, c. Effectiveness of licensee's independent Review Groups, h. Review
| |
| , | | , |
| applicable external audits.
| | report at both the morning Work Planning Meetings and the Management Meetings. |
| | |
| RAP item C.2.1 d. Effectiveness of management review committees.
| |
| | |
| Operations RAP items C.2.1 b. Demonstrated expectation of adherence to procedures: C.3.3 f.
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|
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| Procedure usage / adherence.
| | o_ ; |
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|
| .. | | _-_---_---, |
| ____.._____._______.___.m________._m.-_._- . -
| | - - _ - _ _ _ - - - - - .-_ |
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| | e ., s |
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| | ~ |
| | 'U.S. Nucl:ar Regulatory Commission B17261\ Attachment 2\Page 13 Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary. |
|
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|
| RAP item C.3.3 a. Licensed operator staffing meets requirements and licensee goals.
| | Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation. |
|
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|
| - RAP item C.3.3 'g. Log keeping practices.
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|
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| RAP items C.3.1 e. Qualifications and training of the staff.
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|
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| RAP item C.2.1 e. Management's demonstrated awareness of day-to-day operational concerns.
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|
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| RAP items C.4 a. Operability of TS systems, b. Operability of required secondary and support systems, f. Significant hardware issues resolved (i.e. damaged equipment,
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| ' equipment ageing, modifications).
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|
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| RAP item C.3.3 b. Level of formality in the control room.
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|
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| RAP items C.3.1 g. Attentiveness to duty (staff), h. Level of attention to detail (staff);
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| .
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| '
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| .
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| C.3.3 d. Control room / plant operator awareness of equipment status.
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|
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| Engineering and TechnicalSupport RAP ltems C.3.2 a. Corporate staff understanding of plant issues, b. Corporate staff site specific knowledge
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| ' RAP ltems C.2.2 c. Adequate engineering support as demonstrated by timely resolution of issues, e. Effective information exchange with other utilities: C.1.4 b. Effectiveness of Industry Experience Review Program.
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|
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| Maintenance and Surveillance RAP item C.4 h. Effectiveness of the plant maintenance program.
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|
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| RAP item C.41. Maintenance backlog managed and impact on operation assessed, J.
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|
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| Adequacy of plant housekeeping and equipment storage.
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|
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| RAP items C.4 e. Adequacy of surveillance tests / test program.
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|
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| Updated RAP item C.4, d. Adequacy of system lineups l'
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| u
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| ~
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| l l
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| !
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| ,
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| . -
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| ;
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| LIST OF ACRONYMS USED
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| -ACP- administrative control procedure ACR 9erse condition report ..
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| AEOD- analysis & evaluation of operational data AFW auxiliary feedwater I AITTS- action item _ trending and tracking system: I AWO automated work order BTP branch technical position CBM condition based maintenance CFR code of federal regulations CM ' corrective maintenance CO. - control operator .
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| COP common operating procedure CR .
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|
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| condition report
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| ,CVCS ' chemical and volume control system DCM design control manual EDG emergency diesel generator
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| 'EOC- equipment outage code EOP.
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|
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| emergency operating procedure
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| .ERT . event review teams EWA engineering work authorization EWR.
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|
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| engineering work request FF functional failure FIN fix-it-now FSAR final safety analysis report GE general electric GPM gallons per minute INPO institute of nuclear power operations l&C instrumentation and control lees item equivalency evaluations IST inservice test KPl key performance indicator LCO limiting condition for operation LER licensee event report LLRT local leak rate testing j
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| M&TE measuring and test equipment MDMFP motor driven main feedwater pump
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| : MP - maintenance procedure MPR- master pressure controller MRC' management review council MRT - management review team MSI master setpoint index N/A' .not applicable NGP. ..
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|
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| nuclear group procedures
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| 'NNECO'_ northeast nuclear energy company-L NOT/NOP normal operating temperature and pressure nuclear oversight restart verification plan .
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| '
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| l NORVP
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| .NRC . nuclear regulatory commission
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| __ _ . _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _
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|
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| NRR nuclear reactor regulation NSAB' - nuclear safety assessment board NU northeast utilities -
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| OD operability determinations O&M operations and maintenance OP operating procedure
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| ! OPS operations
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| .ORP operational readiness plan NU OSTI operational safety team inspection PEO plant equipment operator.
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|
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| PDR public document room P&lD .
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|
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| piping and instrument drawing c PORV_- power operated relief valve
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| '
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| PRA' probabilistic risk assessment PIPS performance improvement plans PORC plant operations review committee PM' preventive maintenance PMMS production maintenance management system PMT post maintenance test
| |
| . PSID pounds per square inch differential
| |
| ' PUP procedures upgrade program PWR . pressurized water reactor QSS quench spray system RAC resource allocation committee RAP nrc restart assessment panel RCP reactor coolant pump RCS reactor coolant system -
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| RHR residual heat removal RSS recirculation spray system RWST refueling water storage tank RTD resistant temperature detector SAT systems approach to training SDM shutdown monitoring SDM startup duty manager SE system engineers SlH safety injection high pressure SIL- significant issues list SM shift manager SORC site operations review committee SP surveillance procedure SPO- special projects office SRO- senior reactor operator STA- shift technical advisor -
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| _
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| STAR stop-think-act-review
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| -SG . steam generator -
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| SI- safety injection -
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| SSC.
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|
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| systems, structures and components ST- surveillance test
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| '
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| TDAFW- turbine driven auxiliary feedwater
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| _
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|
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| - - - _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ -- _ . _. _-
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| TM temporary modification
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| -TS - ' technical specification TORS task qualification records URI unresolved item :
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| US
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| '
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| unit supervisor UT ' ultrasonic test VETIP vendor equipment technical information program
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| - WC ' work control .
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| l ,
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| l i
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| l: .
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| .
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| _ __ - .__._____..__..______.____.________.__U
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|
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| .
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| PARTIAL LIST OF
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|
| |
| =DOCUMENTS REVIEWED=
| |
|
| |
| Manmaament Proorams and Oversiaht:
| |
| EN 31094, Rev. O, " Millstone Unit 3 System Engineer Walkdowns," 4/30/97
| |
| EN 31097, Rev. O, " Millstone Unit 3 System Readiness Review," 3/29/98
| |
| _
| |
| Engineering Support Curriculum Advisory Committee Meeting Minutes .;
| |
| Engineering Performance improvement Plan, Revision 1,2/5/97
| |
| Expectations for Management Oversight in the Control Room,4/18/98
| |
| Millstone Station Engineering Support Personnel Job Performance Requirement and Task
| |
| List For Training
| |
| Millstone Station Engineering Support Personnel Orientation and Position Specific Training
| |
| Task List, 2/26/98
| |
| Millstone U3 Performance Indicator Report 4/17/98
| |
| . Millstone Unit 3 Technical Specifications Section 6.5,3. " Nuclear Safety Assessment
| |
| . Board"
| |
| MP3 Corrective Action Program improvement Plan Revision 2,1/20/98
| |
| Mode Change Assessments,4/16/98
| |
| 1996/1997 Maintenance Improvement Plant Millstone Unit 3, Phase I, Rev. 2 12/11/96
| |
| '1998 Operations improvement Plan Millstone Unit 3,4/15/98
| |
| 1998 Maintenance Performance Management Guidelines,4/2/98
| |
| NGP-2.02, Revision 16, " Nuclear Safety Assessment Board,".1/14/98
| |
| . National Academy for Nuclear Training 91-017, Revision 1, " Guidelines for Training and
| |
| Qualification of Engineering Support Personnel," 12/94
| |
| Northeast Utilities Nuclear Safety Standards and Expectations, Rev. O, 5/28/97
| |
| Nuclear Oversight Department Quality Procedure NOOP-4.02, Revision 29, Performance,
| |
| Reporting,'and Follow-up of Surveillance Activities and Filed Observations at the Millstone
| |
| Station."
| |
| Nuclear Oversight Monthly Report - March 1998
| |
| Nuclear Oversight Audit Report MP 98-A01, " Conduct of Operations Millstone U2 & U3"
| |
| i | | i |
| Nuclear Oversight Field Observation MP3-P-98 007, " Post Maintenance Testing," 1/23/98
| |
| Nuclear Oversight Field Observation MP3-P-98-014, " Operability Determination Program,"
| |
| 3/12/98
| |
| Nuclear Oversight Surveillance MP3-P-98-016, " Containment Closeout inspection,"
| |
| 4/13/98
| |
| Nuclear. Oversight Review Verification Plan Assessment Report 4/17/98
| |
| . | | . |
| Nuclear Safety Assessment Board Administrative Procedure, Revision 2,1/30/98
| | I l |
| Nuclear Training Manual NTM-7.202, Revision 7, " Engineering Support Training Program
| |
| . implementing Procedure," 10/6/97
| |
| Nuclear Training Manual NTM-4.03, Revision 4, " Evaluate / Develop OJT Training
| |
| L- . Materials" 7/7/97
| |
| - Nuclear Training Manual NTM-5.06, Revision 3, "On The Job Training and Evaluation,"
| |
| I' .9/30/97 | |
| Selected Nuclear Safety Assessment Board Meeting Minutes
| |
| Self assessments done by' Operations, Maintenance, Engineering, and Corrective Actions
| |
| System Engineer Task Qualification Records
| |
| System Readiness Review Training Documentation,4/22/98
| |
| U3 OA 11 Rev 1 ."Self Assessment"
| |
| U3 OA 5 Rev. O, " Management Observation Program."
| |
| .
| |
| -- -- .- - - - - - - - - - - - - - - - _ - - _ _ _ . _ _ _ _ _ _ , _ _ _ _ _ _ _ _ - , , _
| |
| .
| |
| .
| |
| ,
| |
| . .
| |
| " Windows" Self-Assessment Checkoff lists, Engineering, Operations, Maintenance
| |
| : [[contact::B.D. Kenyon memo to All Nuclear Group Personnel]], subject: Issuance of Nuclear Group
| |
| Policies and Standards Documents, dated August 7,1997.
| |
| Millstone Success Objectives
| |
| Operating Procedure OP3260A, Conduct of Outages
| |
| Safety Analysis Branch Procedure, SAB 3.01, Communication of PRA Findings to NU
| |
| Management
| |
| Safety Analysis Branch Prccedure 3.08, Risk Monitor
| |
| Millstone Station Procedure RP 4, Corrective Action Program, Attachment 4, Risk
| |
| Significance
| |
| 1997 Annual Report on the Status of Compliance with Corporate Nuclear Safety Goals
| |
| (Due 2/28/98)
| |
| NU Assessment Team Report of Millstone Employee Concerns Program dated January 29,
| |
| 1996
| |
| NRC Inspection Report No. 96-59, Millstone Employee Concerns Program
| |
| Millstone Unit 3 Performance Annunciator Panel Reports for 1998
| |
| NRC Inspection Reports issued in the Forth quarter of 1997. ( Rept. Nos. 97-84, Fire
| |
| Protection; 97-201, Resident Report: 97-203, Resident Report: 97-206, SSFI; 97-207,
| |
| Resident Report: 97-211, ICAVP.)
| |
| Reports of Nuclear Oversight audit conducted in the fourth quarter of 1997 of Operations
| |
| Millstone Unit 3 Operational Readiness Plan.
| |
| Nuclear Oversight Re wt Verification Plan reports for April 1998 and a sample of reports
| |
| from 1997
| |
| NRC Inspection Reports issued in the Forth quarter of 1997. ( Rept. Nos. 97-84, Fire
| |
| Protection; 97-201, Resident Report: 97-203, Resident Report: 97-206, SSFl; 97-207,
| |
| Resident Report: 97-211, ICAVP.)
| |
| Nuclear Oversight Verification Plan (covering the 4* qtr.1997)
| |
| Reports of Nuclear Oversight audits and assessments conducted in the fourth quarter of
| |
| 1997 of Operations, Maintenance and Engineering.
| |
| Unit 3 Corrective Action Department Root Cause Investigation instruction 3 CAD-DI-1.02
| |
| PORC minutes
| |
| SORC minutes
| |
| Plant Operations Review Committee procedure OA3
| |
| Site Operations Review Committee procedure OA4
| |
| l Northeast Utilities Quality Assurance Audi MP-98-A05 " Millstone Units 2 and 3 Corrective | |
| l Action Program
| |
| l Root Cause Analysis RP6 rev 1
| |
| ,
| |
| Root Cause Investigation Reoorts Reviewed
| |
| M3-97-4015 "A" EDG Inoperable due to Ventilation Alignment Prohibiting Tornado
| |
| Pecovery
| |
| M3-98-1492 3RHS*SOV606,607,618 & 619 may have the wrong type of solenoid vatve
| |
| M3-98-0897 Unanalyzed Cond! tion for the Design of the RHR Miniflow Valves
| |
| M3-981441 Seven Additional Containment Bypass Leakage Paths were Identified
| |
| M3-98-0616 Manual Control of an Automatic Safety Function in OP 3314A
| |
| M3-97-4537 Draft Copy
| |
| M3-98-0305 Potential for Breach of Containment Boundary via RSS Seal Tank Vent
| |
| . _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -
| |
| M3 98-0921 Action Request Closed Crediting Erroneous Corrective Actions.
| |
| AR97003960-05
| |
| M3-98-1478 Damage was found on Expansion Joint on the Discharge side of 3RSS*P1 A
| |
| Internal Liner Missing
| |
| M3-98-0994 NRC Review identified Discrepancies in URI 50-423/97-84-01 Equipment not
| |
| Tested
| |
| M3-97-4485 NU Dose Assessment inadequacies as Cited in NOV 50-245, 336, 423/97-
| |
| 081-04
| |
| M3-97-4481 NRC Finding - Failure to Recognize and Evaluate Effects of RSS Air Sweeping
| |
| into CHS and St
| |
| M3 97-4495 Motor Pinion Gear Key Failures in Safety injection Accumulator Outlet Valve
| |
| Actuators (3SIL*MV3808A,B,C)
| |
| Ooerations
| |
| ACP-QA-2.12 " System Valve Alignment Control," revision 12
| |
| DC 4 " Procedural Compliance," revision 4, change 2
| |
| NGP 1.09 " Overtime Controls for all Personnel at Millstone Station," revision 8
| |
| OP 3201 " Plant Heatup," revision 14, change 7
| |
| OP 3250.08 " Drain SlH or QSS to RWST," revision O
| |
| OP 3260 " Conduct of Operations," revision 10, change 8
| |
| OP 3260B " Equipment Control," revision 2, change 3
| |
| OP 3260B-1 " Locked Component Checklist," revision 3, change 4
| |
| OP 3301G " Pressurizer Pressure Control," revision 9, change 1
| |
| OP 3601D.1 " Reactor Coolant Pump Operability Check"
| |
| SP 3601G.2 "RCS and Pressurizer Heatup and Cooldown Rate," revision 7, change
| |
| SP 3622.3 " Auxiliary Feedwater Pump 3FWA*P2 Operational Readiness Test,"
| |
| revision 13, change 4
| |
| SP 3712Z " Setting Position of High Pressure Safety injection Throttle Valves,"
| |
| revision 3
| |
| WC6 " Determination and Performance of Independent and Dual
| |
| Verifications," revision 0, change 1
| |
| WC 14 "On-Line Scheduling" revision 1
| |
| Enaineerina and Technical Suonort
| |
| CR M3-98-1402 lack of documentation of "N/A" of procedure steps #
| |
| ,
| |
| CR M3-98-1709 missed two consecutive readings on Pzr heatup surv
| |
| ! CR M3-98-1832 approval authority of procedures not in compliance with TS 6.8.2.b
| |
| and TS 6.5.4.2.e
| |
| '
| |
| CR M3-98-1863 mode change without RCP breaker racked up
| |
| CR M3-98-1865 LCO required actions not completed within allowed time
| |
| CR M3-98-1904 ESF auto start of MDAFW pump on LO-LO SG "C"
| |
| l CR M3-98-1911 PORV lifted twice during master pressure control use
| |
| '
| |
| .CR M3-98-1953 direct communications with control room
| |
| l CR M3-98-1957 operation of master pressure controller resulted in lifting of PORV
| |
| l - - - - - - - - - - - - - - - - - - - - - - -
| |
| _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ __
| |
| CR M3-98-1969 temporary modification on RCP sealinjection filter l
| |
| CR M3-98-1971 electrical panels lack labels
| |
| CR M3-98-1977 work control process for evaluating risk in Mode 3 and Mode 4
| |
| CR M3-98-1978 work control process for evaluating total plant risk using U3-WC-14
| |
| CR M3-98-1997 EDG oil strainer drain valve,3 EGO *V18B, not closed
| |
| CR M3-98-1980 inadequate coding of work order
| |
| CR M3-98-2007 EDG oil strainer drain valve, 3 EGO *V188, not closed
| |
| CR M3-98-2009 operations involved in six events which were adverse to quality:
| |
| l CR M3-98-1709 OPS missed two readings on the PZR heatup surv
| |
| CR M3-98-1863 mode change without RCP breaker racked up
| |
| CR M3-98-1865 LCO required actions not completed within allowed time
| |
| i
| |
| CR M3-98-1904 ESF auto start of MDAFW pump on LO-LO SG "C"
| |
| CR M3-98-1911 PORV lifted twice during master pressure control use
| |
| CR M3-98-1957 Operability of PORV with MPC in manual
| |
| CR M3-98-2081 weaknesses in valve lineups identified by OSTI
| |
| CR M3-98-2101 nuclear training evaluation for Temp Mod 3-97-075 answered
| |
| incorrectly
| |
| CR M3-98-2024 leaks in primary sample sink room
| |
| CR M3-98-2030 EDG starting air receiver (3EGA*TK1 A) drain valve (3EGA*V7)
| |
| cracked open
| |
| CR M3-98-2031 EDG starting air filters (3EGA*FLT3A,3B,3C, and 3D) do not have
| |
| identification labels, and are not shown on P&lDs
| |
| CR M3 98-2046 Millstone 3 does not have a tank book
| |
| CR M3-98+2049 both manual suction valves (3CHS*V707 and 3CHS*V44) for
| |
| charging pump 3CHS*P3C found closed by OSTI
| |
| CR M3-98 2143 locked valves not verified secured as required by OP 3260B,
| |
| " Equipment Control"
| |
| CR M3-98-2149 use of a PEO as advisor to the fire brigade (duplicate of CR M3-98-
| |
| 2151)
| |
| CR M3-98-2150 inconsistencies in OP 3260 related to the requirement for an SRO to
| |
| be in the control room and location of unit supervisor.
| |
| CR M3-98-2151 use of a PEO as advisor to the fire brigade (duplicate of CR M3-98-
| |
| 2149)
| |
| Plant Modifications
| |
| Nuclear group procedure (NGP) 3.04, Initiating and Closing-out Nuclear Engineering Work
| |
| Design Control Manual (DCM)
| |
| RAC 12, Safety Evaluations
| |
| DCR M3-97029 - ASCO Solenoid Valve Replacement
| |
| DCR M3-96078 - 3SWP'P3A/B Suction Pipe Rerouting
| |
| MMOD M3-97511 - EDG Configuration Control and Component Upgrade
| |
| EWR 95056 - RHS/CCP Modification
| |
| DCR M3-97089 - AFW Logic modification
| |
| DCR M3-97030 - Degraded Grid Modification
| |
| PCR MP3-94-094 - Replace service water pump 1 A,1C, and 1D impellers.
| |
| DCR M3-97095 - Improved fault clearing time for 4.16 kV feeder circuits.
| |
| -
| |
| Calculation BAT-SYST-1240E3 DC System Analysis Methodologies and Scenario
| |
| Development and BAT 1-96-1241E3 Battery 1 and Charger, Associated Cable and Device
| |
| Electrical verification Calculation
| |
| DCR M3-97109 - Boric Acid Tank Setpoint Change.
| |
| EWR M3-95-315 RSS heat exchanger permanent screens
| |
| DCR M3-97-097 - Service Water flow Balance Calculation revision Modification
| |
| DCR M3-96-065 - modification to RHS heat exchanger flow control and bypass valve.
| |
| DCR M3-96059 - Modify Target Rock Solenoid Valves 3FWA*HV36A - D
| |
| DCR M3-98003 -Inadvertent Safety injection at Power
| |
| Deferred Modification Review
| |
| EWR 96-297/MMOD M3-97534, Magneblast Breaker Upgrades
| |
| EWR - Main Steam Isolation Valve (MSIV) Solenoid Valves (SVs)
| |
| EWR M3-96241 - Auxiliary Feedwater System Turbine Governor Valve Stem Replacement
| |
| Enoineerina and Technical Sucoort Effectiveness
| |
| CR-M3-98-1907 and CR-M3-98-2052- Suspected bad RTD
| |
| CR-M3-981660 -- Target Rock SOV will not stroke when tested with no flow.
| |
| Operability Determinations
| |
| RP-5 Operability Determination
| |
| OD 25-98 ARCOR unresolved safety question (USO),
| |
| System Readiness Reviews
| |
| Ernergency Diesel Generator
| |
| 25 volt batteries
| |
| 4.16 kV switchgear
| |
| Service Water
| |
| Residual Heat Removal
| |
| Boric Acid Transfer i
| |
| Volume Control Tank
| |
| System Walkdowns
| |
| Emergency Diesel Generator
| |
| Service Water / Component Cooling Water
| |
| Chemical and Volume Control / Safety injection (including letdown and boric acid transfer)
| |
| Auxiliary Feedwater
| |
| Residual Heat Removal
| |
| 25 Vdc
| |
| 4160 kV switchgear systems
| |
| Eauioment Qualification
| |
| Nuclear Group Procedure (NGP) 6.12, " Evaluation of a Replacement item"
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -
| |
| '
| |
| Common Station (NUC) Piocedure MPM 3.00, " item Evaluation"
| |
| NUC MPM 3.02, " item Equivalency Evaluation.
| |
| r
| |
| l | | l |
| .
| | ! |
| I
| |
| _ - _ _ _ _ _ _ - - - - - - _ _ - - - -
| |
| Maintenance and Surveillance
| |
| U3 WC 1, Unit 3 Work Management
| |
| U3 WC 1.1, Unit 3 Minor Maintenance Process Controls
| |
| U3 WC 8, Control and Calibration of Measuring and Test Equipment
| |
| WC 9, Station Surveillance Program
| |
| U3 WC 9.1, Surveillance Program implementation
| |
| WC 10, Jumper, Lifted Lead, and Bypass Control
| |
| U3 WC 14, On-line Scheduling
| |
| U3 WPC 1, Conduct of Planning and Outage Management
| |
| U3 WPC 2, Unit 3 Work Planning
| |
| C WPC 3, Post Maintenance Testing
| |
| C WPC 4, On-line Maintenance
| |
| U3 CMG 001, Conduct of Maintenance Job Briefings
| |
| U3 CMG 002, Foreign Material Exclusion and System Cleanliness
| |
| U3 CMG 003, U3 Conduct of Maintenance
| |
| U3 CBM 105, PM Program Changes and Deferrais for Unit 3
| |
| U3 CBM 107, Integrated PM Program
| |
| CBM-PROG 500, PM Change and Deferral Evaluation Guidelines
| |
| MP 3704A, U3 PM Program
| |
| MP 3705B, Fix-It-Now Conduct of Maintenance
| |
| MP 3718AB, Repair of Bonnet Type Valves
| |
| MP 3783AA,4160 Volt Breaker Preventive Maintenance
| |
| CMP 720A, Scaffold Erection Use, and Removal
| |
| OA 5, Work Observation Program
| |
| OA 8, Ownership, Maintenance and Housekeeping of Buildings Facilitiesn and
| |
| Equipment ;
| |
| OA 10, Millstone Station Maintenance Rule Program j
| |
| l&C 3403, l&C PM Program
| |
| OP 3201-1, Technical Specification Review Mode 4
| |
| ]<
| |
| OP 3201-2, Technical Specification Review Mode 3
| |
| OP 3201-3, Administrative and Regulatory Review Mode 4
| |
| RP-4, Corrective Action Program l
| |
| RP-16, Trouble Reporting -
| |
| SP 31103, Containment Leak Rate Test (ILRT)-Type A
| |
| SP 31105, Containment Quench Spray Header Nozzle Flow Test
| |
| . SP 3609.1, Quench Spray Pump 3OSS*P3A Operational Readiness Test
| |
| SP 3609.2, Quench Spray Pump 3OSS*P3B Operational Readiness Test
| |
| SP 3622.3, Auxiliary Feedwater Pump 3FWA*P2 Operational Readiness Test i
| |
| SP 3622.7, Auxiliary Feedwater Check Valve Operability Check
| |
| SP 3646A.17, Train A ESF With LOP Test ,
| |
| '
| |
| 3-UI-2.01, Materiel Condition -
| |
| Handbook-Millstone Unit 3 Maintenance Personnel Performance Expectations
| |
| U3 Quarterly Component Profile Report, November 6,1996
| |
| ! | |
| LER 89-011, Rev. O, Containment Unfiltered Leakage in Excess of Limits Due to
| |
| Valve Leakage
| |
| i LER 91-004, Rev.1, Containment Leakage in Excess of Limits Due to Valve
| |
| l Leakage
| |
| i .
| |
| f I
| |
| '
| |
| ! - - - _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
| |
| _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ - _ _ _ _ _ . _ . - ___-__ .
| |
| LER 95-004, Rev.1, Historical Breaches Affecting Control Room Pressurization
| |
| and Secondary Containment Vacuum, due to a Change in Technical Specification
| |
| interpretation
| |
| LER 95-005, Rev.1, Noncompliance with Technical Specification for Containment
| |
| integrity While Draining Suction Line
| |
| LER 95-009, Rev. 2, Containment Leakage in Excess of Technical Specification
| |
| Limits Due to Valve Leakage
| |
| LER 96-012, Rev.1, Containment Leakage in Excess of Technical Specification
| |
| Limits Due to Valve Leakage
| |
| LER 96-023, Rev. O, Failure to include Fuel Transfer Tube Bellows within
| |
| Containment Penetration Test Program
| |
| .
| |
| :.
| |
| l | | l |
| .
| | |
| Appendix A
| |
| Operational Events
| |
| There were two operational events and three failures to meet technical specifications
| |
| during the initial heatup from cold shutdown. Some of these events occurred prior to the
| |
| OSTI arriving onsite and therefore the team did not directly observe operator actions during
| |
| these events. The team did an independent review of each event. This included interviews
| |
| with the operators involved, review of plant response to the events where appropriate, ar.d
| |
| a review of the adequacy of the appropriate plant procedures. The causes and contributing
| |
| factors are described in the affected operations areas of this report and documented
| |
| below.
| |
| . Failure to Monitor Pressurizer Heatun
| |
| - On April 1,1998, while a plant heatup was in progress, a CO failed to record pressurizer
| |
| temperature every half hour as required by technical specification (TS) 3.4.9.2. The TS
| |
| surveillance requirement was implemented by performing surveillance procedure (SP)-
| |
| 3601G.2, "RCS and Pressurizer Heatup and Cooldown Rate," step 4.3.3. The CO was
| |
| standing the watch for the first time in over a month. The CO was aware that reactor
| |
| coolant system (RCS) and pressurizer heatup surveillance were in progress. The CO had
| |
| recorded RCS heatup rate but forgot to take the pressurizer temperature data. Another CO
| |
| identified that the readings were missed. The operators then accessed the plant process
| |
| e computer and verified that the pressurizer maximum allowed heatup rate had not been
| |
| g exceeded. The pressurizer temperature data was not logged between 04:00 hours and
| |
| 04:45 hours. The temperature change during this period was 4.5 degrees of approximately
| |
| 6'F/ hour. Technical Specifications require that the pressurizer heatup rate remains below
| |
| 100'F/ hour.
| |
| The team conducted an independent review of the event concluded that there were no
| |
| safety consequences as a result of the event. The primary cause of the event was the
| |
| CO's lack of attention to detail and the failure to follow procedures. A contributing factor
| |
| was ineffective supervisory oversight by the US. The US should have more closely
| |
| monitored the plant heat-up and the CO's performance given that this was the CO's first
| |
| watch in over a month.
| |
| Inocerable Reactor Coolant Loons
| |
| .-
| |
| On April 7,1998, at 22:54 hours, Unit 3 entered Mode 4 with less than the required
| |
| - number of operable reactor coolant loops. When the plant entered Mode 4, the "B" reactor
| |
| coolant pump was running and the other three reactor coolant pumps were inoperable
| |
| l
| |
| . since the associated breakers were tagged open and racked down. TS 3.4.1.3 required
| |
| J that at least two reactor coolant systems loops be operable with one loop in operation.
| |
| '
| |
| Operators discovered this proolern on April 8 at 18:10 hours. At that time, the operators
| |
| rendered the.."A" loop' operable by racking up the "A" reactor coolant pump breaker.
| |
| (
| |
| l
| |
| l'
| |
| The team conducted an independent review of the event and concluded that there were no
| |
| '
| |
| safety consequences as a result of the event. However, operators missed several-
| |
| opportunities to discover this problem both before and after the Mode change. Before .
| |
| Lentry into Mode 4, the licensee had performed a readiness for Mode change review. This -
| |
| _
| |
| included a review of technical specifications, the tag out log and a reactor coolant system
| |
| readiness review, in addition, the operators performed OP 3601 D.1, " Reactor Coolant -
| |
| Pump Operability Check," that had identified that the A,C and D loops were inoperable.
| |
| However, the OP acceptance criterion was incomplete in that it only required one loop to
| |
| be in ' operation and was silent regarding the operability requirements of the remaining loop.
| |
| 'After the Mode change,' two different shifts failed to identify this deficiency despite clear
| |
| . control board indication that three reactor coolant pumps were racked down.
| |
| The team concluded that the primary cause of the event was a lack of knowledge of the
| |
| TS requirements in relation'to plant conditions. Contributing factors in this event were a
| |
| ' lack of control board awareness and incomplete acceptance criteria in Operator Procedure
| |
| - OP 3601D.1.
| |
| '
| |
| Failure to Verifv Isolation of Potential Dilution Paths
| |
| On' April 6,1998, at 17:15 hours, the operators declared Channel 1 of Shutdown Margin
| |
| Monitoring system inoperable and entered TS 3.3.1 Functional Unit 21, Action 5(a). Action
| |
| ~ 5(a) required that if the inoperable channel had not been restored to an operable status
| |
| within 48 hours then the licensee was to suspend all operations involving positive
| |
| reactivity changes and to perform, within the next 4 hours, a surveillance procedure to
| |
| verify that all potential boron dilution paths to the reactor coolant system were isolated.
| |
| The operators did not recognize that the 48 hour action time had expired and therefore did
| |
| not perform the required surveillance procedure by April 8,1998, at 21:15 hours. On April
| |
| 9, at 04:30 hours, operators discovered that the surveillance procedure had not been
| |
| performed. The operators promptly performed the surveillance and verified that all potential
| |
| '
| |
| boron dilution paths to the reactor coolant system were isolated.
| |
| The team conducted an independent review of the event concluded that there were no
| |
| safoty consequences as a result of the event. The primary causes of the eveint was
| |
| inattention to detail and an inadequate shift turnover between shift managers on April 8.
| |
| The oncoming SM was not aware that the 48 hour action time would expire during his
| |
| shift. A contributing factor was an incomplete log entry when the channel had been
| |
| declared inoperable on April 6. Procedure OP 3260, " Conduct of Operations," required that
| |
| any conditional surveillance requirement be logged when logging entry into a TS action
| |
| . statement.
| |
| Automatic initiation of the Auxiliarv Feedwater Svatem
| |
| l
| |
| '
| |
| ~ On April 11,1998, while a plant heatup was in progress, an inadvertent engineered
| |
| safeguards' actuation occurred when the "C" steam generator reached the low-low level set
| |
| point. The plant response was an automatic initiation of the motor-driven auxiliary
| |
| l
| |
| _
| |
| _ _ - _ _ _ _ _ . _ - _ _ . . _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ - _ . _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . , _ _ _ _
| |
| _
| |
| ; feedwater pump to restore steam generator level. The plant system responded as
| |
| . designed. The low steam generator water level condition resulted from inadequate main
| |
| - feedwater flow.
| |
| Prior to transitioning into Mode 4 on April '7, operators had initiated a continuous bottom
| |
| .. blowdown on the "C" steam generator (SG) to allow chemistry to obtain water samples.
| |
| This was due to an inoperable "C" SG sample line.
| |
| On April 10, operators initiated a plant heatup to NOT/NOP. This initiated a 24 hour
| |
| window to perform required steam driven auxiliary feedwater pump testing. Make up to the
| |
| - SGs was provided by the condensate system. On April 11, the heat up had progressed to
| |
| the point where it was necessary to start the motor driven main feedwater pump (MDMFP)
| |
| to continue to provide makeup to the SGs. Operating Procedure (OP) 3201, " Plant
| |
| Heatup," step 4.4.9 directed that the MDMFP be' started and SG levels be maintained
| |
| between 45% and 55%.
| |
| As preparations were in progress to start the MDMFP, a "C" SG low level alarm (30%)
| |
| was received. Operators suspended the plant heat up, isolated steam flow from the "C"
| |
| SG, and initiated a plant cooldown. The shift manager dispatched operators into the plant
| |
| in attempt to locate the source of the "C" SG inventory loss. However, source of the
| |
| inventory loss was not determined and water level in the "C" SG continued to decrease.
| |
| The starting of the MDMFP was' delayed due to the unavailability of needed plant support
| |
| personnel. When the pump was started, sparks were observed emanating from a pump
| |
| seal. The shift manager directed that the pump be tripped and auxiliary feedwater manually
| |
| initiated. However, "C" SG level decreased to the low-low level set point (18%) and
| |
| auxiliary feedwater automatically initiated before the operators were able to manually
| |
| initiate the system.
| |
| Operators subsequently restored "C" SG to its normal level. Problems with the motor -
| |
| L driven main feedwater pump were resolved and the operators placed the auxiliary
| |
| feedwater system into standby. The licensee initiated an event review team to determine
| |
| the cause(s) of the event.
| |
| The team conducted an independent review of the even't and concluded that there were no
| |
| safety consequences as a result of the event. The primary cause of the event was the
| |
| failure of the operators to maintain SG water level in the normal operating band by not
| |
| ,
| |
| promptly providing feedwater either from the MDMFP or by manually starting a motor
| |
| F
| |
| driven auxiliary feedwater pump. Several other problems contributed to this event. These
| |
| !
| |
| ' are documented below.
| |
| '
| |
| = This was the first plant heatup performed using the MDMFP. Past heatups had used
| |
| auxiliary feedwater to' provide water to the SGs.'The licensee had not conducted
| |
| .
| |
| tests or operated the MDMFP before the point where the pump was needed to fill
| |
| . the stuam generators. The MDMFP had been idle for two years.
| |
| l-
| |
| L
| |
| (;
| |
| _ _ _ _ - . _ _ _ _ _ - ___-_ - -_ - _ _-__-_-_- - _ - _ _-_____-_ _ _ _ _ .
| |
| r
| |
| *- l Operators did n' ot recognize the source of the "C" steam generator inventory loss
| |
| via the blowdown line. This lineup was not documented as an abnormal condition or
| |
| alternate configuration in the shift turnover log. There was control room indication
| |
| the blowdown lineup.
| |
| * ' The attempted starting of the MDMFP. was unnecessarily delayed. The licensee's
| |
| condition based maintenance (CBM) group had requested that they be present to
| |
| monitor the operation of the MDMF
| |
| : [[contact::P. However]], the shift was not able to locate a
| |
| member of CBM.-
| |
| a' 'An adequate heat up rate had not been established early in the previous shift to
| |
| support the required NOT/NOP testing within the allowed 24 hour test window. As
| |
| a result the shift manager directed the plant heatup rate to be increased. The
| |
| increased heatup rate reduced the time the operators had to respond to lowering
| |
| level in the C SG.
| |
| . The level of activity in the control room prior to the event was high. This included
| |
| dealing with service water strainer problems, responding to a high level alarm in a
| |
| safety injection accumulator, preparing the steam driven auxiliary feedwater pump
| |
| for testing, responding to numerous shutdown margin monitor alarms, and
| |
| controlling and recording the plant heat up.
| |
| * Based on interviews with the operators involved in the event, personnel fatigue may
| |
| have been a contributing factor.
| |
| Inadvertent Onaninaa of a Power Onarated Relief Valva
| |
| On April 12,1998, operators inadvertently opened a power operated relief valve (PORV) on
| |
| - two occasions. At the time of the event the plant heat up to normal operating temperature
| |
| and pressure had just been completed. OP 3301G, " Pressurizer Pressure Control," step
| |
| 4.1.6 directed the operator to place the pressurizer master controller in automatic. The Unit
| |
| supervisor (US) and the control operator (CO) had never performed this evolution outside of '
| |
| simulator training. The event occurred when the CO, under the direction of the US,- 3
| |
| deviated from the operating procedure and manually lowered the master pressure controller
| |
| in an attempt to match the automatic and manual signals. This action resulted in the
| |
| lowering of the PORV lift setpoint to the point where the PORV lifted. The PORV
| |
| automatically closed when reactor coolant system pressure dropped to approximately 2200
| |
| psig as designed. In response, the CO promptly responded to shut the associated PORV i
| |
| , , block valve. The CO then manually raised the controller output and reopened the PORV
| |
| block valve. However, the output of the controller had not been raised sufficiently and the
| |
| PORV lifted and automatically shut for a second time. The operators subsequently adjusted
| |
| the controller setpoint to the proper level and placed the controller in automatic.
| |
| -The team conducted.an independent review of the event and conclude' d that there were no
| |
| safety consequences as a result of the event.'The primary cause of the event was the
| |
| -4 q
| |
| ,
| |
| a____N _________A_..:.__..--___________.-_.___a-__.___1-_._-.. -
| |
| ^
| |
| u.- ._ _--._--a _- - . - - ,
| |
| . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ - _ - _ - _
| |
| %
| |
| CO's and US's lack of knowledge of the operation of the master pressure controller and
| |
| the controller's interrelated components. Other problems contributed to this event. These
| |
| are documented below.
| |
| * The operators performed actions that were not in compliance with procedural
| |
| guidance.
| |
| * Oversight by shift management was ineffective. The shift manager (SM) was not
| |
| informed of the impending evolution as he had directed during the evolution
| |
| prebriefing. The SM had intended to supervise the evolution because he was aware
| |
| that the US and CO lacked experience in transferring the master controller into
| |
| automatic.
| |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARDD-99-12, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review DD-99-12 Has Expired.With Certificate of Svc.Served on 9910281999-10-28028 October 1999
Informs That Time Provided by NRC Regulation within Which Commission May Act to Review DD-99-12 Has Expired.With Certificate of Svc.Served on 991028
ML20217N8261999-10-25025 October 1999
Discusses Errata Re 991021 Filing of Northeast Nuclear Energy Co Answer to Request for Hearing & Petition to Intervene
B17901, Submits Statement of Personal Qualification (NRC Form 398) Along with Supporting Certification of Medical Exam by Facility Licensee (NRC from 396) in Support of License Renewal for PM Miner.Encls Withheld,Per 10CFR2.790(a)(6)1999-10-18018 October 1999
Submits Statement of Personal Qualification (NRC Form 398) Along with Supporting Certification of Medical Exam by Facility Licensee (NRC from 396) in Support of License Renewal for PM Miner.Encls Withheld,Per 10CFR2.790(a)(6)
B17886, Requests Permission to Utilize Code Case N-623, Deferral of Insps of Shell-to-Flange & Head-to-Flange of Reactor Vessel,Section Xi,Div 1, for Millstone Unit 21999-10-18018 October 1999
Requests Permission to Utilize Code Case N-623, Deferral of Insps of Shell-to-Flange & Head-to-Flange of Reactor Vessel,Section Xi,Div 1, for Millstone Unit 2
05000336/LER-1999-012, Forwards LER 99-012-00,re Unrecoverable CEA Misalignment Entry Into TS 3.0.3 on 990917.Commitments Made by Util Are Encl1999-10-15015 October 1999
Forwards LER 99-012-00,re Unrecoverable CEA Misalignment Entry Into TS 3.0.3 on 990917.Commitments Made by Util Are Encl
B17900, Forwards Revised Assumptions Used in Fuel Handling Accident Analysis & Summary of Results.List of Regulatory Commitments Are Listed in Attachment 11999-10-14014 October 1999
Forwards Revised Assumptions Used in Fuel Handling Accident Analysis & Summary of Results.List of Regulatory Commitments Are Listed in Attachment 1
ML20217G9491999-10-14014 October 1999
Forwards Exemption from Requirements of 1-CFR50,App E, Section IV.F.2.c,re Conduct of full-participation Exercise in Sept 1999,at Plant,Units 1,2 & 3
ML20217D9671999-10-12012 October 1999
Forwards Copy of Transcript of Public Meeting Held by NRC Staff & NNECO on 990825 at Waterford,Connecticut on Decommissioning Program for Millstone,Unit 1.Without Encl
ML20217D3011999-10-0707 October 1999
Forwards Request for Addl Info Re Util 990118 Request for Amend to License NPF-49 to Allow full-core Offloads to Spent Fuel Pool During Core Offloads to Spent Fuel Pool During Core Offload Events
ML20217F0031999-10-0606 October 1999
Forwards Original Petition to Intervene Being Filed on Behalf of Clients,Connecticut Coalition Against Millstone & Long Island Coalition Against Millstone,Iaw Provisions of 10CFR2.714
ML20217P1201999-10-0606 October 1999
Informs NRC of Proposed Acquisition of Parent Holding Company of Central Maine & Requests NRC Concurrence,Based on Threshold Review,That Proposed Acquisition Does Not,In Fact, Constitute Transfer Subject to 10CFR50.80
B17892, Requests Withdrawal of License Amend Application Re 24-month SG Tube Insp Surveillance Extensions,Submitted in Util 950726 & s to NRC1999-10-0505 October 1999
Requests Withdrawal of License Amend Application Re 24-month SG Tube Insp Surveillance Extensions,Submitted in Util 950726 & s to NRC
ML20217B4711999-10-0404 October 1999
Informs That Staff Did Not Identify Any Safety Concerns Re Licensee Proposals to Modify Commitments Made for Action Items 4.2.1,4.2.2,4.5.1 & 4.5.2 of GL 83-28 by Providing Addl Justifications or Safety Bases for Changes
ML20212K1241999-10-0101 October 1999
Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected
ML20212J3051999-10-0101 October 1999
Discusses GL 97-06 Re Degradation of SG Internals,Dtd 971230.GL Requested Each PWR Licensee to Submit Info That Will Enable NRC Staff to Verify Whether PWR SG Internals Comply & Conform to Current Licensing Basis for Facilities
ML20212L2081999-10-0101 October 1999
Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance
ML20212J9991999-10-0101 October 1999
Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected
ML20212L1971999-10-0101 October 1999
Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety
ML20212J2451999-10-0101 October 1999
Informs That Util 980807 & 990629 Responses to GL 98-01, Y2K Readiness of Computer Sys at NPPs Acceptable.Nrc Considers Subj GL to Be Closed for Units 2 &3
ML20212L1831999-10-0101 October 1999
Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health
ML20212L2171999-10-0101 October 1999
Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island
ML20217A9271999-09-30030 September 1999
Discusses Investigation Conducted at Millstone Nuclear Power Station by NRC OI Region I on 980319 to Determine If Contract Training Instructor Was Terminated for Raising Concerns About Quality of Training Matls
ML20217B3221999-09-30030 September 1999
Refers to Investigation Rept 1-1997-035 Conducted at Millstone Nuclear Power Station by NRC Ofc of Investigation Field Ofc,Region I on 970915 to Determine Whether Former Health Physics Technician Discriminated Against
ML20212J6621999-09-30030 September 1999
Informs of Completion of mid-cycle PPR of Units 2 & 3 on 990916.Identified Several Recent Instances in Which Condition Repts Were Not Initiated,Resulting in Untimely or Inadequate C/As.Historical Listing of Plant Issues Encl
B17887, Requests Exemption from Requirements of 10CFR140.11(a)(4) Which Requires Licensees to Maintain Secondary Financial Protection Beyond Primary Layer1999-09-28028 September 1999
Requests Exemption from Requirements of 10CFR140.11(a)(4) Which Requires Licensees to Maintain Secondary Financial Protection Beyond Primary Layer
ML20216J1341999-09-28028 September 1999
Ltr Contract:Task Order 49, Millstone Units 2 & 3 Employee Concerns Program Insp, Under Contract NRC-03-98-021
B17883, Forwards Mnps Unit 3 ISI Summary Rept,Cycle 6, IAW ASME Section XI,IWA-62301999-09-27027 September 1999
Forwards Mnps Unit 3 ISI Summary Rept,Cycle 6, IAW ASME Section XI,IWA-6230
B17890, Provides Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal1999-09-27027 September 1999
Provides Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal
B17888, Informs That There No Longer Exists Need to Maintain Millstone Unit 2 SRO License for CA Hines,License SOP-10741-01,effective 9909151999-09-24024 September 1999
Informs That There No Longer Exists Need to Maintain Millstone Unit 2 SRO License for CA Hines,License SOP-10741-01,effective 990915
B17884, Forwards NRC Form 536, Operator Licensing Exam Data, for Mnps,Units 2 & 3,per Administrative Ltr 99-031999-09-24024 September 1999
Forwards NRC Form 536, Operator Licensing Exam Data, for Mnps,Units 2 & 3,per Administrative Ltr 99-03
ML20212F4961999-09-20020 September 1999
Forwards Insp Repts 50-245/99-08,50-336/99-08 & 50-423/99-08 on 990615-0809.Four Violations of NRC Requirements Occurred & Being Treated as Ncvs,Consistent with App C of Enforcement Policy
05000336/LER-1999-001, Forwards LER 99-001-00 Re Thermal Reactor Power Limit That Was Exceeded.Commitments Made by Util Encl1999-09-20020 September 1999
Forwards LER 99-001-00 Re Thermal Reactor Power Limit That Was Exceeded.Commitments Made by Util Encl
B17867, Requests Relief from Requirements of 10CFR50.55a(g),IAW ASME Section XI for Millstone,Unit 3.Util Requests Relief from Performing Visual Exam of Reactor Pressure Supports to Extent Required by Code for Class 1 Supports1999-09-17017 September 1999
Requests Relief from Requirements of 10CFR50.55a(g),IAW ASME Section XI for Millstone,Unit 3.Util Requests Relief from Performing Visual Exam of Reactor Pressure Supports to Extent Required by Code for Class 1 Supports
B17865, Provides NRC Staff with Updated Proposed Rev of FSAR Section 14.6.3, Radiological Consequences of SG Tube Failure. Updated Proposed Rev Will Replace Info Provided in Attachment 3 of Initial Submittal1999-09-16016 September 1999
Provides NRC Staff with Updated Proposed Rev of FSAR Section 14.6.3, Radiological Consequences of SG Tube Failure. Updated Proposed Rev Will Replace Info Provided in Attachment 3 of Initial Submittal
B17876, Informs That Util Will Adopt Last Approved Northeast Util QA Program (Nuqap) Tr,Rev 21,dtd 990630,as Unit 1 Nuqap,Per Decision to Permanently Cease Operations at Subject Plant1999-09-16016 September 1999
Informs That Util Will Adopt Last Approved Northeast Util QA Program (Nuqap) Tr,Rev 21,dtd 990630,as Unit 1 Nuqap,Per Decision to Permanently Cease Operations at Subject Plant
B17882, Forwards NRC Forms 398 & 369 in Support of License Renewal for Bb Parrish,License SOP-10399-2.Encl Withheld Per 10CFR2.790(a)(6)1999-09-15015 September 1999
Forwards NRC Forms 398 & 369 in Support of License Renewal for Bb Parrish,License SOP-10399-2.Encl Withheld Per 10CFR2.790(a)(6)
B17881, Forwards NRC Form 398 & NRC Form 396 for Le Olsen,License SOP-10398-2.Encl Withheld Per 10CFR2.790(a)(6)1999-09-15015 September 1999
Forwards NRC Form 398 & NRC Form 396 for Le Olsen,License SOP-10398-2.Encl Withheld Per 10CFR2.790(a)(6)
B17859, Forwards up-to-date Distribution Lists for NRC Correspondence to NNECO & NUSCO.Side-bars Indicate Changes from Previous Lists Provided to NRC on 9801281999-09-15015 September 1999
Forwards up-to-date Distribution Lists for NRC Correspondence to NNECO & NUSCO.Side-bars Indicate Changes from Previous Lists Provided to NRC on 980128
B17880, Forwards NRC Form 398 & NRC Form 396 for Rf Martin,License SOP-10397-0.Encls Withheld Per 10CFR2.790(a)(6)1999-09-15015 September 1999
Forwards NRC Form 398 & NRC Form 396 for Rf Martin,License SOP-10397-0.Encls Withheld Per 10CFR2.790(a)(6)
B17872, Informs of Election to Consolidate Previous Commitments Re Work Observation Program with Two New Programmatic Commitments Listed in Attachment 11999-09-14014 September 1999
Informs of Election to Consolidate Previous Commitments Re Work Observation Program with Two New Programmatic Commitments Listed in Attachment 1
ML20212A9011999-09-10010 September 1999
Forwards Environ Assessment & Finding of No Significant Impact Re Application for Exemption,Dtd 990803.Proposed Exemption Would Provide Relief from Requirement of 10CFR50
ML20212A3171999-09-10010 September 1999
Discusses Investigation Rept 1-1998-045 Conducted on 981112 to Determine If Former Senior Health Physics Technician Being Denied Employment at Millstone in Retaliation for Having Raised Safety Concerns in Past.Synopsis Encl
B17838, Forwards Revs 34 & 35 to Physical Security Plan.Explanation of Changes Provided as Attachment 1.Without Encls1999-09-10010 September 1999
Forwards Revs 34 & 35 to Physical Security Plan.Explanation of Changes Provided as Attachment 1.Without Encls
ML20212A7501999-09-10010 September 1999
Forwards Staff Requirements Memo Response,Dtd 990525,which Provides Actions NRC Plans for Continued Oversight of safety-conscious Work Environ & Employee Concerns Program
ML20211J9291999-09-0303 September 1999
Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests
ML20211K5171999-09-0202 September 1999
Expresses Appreciation for Support Provided for NRC Public Meeting on 990825
05000336/LER-1999-010, Forwards LER 99-010-00,documenting 990804 Event of Failure to Perform ASME Section XI IST on Pressurizer Relief Line Flow Control Sample Valve Following Maint Activities.List of Util Commitments Contained in Attachment 11999-09-0202 September 1999
Forwards LER 99-010-00,documenting 990804 Event of Failure to Perform ASME Section XI IST on Pressurizer Relief Line Flow Control Sample Valve Following Maint Activities.List of Util Commitments Contained in Attachment 1
ML20216H0591999-09-0202 September 1999
Responds to Re Issues Submitted by Cullen on Behalf of Several Petitioners Concerning Offsite Emergency Prepardeness for Millstone Nuclear Power Station
ML20211N9241999-09-0101 September 1999
Forwards Document Classification Form for Insertion Into Emergency Planning Services Department Procedures
ML20211H0741999-08-30030 August 1999
Discusses GL 92-01,Rev 1, Rv Structural Integrity, Issued by NRC on 950519 & NNECO Responses for Millstone Unit 2 & 980715.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 Based on Response Review
1999-09-30
[Table view]
Category:OUTGOING CORRESPONDENCE
MONTHYEARDD-99-12, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review DD-99-12 Has Expired.With Certificate of Svc.Served on 9910281999-10-28028 October 1999
Informs That Time Provided by NRC Regulation within Which Commission May Act to Review DD-99-12 Has Expired.With Certificate of Svc.Served on 991028
ML20217G9491999-10-14014 October 1999
Forwards Exemption from Requirements of 1-CFR50,App E, Section IV.F.2.c,re Conduct of full-participation Exercise in Sept 1999,at Plant,Units 1,2 & 3
ML20217D9671999-10-12012 October 1999
Forwards Copy of Transcript of Public Meeting Held by NRC Staff & NNECO on 990825 at Waterford,Connecticut on Decommissioning Program for Millstone,Unit 1.Without Encl
ML20217D3011999-10-0707 October 1999
Forwards Request for Addl Info Re Util 990118 Request for Amend to License NPF-49 to Allow full-core Offloads to Spent Fuel Pool During Core Offloads to Spent Fuel Pool During Core Offload Events
ML20217B4711999-10-0404 October 1999
Informs That Staff Did Not Identify Any Safety Concerns Re Licensee Proposals to Modify Commitments Made for Action Items 4.2.1,4.2.2,4.5.1 & 4.5.2 of GL 83-28 by Providing Addl Justifications or Safety Bases for Changes
ML20212J3051999-10-0101 October 1999
Discusses GL 97-06 Re Degradation of SG Internals,Dtd 971230.GL Requested Each PWR Licensee to Submit Info That Will Enable NRC Staff to Verify Whether PWR SG Internals Comply & Conform to Current Licensing Basis for Facilities
ML20212L1831999-10-0101 October 1999
Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health
ML20212J9991999-10-0101 October 1999
Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected
ML20212J2451999-10-0101 October 1999
Informs That Util 980807 & 990629 Responses to GL 98-01, Y2K Readiness of Computer Sys at NPPs Acceptable.Nrc Considers Subj GL to Be Closed for Units 2 &3
ML20212K1241999-10-0101 October 1999
Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected
ML20212L1971999-10-0101 October 1999
Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety
ML20212L2171999-10-0101 October 1999
Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island
ML20212L2081999-10-0101 October 1999
Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance
ML20212J6621999-09-30030 September 1999
Informs of Completion of mid-cycle PPR of Units 2 & 3 on 990916.Identified Several Recent Instances in Which Condition Repts Were Not Initiated,Resulting in Untimely or Inadequate C/As.Historical Listing of Plant Issues Encl
ML20217A9271999-09-30030 September 1999
Discusses Investigation Conducted at Millstone Nuclear Power Station by NRC OI Region I on 980319 to Determine If Contract Training Instructor Was Terminated for Raising Concerns About Quality of Training Matls
ML20217B3221999-09-30030 September 1999
Refers to Investigation Rept 1-1997-035 Conducted at Millstone Nuclear Power Station by NRC Ofc of Investigation Field Ofc,Region I on 970915 to Determine Whether Former Health Physics Technician Discriminated Against
ML20216J1341999-09-28028 September 1999
Ltr Contract:Task Order 49, Millstone Units 2 & 3 Employee Concerns Program Insp, Under Contract NRC-03-98-021
ML20212F4961999-09-20020 September 1999
Forwards Insp Repts 50-245/99-08,50-336/99-08 & 50-423/99-08 on 990615-0809.Four Violations of NRC Requirements Occurred & Being Treated as Ncvs,Consistent with App C of Enforcement Policy
ML20212A9011999-09-10010 September 1999
Forwards Environ Assessment & Finding of No Significant Impact Re Application for Exemption,Dtd 990803.Proposed Exemption Would Provide Relief from Requirement of 10CFR50
ML20212A7501999-09-10010 September 1999
Forwards Staff Requirements Memo Response,Dtd 990525,which Provides Actions NRC Plans for Continued Oversight of safety-conscious Work Environ & Employee Concerns Program
ML20212A3171999-09-10010 September 1999
Discusses Investigation Rept 1-1998-045 Conducted on 981112 to Determine If Former Senior Health Physics Technician Being Denied Employment at Millstone in Retaliation for Having Raised Safety Concerns in Past.Synopsis Encl
ML20211K5171999-09-0202 September 1999
Expresses Appreciation for Support Provided for NRC Public Meeting on 990825
ML20211H0741999-08-30030 August 1999
Discusses GL 92-01,Rev 1, Rv Structural Integrity, Issued by NRC on 950519 & NNECO Responses for Millstone Unit 2 & 980715.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 Based on Response Review
ML20211H9971999-08-27027 August 1999
Forwards Insp Rept 50-423/99-07 on 990614-0715.Violations of NRC Requirements Occurred Re Adequacy of C/As for Organizational Changes & Being Treated as NCVs
DD-99-09, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-09) Expired.Commission Declined Any Review & Decision Became Final on 990823.With Certificate of Svc.Served on 9908261999-08-26026 August 1999
Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-09) Expired.Commission Declined Any Review & Decision Became Final on 990823.With Certificate of Svc.Served on 990826
ML20211F5841999-08-23023 August 1999
Discusses Proposed Rev 21 to Northeast Utils Quality Assurance Program TR for NRC Review & Approval,Iaw 10CFR50.54
ML20211D5701999-08-20020 August 1999
Informs That in May 1999,Northeast Nuclear Energy Co, Restarted Millstone Nuclear Power Station,Unit 2.Licensee Has Been Tasked Charter with Listed Specific Responsibilities
ML20211C4621999-08-18018 August 1999
Discusses Rev to TS Bases Sections 3/4.5.2 & 3/4.5.3, Emergency Core Cooling Sys Subsystems
ML20210S9611999-08-13013 August 1999
Informs That NRC Received Encl Ltr from Pb Johnston Expressing Concern About Certain Impacts on Shareholders of New England Electric Sys with Respect to Nees Proposed Merger with Natl Grid Group
ML20210S9511999-08-13013 August 1999
Responds to to Collins Expressing Concerns with Certain Terms of Proposed Merger Between New England Electric Sys & National Grid Group.Nrc Has No Authority to Interject Itself in Nees Merger with National Grid Group
ML20210N4921999-08-0909 August 1999
Ack Receipt of 990331 Electronic Transfer of $88,000 for Civil Penalty,Proposed on 990309.Corrective Actions Will Be Examined During Future Insp
ML20210C0751999-07-21021 July 1999
Forwards 990721 Notice of Public Meeting Re post-shutdown Decommissioning Activities Rept
ML20210A9681999-07-14014 July 1999
Responds to Re Changes to Millstone Physical Security Plan Identified as Rev 32,submitted Per Provisions of 10CFR50.54(p).No NRC Approval Is Required,Based on Util Determination That Revs Do Not Decrease Plan Effectiveness
ML20209E7341999-07-12012 July 1999
Discusses Util Responses to GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. Responses Acceptable.Info Revised in Reactor Vessel Integrity Database (Rvid) & Is Releasing as Rvid Version 2
ML20209G2921999-07-0909 July 1999
Forwards Insp Repts 50-336/99-06 & 50-423/99-06 on 990420-0614.Ten Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy
DD-96-23, Informs That on 961226,NRC Issued Partial Director'S Decision DD-96-23,in Response to Petition Submitted,Per 10CFR2.206,on 9508211999-07-0101 July 1999
Informs That on 961226,NRC Issued Partial Director'S Decision DD-96-23,in Response to Petition Submitted,Per 10CFR2.206,on 950821
ML20196J2111999-06-30030 June 1999
Forwards SE Concluding Licensee USI A-46 Implementation Program Meets Purpose & Intent of Criteria in Generic Implementation Procedure for Seismic Verification of NPP Equipment, Rev 2
ML20196J5031999-06-30030 June 1999
Responds to 990414 Petition,Submitted Per 10CFR2.206 to Nrc. NRC Solicited Support from FEMA to Ensure That Appropriate Response to Enhancements Identified to Offsite EP in Event of Radiological Emergency at Millstone,Developed
ML20196J1131999-06-29029 June 1999
Forwards Notice of Receipt & Availability for Comment of Post-Shutdown Decommissioning Activities Rept, Re .Notice Provided for Public Comments to Be Submitted within 30 Days of Notice Date
ML20196G9531999-06-24024 June 1999
Discusses Changes Provided by NNECO on 990504 to TS Bases Sections 3/4.7.7 & 3/4.7.8.Returns TS Bases to NNECO to Be Inserted in TS to Ensure That NRC Staff & NNECO Have Identical TS Bases Pages
ML20212H9661999-06-21021 June 1999
Confirms 990611 & 14 Telcons with M Selden,In Which Beckman & Assocs,Inc Was Advised to Stop Work Under Mod 4 to Task Order 005,under Contract NRC-03-98-021
ML20212H6661999-06-15015 June 1999
Forwards RAI Re 990315 Application Request for Approval of Proposed Indirect Transfer of Seabrook Station,Unit 1 License & Proposed Indirect Transfer of Millstone,Unit 3 License to Extent Held by Nepco
ML20212J0751999-06-15015 June 1999
Forwards Notice of Withdrawal of Amend Request for Allowed Outage Time Extensions for Emergency Diesel Generators & Low Pressure Safety Injection Trains of Emergency Core Cooling Sys
ML20195J3121999-06-15015 June 1999
Expresses Concern Re M Casey 990523 Column, Gaffes Turn Into Cash at NRC, & Disagrees with New London Day Earlier Editorial Criticism of NRC Investigations of Harassment & Intimidation of Employees at Millstone NPPs
ML20195K0601999-06-15015 June 1999
Forwards Request for Addl Info Re fire-related IPEEE Analysis,Per GL 88-20
ML20195J4761999-06-10010 June 1999
Forwards Insp Rept 50-336/98-219 on 981214-18,990126-29 0208-19 & 0301-05.Four Violations Identified & Being Treated as Noncited Violations
ML20195J0321999-06-10010 June 1999
Expresses Appreciation for Serving as Moderator for 990209 Public Meeting at Waterword,Ct.Questions Raised by Interested Members of Public & NRC Responses Encl.Staff Reply to Blanch Also Encl
ML20196J5091999-06-0404 June 1999
Requests Assistance to Review Petition Submitted Under 10CFR2.206 of NRC Rules.Petition Concerns EP Issues for Millstone Nuclear Power Station
ML20207G1121999-06-0303 June 1999
Forwards Insp Repts 50-245/99-05,50-336/99-05 & 50-423/99-05 on 990302-0419.No Violations Noted.Closure of 15 Significant Items List (SIL) Issues at Unit 2 Signifies Completion of Insp for Entire Unit 2 SIL
ML20207G6271999-06-0303 June 1999
Forwards Amends 105,235 & 171 to Licenses DPR-21,DPR-65 & NPF-49,respectively & Safety Evaluation.Amends Replace Specific Titles in Section 6.0 of TSs for All Three Millstone Units with Generic Titles
1999-09-30
[Table view] |
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August 12,1998 p Mr. M. L. Bowling, Recovery Officer - Technical Services l C/o Ms. P. A. Loftus, Director - Regulatory Affairs for Millstone Station NORTHEAST NUCLEAR ENERGY COMPANY PO Box 128 l
Waterford, CT.06385
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SUBJECT: INSPECTION 50-423/97-83
Dear Mr. Bowling:
This letter refers to your July 14,1M8 correspondence, in reponse to our June 12,1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, ORIGINAL SIGNED BY:
Jacque P. Durr, Chief Inspections Branch Millstone inspections Docket Nos. 50-245; 50-336;50-423
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Mr. M. cc:
B. Kenyon, President and Chief Executive Officer - Nuclear Group M. H. Brothers, Vice President - Operations J. McElwain, Recovery Officer - Millstone Unit 2 J. Streeter, Recovery Officer - Nuclear Oversight P. D. Hinnenkamp, Director - Unit 3 J. A. Price, Director - Unit 2 D. Amerine, Vice President - Human Services E. Harkness, Director, Unit 1 Operations J. Althouse, Manager - Nuclear Training Assessmeat Group F. C. Rothen, Vice President, Work Services J. Cantrell, Director - Nuclear Training (CT)
S. J. Sherman, Audits and Evaluation cc: w/ copy of Licensee's Response Letter L. M. Cuoco, Esquire J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN J. M. Block, Attorney, CAN S. P. Luxton, Citizens Regulatory Commission (CRC)
Representative T. Concannon E. Woollacott, Co-Chairman, NEAC
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Mr. M. l Distribution w/cv of licensee ra=aanse letter: l t
Region i Docket Room (with sney of concurrences)
Nuclear Safety Information Center (NSIC)
! PUBLIC I
. FILE CENTER, NRR (with Oriainal concurrences) i SPO Secretarial File, Region I i NRC Resident inspector i B. Jones, PIMB/ DISP -
W. Lanning, Deputy Director of Inspections, SPO, RI H. Miller, Regional Administrator, RI -
J.~ Andersen, PM, SPO, NRR
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M. Callahan, OCA R. Correia, NRR '
B. McCabe, OEDO
. S. Dembek, PM, SPO, NRR i E. Imbro, Deputv '0irector of ICAVP Oversight, SPO, NRR ;
D. Mcdonald, PM, SPO, NRR I W. Dean, Project Directorate, NRR
..P. McKee, Deputy Director of Licensing, SPO, NRR S. Reynolds, Chief, ICAVP Oversight, SPO, NRR D. Screnci, PAO Inspection Program Branch (IPAS)
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l L DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\97-83.RPY l- To receive a copy of this document, indicate in the box: "C" = Copy without
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attrchment/ enclosure "E" = Copy with attachment / enclosure "N" = No copy
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l OFFICE Rl/DRP l Rl/DRP _
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- . NAME BLUMBERG/db DURR % ),
L DATE pfjg/f7 08/ /98 08/ /98 08/ /98 OFFICIAL RECORD COPY i
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It Northeast none rerry na. (noot 136), witerrora, er 06383 l
C ar beg Millstone Nu-lear Power Station Northeast Nuclear Energy Company P.O. Box 128 j Waterford. Cr 06385-0128 l (860) 447-1791 l Fax (860) 444-4277
'Ihe %rtheast !!tilitics System JUL I 31998 Docket No. 50-423 B17261 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 3 NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83 Reply to a Notice of Violation
- By letter dated June 12,1998 the Nuclear Regulatory Commission transmitted the results of the above referenced inspection. The letter included a Notice of Violation citing six areas where Northeast Nuclear Energy Company's (NNECO's) activities were not in compliance with Nuclear Regulatory Commission regulations.
Attachment 1 provides a summary cf NNECO's commitments cc.itained in this submittal. Attachment 2 provides NNECO's response to the Notice of Violation items.
As stated in the individual responses, corrective actions have been taken to restore !
compliance. The cause for the majority of the violations was due to the organization i being in a " recovery mode" for the past two years and not in an " operational mode".
The corrective actions that we have identified will provide the organization with the operational focus that is needed to safely operate the unit.
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Should you have any questions regarding the information contained herein, please ;
contact Mr. David A. Smith at (860) 437-5840.
l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
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Martin L Bowling, Jr.V ,
Recovery Officer - Technical Services l Attachments (2)
oum. mum nM9 /1/51A Y lb)$
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l l U.S. Nucl=r Regulatory Commission B17261\Page 2 l
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cc: H. J. Miller, Region i Admir.istrator W. D. Lanning, Deputy Director, inspections, Special Projects Office J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 5
! W. D. Travers, Ph.D., Director, Special Projects Office
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Docket No. 50-423 B17261 j
Attachment 1 Millstone Nuclear Power Station, Unit No. 3
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Summary of Commitments NRC Operational Safety Team inspection (OSTI) Report No. 50-423/97-83
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U.S. Nuclerr Regul: tory Commission B17261\ Attachment 1\Page 1 List of Regulatory Commitments
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The following table identifies those actions committed to by NNECO in this document.
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Please notify the Manager, Millstone _ Unit No. 3 Regulatory Compliance at the Millstone Nuclear Power Station Unit No. 3 of any questions regarding this document or any associated regulatory commitments.
i Commitment Description Committed Date Number or Outage B17261-01 Revise DC 1, " Administration of Procedures and Complete Forms", to address the use of the " Temporary Change" process as described in the Technical Specifications.
B17261-02 Revise DC 4, " Procedure Compliance" to ensure Complete a procedure change is processed, if required, prior to recommencing the performance of a task
- or evolution that was stopped due to instructions appearing to be inadequate, the occurrence of unexpected results, or the task or evolution could not be performed as written.
B17261-03 Revise Procedure RP-4," Corrective Action Complete Program", to ensure the proper level of apprc. val l is provided for the extension of any corrective actions to prevent recurrenca.
The following commitments were previously provided in re!ated Licensee Event (
Report (LER) submittals and are provided for tracking purposes only.
B17183-01 The Reactor Coolant Pump Operability Procedure
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Complete
- (OP3601D.1) and Surveillance Forms acceptance criteria have been revised.
B17183-02 Training has been conducted for Operations Complete crews on Technical Specification 3.4.1.3 requirements.
B17183-04 A briefing has been provided to the Operations Complete Procedure Group to provide management's expectations of clarity and level of detail in surveillance acceptance criteria.
B17183-05 A briefing has been provided to Operations crews Complete on expectations regarding verification of
, information and performance of electrical line-ups, proper use and satisfaction of acceptance criteria and the need for surveillance validation. -
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U.S. Nuclecr Regulttory Commission B17261%ttachment 1\Page 2 Commitment Description Committed Date Number or Outage B17188-01 The Steam Generator Blowdown Sample Isolation Complete Valve 3SSR*CTV19C has been retumed to
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service so the normal path for sampling has been made available.
B17188-02 The Motor Driven Feedwater pump was re-tested Complete prior to heat-up.
B17188-03 Operating Procedure (OP3201), " Plant Heatup", Complete has been revised to place the Motor Driven Feedwater pump in service prior to exceeding 470 degrees F for the Reactor Coolant System.
B17188-04 The Operations crews have received classroom Complete and simulator training on lessons learned from this event.
B17188-05 The Unit Director and Assistant Unit Director Complete expectations for performing the heat-up/ start-up activities have been discussed with each Operating crew.
B17189-01 Shift personnel attended a training session with Complete Unit Management. Operations Manager emphasized his expectations for effective conduct of shift turnover / briefs, with an emphasis on heightened operator awareness and efficient time management associated with " active" Technical Specification Limited Condition of Operation action statement requirements.
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Docket No. 50-423 B17261 i
L Attachment 2 i
Millstone Nuclear Power Station, Unit No. 3
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, NRC Operational Safety Team Inspection (OSTI) Report No. 50-423/97-83 l Repiv to a Notice of Violation
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U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 1 Nuclear Reaulatory Commission Violation "A" (50-423/97-83-01)
Restatement of the Violation Technical Specification (TS) 6.8.3 requires, in part, that temporary changes to procedures of Specification 6.8.1 (including Appendix A of Regulatory Guide 1.33) may be made provided (a) the intent of the original procedure is not altered; (b) the change is approved by two members of plant management staff, at least one of whom holds a Senior Operator license on the unit affected; and (c) the change is documented and reviewed by the Plant Operations Review Committee (PORC) or Site Operations Review Committee (SORC) or Station Qualified Reviewer, ... within 14 days of implementation.
Contrary to the above, as si February 20,1998, administrative procedure Document Control (DC) 4, "Procedun I Compliance" allowed operators to make non-intent changes to procedures without being approved by two members of plant management staff or reviewed by PORC or 609f' a Station Qualified Reviewer, ... within 14 days of
' implementation. Examples of procedure non-intent changes where required reviews were not completed included not isolating a residual heat removal (RHR) loop from the reactor coolant system as required when aligning the RHR loop for safety injection (OP3310A, Residual Heat Removal System); exceeding the guidance of a procedural caution statement (SP 3606.4, Containment Recirculation Pump 3RSS*P1D Operational Readiness Test); and performing procedure steps out of order and not removing vent rigs (OP 3301D, Reactor Coolant Pump Operation).
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The reason for this violation is attributed to a lack of understanding of the administrative requirements for non-intent changes to procedures and the application of "Not Applicable" or "N/A" when not performing steps.
Corrective Actions That Have Been Taken and Results Achieved Operating procedures, and a sampling of surveillance procedures were reviewed for improper use of the term "N/A". Deficiencies identified were corrected through procedure changes or by adding additional documentation to the forms DC 1, " Administration of Procedures and Forms", no longer refers to a non-intent change process and specifically addresses the use of the " Temporary Change" ,
process as it is described in the Technical Specifications.
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U.S. Nucisar R gulttory Commission B17261\ Attachment 2\Page 2 DC 4, " Procedure Comp!iance" was . revised to ensure a procedure change is i
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processed, if required, prior to recommencing the performance of a task or evolution i that was stopped due to the instructions appearing to be inadequate, the occurrence of unexpected results, or the task or evolution could not be performed as written.
Presentations were given to the Millstone Unit No. Unit 3 Shift Managers in order to
! provide clarification regarding this practice. These presentations addressed "The Use j of 'N/A' to Indicate Non-Performance of Procedure Steps" and " Determining if a l~ Modification Alters the Original Intent". This included a discussion with the Manager, l Station Procedure Group regarding the proper use of N/A and documentation required.
This presentation was also shared with the Millstone Unit Nos.1 and 2 Shift Managers.
This material was also posted on the Millstone Web Site and communicated to the organization through our daily communications newsletter.
l Additionally, a lessons learned memorandum was provided to each member of the
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Operations Department and required to be reviewed prior to the next time they stood a Control Room shift.
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' Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
- Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 3 ( . Nuclear Reaulatory Commission Violation "B" (50-423/97-83-02)
l Restatement of the Violation TS 3.4.1.3 requires, in part, that at least two of the reactor coolant system loops (from among 4-reactor coolant system loops and/or 2-residual heat removal loops) shall be OPERABLE in Mode 4.
Contrary to the above, on April 7,1998, at 22:54 hours, only one reactor coolant system (RCS) loop was OPERABLE with the plant in Mode 4. This violation continued until April 8,1998 at 18:10, when a second RCS loop was made OPERABLE.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The cause of the event was human error. The Shift Manager used surveillance information without validating that the Technical Specification requirement for the
' Reactor Coolant System loops OPERABLE in Mode 4 was satisfied within the heat-up procedure. A contributing cause was insufficient detail in the surveillance acceptance criteria. (This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event Report (LER) 98-022-00, dated May 8,1998. (Reference Northeast Utiliiies letter to USNRC, B17183).
Corrective Actions That Have Been Taken and Results Achieved The following corrective actions have been completed and are described in Millstone Unit No. 3 LER 98-022-00:
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A briefing has been provided to Operations crews on expectations regarding verification of information and performance of electrical line-ups, proper use and satisfaction of acceptance criteria, and the need for surveillance validation.
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The Reactor Coolant Pump Operability Procedure (SP3601D.1) and Surveillance Forms acceptance criteria have been revised.
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Training has been conducted for Operations crews on Technical Specification 3.4.1.3 requirements.
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A briefing has been provided to the Operations Procedure Group to provide Management's expectations of clarity and level of detail in surveillance acceptance criteria.
Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved ~
Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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B17261\ Attachment 2\Page 4 Nuclear Reaulatory Commission Violation "C" (50-423/97-83-031 Restatement of the Violation TS 6.8.1 requires, in part, that written procedures sha!I be established, implemented and maintained covering the activities referenced in Appandix A of Regulatory Guide !
1.33, Revision 2, February 1978. )
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, item 2a, requires general operating procedures for cold shutdown to hot standby, item 3j requires procedures for startup operation and shutdown of safety related pressurized water reactor (PWR) systems for pressurizer pressure and spray control systems, and item 1d requires that administrative procedures covering procedure adherence and temporary change method be developed.
Contrary to the above, written procedures were not implemented as evidenced by the following examples:
' Example 1 Operating Procedure OP 3301-G, step 4.1.6, requires the operators to place the pressurizer master pressure controller in automatic.
On April 12,1998 operators deviated from the operating procedure and did not place the master pressure controller in automatic in accordance with step 4.1.6. Instead they manually lowered the master pressure controller in an attempt to match the automatic and manual signals. This failure to follow procedures resulted in two inadvertent openings of the pressurizer power operated relief valve.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The reason for this violation was the Unit Supervisor and the Reactor Operator did not operate the Pressurizer Master Pressure Controller properly due to a lack of understanding of the controller. Prior to taking the Master Pressure Controller from the manual mode to the automatic mode of operation (in accordance with step 4.1.6), the operator was instructed to adjust the controller (in accordance with step 4.1.5) to clear an annunciator that was lit. This caused the Pressurizer Overpressure Relief Valve (PORV) to open. This condition then resulted in setting up the controller to an output that would open the PORV for a second time wnen the 2200 psia interlock reset.
Personnel were performing the steps in accordance with the procedure, however, due to a lack of knowledge as a result of inadequate training on an infrequently performed evolution, the event occurred -
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'U.S. Nucinar Regulatory Commission B17261\ Attachment 2\Page 5 Corrective Actions That Have Been Taken and Results Achieved Following the events, the l&C department was contacted to provide guidance on the operation of the Pressurizer Master F. essure Controller. Personnel verified that the controller was functioning properly and that the settings were appropriate. Once this determination was made and adjustments completed, automatic pressure control was achieved using procedure OP3301G.
Classroom training was provided to each of the operating crews to address both the lessons leamed from this event, as well as more specific details regarding the proper operation of the Pressurizer Master Pressure Controller under normal, abnormal and emergency operating conditions. The training session commenced with an introduction from line management which explained the purpose of the training, as well as a clear understanding of management's expectations regarding the safe operation of the plant through conservative decision making. Following the classroom training, simulator sessions were conducted where the terminal objective was for the operators to demonstrate their ability to transfer pressurizer pressure control between automatic and manual operation. This included hands-on training for the operation of the Master
' Pressure Controller as well as the Spray Valve Controllers.
Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation.
Example 2 Operating procedure (OP) 3201, Plant Heat-up", step 4.4.9, requires that steam generator level be maintained between 45-55%.
On April 11, 1998, operators failed to maintain the level in the "C" steam generator between 45-55% during a plant heat-up. The level in the "C" steam generator dropped to the low-low level setpoint (18%) before level was automatically restored by the motor-driven auxiliary feedwater pumps.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The cause of the event was the failure of Control Room Operations personnel to diagnose that the Steam Generator "C" level loss was the result of an abnormal sampling blowdown lineup. Controlling the level in Steam Generator "C", was *
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cddressed by providing additional feedwater flow rather than placing a hold on the heatup and determining the cause of the level control problem.
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U.S. Nucl:er R:gulatory Commission B17261\ Attachment 2\Page 6 An associated cause was insufficient planning and several delays during the initial i stages of heatup which challenged the shift's ability to meet a 24-hour surveillance criteria (Technical Specification 3.0.3 action) for Response Time Testing of the Turbine :
Driven Auxiliary Feedwater Pump. Also contributing to the event was lack of testing of I the Motor Driven Feedwater Pump prior to use. The start of the Motor Driven Feedwater Pump occurred relatively late in the heat-up evolution providing a relatively ,
short period to recover from the Motor Driven Feedwater Pump startup problems.
i This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event l Report (LER) 98-C23-00, dated May 9,1998. (Reference Northeast Utilities Letter to USNRC, B17188).
Corrective A Gons That Have Been Taken and Results Achieved The following corrective actions have been completed and are described in Millstone Unit No. 3 LER 98-023-00:
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. The Steam Generator Blowdown Sample Isolation Valve 3SSR*CTV19C has been retumed to Service so the normal path for sampling has been made available.
. The Moto: Driven Feedwater pump was re-tested prior to heat-up.
. Operating Procedure (OP3201), " Plant Heatup" has been revised to place the Motor
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Driven Feedwater pump in service prior to exceeoing 470 degrees F for the Reactor Coolant System.
. The Operations crews have received classroom and simulator training on lessons learned from this event.
. The Unit Director and Assistant Unit Director expectations for performing the heatup/startup activities have been discussed with each Operating crew.
Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
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Millstone Unit No. 3 is in full compliance with respect to the cited violation.
Example 3 l i Condition Based Maintenance Procedure CBM 105, "PM Program Changes and l Deferrals for U3", states that, " deferral requests are required if a PM ... cannot be performed within its grace peiiod."
On April 10,1998, a preventive maintenance task (automated werk order 96-12561) for
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the turbine auxiliary feedwater pump govemor had not been deferred or performed ,
within its grace period.
NNECO's Response NNECO does not dicpute the cited violation.
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'U.S. Nuclxr Regulatory Commission B17261\ Attachment 2\Page 7 Reason for the Violation The reason for this violation is attributed to personnel error in performing scheduling activities. Within the Millstone Unit No. 3 power ascension schedule there were three ascension to Mode 3 activities which represented: 1) the first heat up to Mode 3, 2) the repair contingency window, and 3) a contingency repair window that followed the turbine generator overspeed testing. The responsible individual incorrectly scheduled the Preventive Maintenance for changing the oil in the Turbine Driven Auxiliary Feedwater pump governor during the third ascension to Mode 3 which was scheduled for May,1998. The " Preventive Maintenance Change and Deferral Request" submitted ,
by Work Planning for this component was properly approved for deferral with the intent that the maintenance would be completed prior to steam admission. The individual did not self check his performance when scheduling this activity.
Corrective Actions That Have Been Taken and Results Achieved in response to this scheduling error, the individual's supervisor reviewed the details of i the "Stop - Think - Act - Review" (STAR) program with him. The individual was also I
' counseled regarding management's expectation to take the necessary time to assure f that the work is perfonned properly. '
Corrective Actions to Avoid Future Violations ,
No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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'U.S. Nuclear Regulatory Commission B17261\ Attachment 2\Page 8 Nuclear Reaulatory Commission Violation "D" (50-423/97-83-04)
Restatement of the Violation Technical Specification (TS) 3.4.9.2 requires, in part, bat pressurizer temperature shall be determined to be within the limits at least once per 30 minutes during heat-up or cooldown.
Contrary to the above, on April 1,1998, pressurizer temperature was not determined to be within the limits at least once per 30 minutes during a plant heat-up. The pressurizer heat-up rate was not compared to Technical Specification Limits between 0400 and 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> as required.
NNECO's Response NNECO does not dispute the cited violation.
Reasort for the Violation The cause of this event is attributed to human error. The Operator was aware that
- Reactor Coolant System and Pressurizer heat-up surveillance were in progress. The Operator recorded the Reactor Coolant System heat-up rate as required, but inadvertently did not take the Pressurizer heat-up rate data, which was on a second data sheet. Historical computer point data were extracted from the plant computer to verify Technical Specification limits were not exceeded.
Corrective Actions That Have Been Taken and Results Achieved The operator was counseled regarding this event and his performance. The individual was reminded of the importance of proper turnovers and performing surveillance when required. A lessons learned summary was developed and shared with the Operations Department.
A training session was provided to the on-shift members of the Operations Department which incided a specific section in the lesson plan regarding this event. Discussion during the lesson included the event, the apparent cause, review of the lessons learned, and a question and answer period. An Operations Briefing Sheet was also provided to the department detailing the importance of pre-job briefs, understanding the i task at hand, and the individual roles and responsibilities required when performing the task.
Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved
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'U.S. Nucl=r Regul: tory Commission B17261\ Attachment 2\Page 9 Nuclear Reaulatory Commission Violation "E" (50-423/97-83-06)
Restatement of the Violation Criterion XVI of 10CFR 50, Appendix B, requires, in part, that measures must be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. For significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, as of April 13,1998, appropriate corrective actions were not taken to prevent recurring system alignment deficiencies that were identified in an investigation report, " Configuration Control of Valves Switches / Breakers, CR M3-97-0485". These deficiencies included valves not properly aligned, inadequacies in the implementation of the valve and breaker alignment process, and deficiencies in the implementation of the locked valve procedure.
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NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The reason for this violation is attributed to management's failure to establish and implement a comprehensive program to adequately document and track component alignment deviations controlled by existing processes / procedures. Although existing i processes / procedures are in place to control the individual aspects of component !
alignment, there has been inadequate integration of these processes / procedures into an effective common program with a single owner.
Specifically, at the time that Condition Report M3-97-0485 was being investigated, management did not recognize that the existing program was not adequate. On the contrary, the investigation determined that the program / process / procedures in place at the time were adequate and that it was a matter of individuals not implementing the program correctly. The investigation into these recent examples recognized that the existing program / process / procedures are not well integrated and that thic was the cause of the event.
Corrective Actiorr, That Have Been Taken and Results Achieved
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Numerous corrective actions have been taken to address the items noted in the
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inspection Report regarding Configuration Control at Millstone Unit No. 3. These items are detailed as follows:
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'U.S. Nuclur Regulatory Commission B17261\ Attachment 2\Page 10 Procedure RP4, " Corrective Action Program", has been revised to ensure that the proper level of approval is provided for the extension of any corrective actions tn prevent recurrence.
Each of the mispositioned valves identified in the OSTI Inspection Report were verified to be placed in their proper alignment.
The Millstone Unit No. 3 Operations Manager reinforced procedure compliance with Operations Department personnel with respect to the procedure requirements in DC4 (Procedure Compliance) that allow the use of "NA's" on procedures and forms.
Additionally, there was a discussion regarding where to document the bases for each use of a "Not Applicable" statment, and that pen and ink changes to component configuration on forms are not allowed. (DC 1)
The locked valve program was audited by the line organization to Operations Procedure OP 3260B " Equipment Control" and discrepancies resolved. An evaluation '
of systems not presently included in the locked valve program was performed against
. the criteria'in OP 32608.-
Completed valve lineup forms required to support the startup of Millstone Unit No. 3 were reviewed in order to identify deviations from approved lineups. The deviations t identified in the completed lineup forms were resolved by making procedure changes as necessary. Valves in the lineups that were repositioned after the date of valve lineup completion had their pc.,sitions verified.
OperatinD Procedure line-ups were reviewed to identify references to throttle valve positions, and appropriate procedure changes entered to provide necessary guidance for their settings. Throttle valve positions were verified in the field to assure that components were properly positioned.
Procedure OP 3260B was revised to clarify requirements for verifying positioning of locked throttle valves and criteria for independent verification selection requirements.
Procedures were reviewed to determine if independent reviews were properly documented on the valve line-up sheets. Valve line-up sheets were reviewed and field walk-downs conducted to verify proper positioning.
The surveillance schedule was updated to include the audit of locked valves in accordance with OP 32608. In addition, the other 3200 series procedures were
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reviewed for frequency based performance requirements. This effort identified two enhancements that were incorporated into existing tracking programs to assure proper scheduling and performance.
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'U.S. Nucirr Regulatory Commission B17W%ttachment 2\Page 11 The Engineenng Department evaluated the criteria for labeling of valves for vendor supplied skid mounted equipment. The program was determined to be adequate from the viewpoint that valves that are acaally positioned by the operators in the field are labeled, and those that are not labeled were determined to be maintenance convenience valves (e.g., valves such as petcocks are used to avoid having to remove a pipe cap).
Two systems were reviewed to determine if the proper level of electrical components were included on valve line-up sheets. The Emergency Diesel and Quench Spray Systems were both reviewed and determined to either have the appropriate components listed or they were addressed in other Operating Procedures.
A Multi-Discipline Configuration Control Task Force has been established to evaluate, trend and recommend improvements in the configuration control processes. This task force is intended to conduct review of configuration control incidents identified through unit generated condition reports, Nuclear Oversight audits, and regulatory inspection reports. The task force examines the programmatic aspects of both valve and electrical
. configuration control including but not limited to tagging, position verification, inaccessible valves, locked valves, and work practices. Results of the review are periodically sent to the Unit Director and the Vice President of Operations with reymmended actions to improve performance. The task force is chaired by a senior i manager with members that represent various departments from all three Millstone l Units.
Active tag clearances were field " ified prior to restart to assure that components were properly positioned. No problems were noted. '
Peer checks have been implemented for operator actions during power ascension to increase assurance of the proper performance of sufety related operational procedures and surveillance.
Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved l Millstone Unit No. 3 is 'n full compliance with respect to the cited violation.
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'U.S. Nucirr Regul: tory Commission B17261\ Attachment 2\Page 12 Nuclear Reaulatory Commission Violation "F" (50-423/97-83 d} l Restatement of the Violation TS Table 3.3-1, Functional Unit 21, Action 5(a), requires, in part, that with a Shutdown Margin Monitoring channel inoperable, restore the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or verify valves as per Specification 4.1.1.2.2 (potential dilution
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paths), are closed and secured in position within the next four hours.
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Contrary to the above, on April 8,1998, at 21:15 hours, 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> after declaring a {
Shutdown Margin Monitor channel inoperable, the valves identified in Specification '
4.1.1.2.2 had not been verified to be closed and secured in position. On April 9,1998, upon discovery of this deficiency by the licensee, the valves were verified closed and j secured in place.
NNECO's Response NNECO does not dispute the cited violation.
Reason for the Violation The cause of this condition is attributed to human error in that the shift managers failed to recognize the need to complete the required surveillance in the allowed time. This oversight was due to poor prioritization of the required tasks during the shift which resulted in not assigning a responsible individual to perform these tasks.
This violation was also addressed by NNECO in Millstone Unit No. 3 Licensee Event Report (LER) 98-024-00 dated May 1,1998. Reference Northeast Utilities Letter to USNRC, B17189.
Corrective Actions That Have E>een Taken and Results Achieved The following corrective actions have been completed, some of which are described in Millstone Unit No. 3 LER 98-024-00:
. Actions were taken to verify that the boron dilution pathways were secured.
. Shift personnel attended a training session with Unit Management where the I Operations Manager emphasized his expectations for effective conduct of shift turnover / briefs, with an emphasis on beightened operator awareness and efficient time management associated with " active" Technical Specification Limited I Conditions of Operation action statement requirements.
. Additional detail has been added to the Shift Daily Status Report in order to assure that Limited Conditions of Operation rewive the proper focus. These have been added up front in the report and are also discussed during the Shift Manager's
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report at both the morning Work Planning Meetings and the Management Meetings.
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'U.S. Nucl:ar Regulatory Commission B17261\ Attachment 2\Page 13 Corrective Actions to Avoid Future Violations No additional corrective actions are deemed necessary.
Date When Full Compliance Will Be Achieved Millstone Unit No. 3 is in full compliance with respect to the cited violation.
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