ML20202A823

Responds to NRC Re Violations Noted in Insp Repts 50-245/97-81,50-336/97-81 & 50-423/97-81 of Emergency Preparedness Program on 971222.Corrective Actions:Management Ownership of & Involvement in Dose Has Been Established

ML20202A823
Person / Time
Site:	Millstone
Issue date:	02/05/1998
From:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-245-97-81, 50-336-97-81, 50-423-97-81, NUDOCS 9802100179
Download: ML20202A823 (16)

Text

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FEB 5 1998 Docket Nos. 50-245 50-336 50-423 B16953 Re: 10CFR2.201 U.S. Nuclear Regu~atory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Reply to Notice of Violation 50-245,336,423/97-81 Notice of Violation For NRC Emergency Preparedness Program Inspection Report Nos. 50-245.336.423/97-81 in a letter dated November 24,1997,* the NRC transmitted the results of a combined Emergency Preparedness Exercise and Emergency Preparedness Program inspection.

The NRC Inspection Report listed four apparent violations of NRC requirements. An enforcement conference was held between the representatives of the NRC Staff and Northeast Nuclear Energy Company (NNECO) at the NRC Region 1 office on l

December 22,1997 to discuss the apparent violations. In a letter dated December 30, 1997W, the NRC transmitted the final results of the Emergency Preparedness Program inspection which includes four Level IV violations.

i NNECO's commitments associated with the response are contained within to this letter.

On behalf of Millstor, Unit Nos.1,2, and 3, Attachment 2 provides NNECO's reply to the identified inadequacles in the dose assessment process Notice of Violation W

J. T. Wiggins letter to Neil S. Carns, " Emergency Preparedness inspection of the Millstone Station August 21,1997 NRC/ FEMA Graded Plume Exposure Exercise, And The Emergency Preparedness Program For Restart," dated November 24,1997.

J. T. Wiggins letter to B. D. Kenyon, ' Notice of Violation For NRC Emergency Preparedness Program inspection Report Nos. 50-245,336,423/97-81," dated December 30,1997,

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U.S. Nuclear Reguictory Commission B16953\\Page 2 pursuant to the provisions of 10CFR2.201. Attachment 3 provides NNECO's repiy to

<the failure to maintain emergency response equipment and facilities Notice of Violation pursuant to the provisions of 10C"R2.201. Attachment 4 provides NNECO's reply to the decrease in effectiveness of licensee implemented Revision 22 to the emergency plan Notice of Violation pursuant to the provisions of 10CFR2.201. Attachment 5 provides NNECO's reply to the failure of internal audit A25113 to include all elements of 10CFR50.54(t) Notice of Violation pursuant to the provisions of 10CFR2.201.

If you have any questions concerning this submittal, please contact Mr. Michael D.

Ehredt at (860) 440-2142.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY MAA Martin L.' Bowling, Jr.

J Millstone Unit No. 2 Recovery Officer l

Attachments (5) l l

cc:

H. J. Miller, Region 1 Administrator W. D. Travers, Ph.D., Director, Special Projects Office P. F. McKee, Deputy Director, Licensing and Oversight, Special Projects Office W. D. Lanning, Deputy Director, inspections, Special Projects Office J. P. Durr, Branch Chief Inspections, Special Projects Office M. C. Modes, Chief, Emergency Preparedness and Safeguards Branch S. Dembek, NRC Project Manager, Millstone Unit 1 T. A. Eastick, Senior Resident inspector, Millstone Unit 1 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit 2 J. W. Andersen, NRC Project Manager, Millstone Unit 3 A. C. Corne, Senior Resident inspector, Millstone Unit 3 L

i l

Docket Nos. 50-245 i

50-336 50-423 r

B16953 l

Millstone Nuclear Power Station, Unit Nos.1,2, and 3 List of Regulatory Commitments Reply to Notice of Violation For NRC Emergency Preparedness Program Inspection Report Nos. 50-245,336,423/97-81 5

February 1998

U.S. Nuclear Regulatory Commission B16953%ttachment 1\\Page 1 List of Regulatory Commitments The following table identifies those actions committed to by NNECO in this document.

Regulatory Commitment C:smmitted Date or Outage B169531:

Tabletop drills to ensure the proficiency February 6,1998 of dose assessment personnel are currently being conducted.

B16953-2:

A Nuclear Oversight evaluation will be May 29,1998 performed after the completion of the corrective actions to ensure that t.,e actions taken have been effective in resolving the deficiencies identified in the dose assessment process.

B16953-3:

The continuing training program for the May 1,1998 l

Chemistry Technicians involved in on-shift dose assessment will be revised to incorporate practical application dose assessment axercises.

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Docket Nos. 50-245

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50-336 50J23 B16953 e

1 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Reply to Notice of Violation 50-245,336,423/97-81 Identified inadequecles in The Dose Assessmert Process e

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February 1998

U.S. Nucl:cr R:gul: tory Commission B16953%ttachment 2\\Page 1 Restatement of the Violation 10CFR50.54(q) states that; "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in $50.47(b) and the requirements in Appendix E of this part.

10CFR50.47(b)(9) states that; " Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of radiological conditions are in use."

Contrary to the above, as of August 29,1997, Mequate dose assessment methods were not in use, in that all personnel responsible for dose assessment could not adequately perform radiological dose assessment for potential offsite consequences of radiological conditions in a manner necessary to support timely emergency management decision making for protective action recommendations.

This is a Severity Level IV violation (3upplement Vill-Emergency Preparedness).

Reason for the Violation:

The root cause for the inadequacies in the dose assessment process was insufficient upper management involvement in the development and implementation of the dose assessment process, Without upper management involvement an improper First Line Management mindset allowed the lack of a questioning attitude to exist within the Dose Assessment department.

Corrective Steps Taken and Results Achieved:

The following actions have been taken to resolve the non-compliances described in this notice of violation:

1, Management ownership of and involvement in the dose assessment process has been established. At the direction of management, an internal self-assessment, performed by an external company, was conducted and an independent assessment, with recovery support for the dose assessment process, was provided by industry peers.

2.

Dose assessment procedures have been revised to ensure that TEDE is now calculated, in both the control room and the EOF, as defined in EPA-400.

3.

Dose assessment procedures have been streamlined and condensed and the dose assessment methodology has been revised to allow for rapid assessments.

U.S. Nucl:Cr R:gul: tory Commission

B16953\\ Attachment 2\\Page 2

• 4.

- Manual calculations of TEDE and thyroid CDE have been replaced with a human engineered computer program named IDA.

IDA is quality software and will compute TEDE and thyroid CDE based on EPA-400.

5.

The techniques and methods used within the dose assessment procedures have been revised to ensura compliance with NRC regulations and current industry practice - The bases for methods, values and conversion factors used within the dose assessment procedures are contained within a procedure basis document.

6.

Dose assessment training materials have been revised and dose assessment personnel have received training on the new procedures, methodologies and computer software.

7.

The revised dose assessment training materials have been incorporated into the continuing training program for the Radiological Dose Assessment Team.

Corrective Steps That Will Be Taken to Avoid Further Violations:

The following actions will be taken to ensure that the non-compliances described in this notice of violation do not reoccur:

1.-

Tabletop drills to ensure the proficiency of dose assessment personnel are currently being conducted.

2.

A Nuclear Oversight evaluation will be performed after the completion uphe corrective actions to ensure that the actions taken have been effective in resolving the deficiencies identified in the dose assessment process.

3.

The continuing training program for the Chemistry Technicians involved in on-shift dose assessment will be revirad to incorporate practical application dose assessment exercises.

Date When Full Compliance Will Be Achieved:

NNECO is currently in full compliance regarding this violation.

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Docket Nos. 50-245 50-336 50-413 B16953 i

Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Reply to Notice of Violation 50-245,336,423/97-81 Failure To Maintain Emergency Response Equipment And Facilities t

February 1998

U.S. Juciser R:gul tory Commission B16953\\ Attachment 3\\Page 1 Restatement of the Violation 10CFR50.54(q) states that; "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in S50.47(b) and the requirements in appendix E of this part.

10CFR50.4)(b)(8) states that; " Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

Contrary to the above, as of August 29,1997, adequate facilities and equipment were not being maintained, in that the TSC/OSC reference library contained uncontrolled drawings and other documents related to the response effort were in the facility but were not marked as controlled documents.

This is a Severity Level IV violation (Supplement Vill-Emergency Preparedness).

Reason for the Violation:

The root cause for this violation was the ineffectiveness of Emergency Planning Department management in controlling change.

Factors contributing to this were insufficient programmatic detail, inadequate interfacing with other organizations, confusing management expectations, and the complexity of changes occurring in both the station Emergency Response Organization and station schedules.

Corrective Steps Taken and Results Achieved:

The following actions have been taken to resolve the non-compliances described in this notice of violation:

1.

Management expectations have Laen established for emergency response facility maintenance.

2.

The Emergency Planning tiepartment procedures regarding the maintenance of emergency response facilities have been revised to add additional detail.

3.

The re-establishment of emergency response facility readiness after use of the i

facility is now being documented.

l Corrective Steps That Will Be Taken to AvcM Further Violations:

No further corrective actions are necessary.

U.S. Nucirr Regulatory Comm;ssion B16953%ttachment 3\\Page 2 Date When Full Compilance Wist Be Achieved:

NNECO is currently in full compliance regarding this violation.

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Docket Nos. 50-245 50-336 50-423 B16953 l

1 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Reply to Notice of Violation 50-245,336,423/97 Decrease In Effectiveness Of Licensee implemented Revision 22 To The Emergency Plan February 1998

U.S. Nucirr_Regulitory Commission B18953\\ Attachment 4\\Page 1 i

Restatement of the Violation 10CFR50.54(q) states that: "A licensee authorized to possess and operate a nuclear power reactor:.shall follow and _ maintain in effect emergency plans which meet the~

standards in $50.47(b) and the requirements in appendix E of this part._"... The nuclear-power reactor licensee may make changes to these plans without commission approval-only if the changes'_do not decrease the effectiveness of the plans and the-plans continue to meet the standards of $50.47(b) and the requirements of appendix E to_this part...."

. Contrary to the above, the NRC dotarmined,- by direct inspecuon, that during June.1997, the licensee _ implemented Revision 22 to the emergency plan. The licensee decreased the effectiveness of the emirgency plan in Revision 22 and implemented it without prior NRC approval.- Decreases m effectiveness included changing accountability time from

-30.to 45 minutes, a provision decreasing the coverage for 4 health physics positions

-from 30 to 60 minutes, and staffing time reductions for other emergency response staff ~

members.

This ls' a Severity Level IV violation (Supplement Vill-Eme,gency Preparedness).

Reason for the Viol'ation:

The root cause for this violation was a failure of the Emergency _ Planning' Services

- Department management to develop and implemert a comprehensive change control process. Although an emergency program change review process was in place, the process did' not ensure adequate reviews. Additionally, Emergency Plan revisions were not regarded as substantial undertakings in that defined project schedules and resources were not required End verification and validation of the Emergency Plan was not performed. The level of qua!ification required to perform _10CFR50.54(q) reviews of

- Emergency Plan changes was not addressed by procedures.

4

- Corrective Stepa Taken and Results Achieved:

The following actions have been taken to resolve the non-compliances described in this notice of violation:

1.-

The Emergency Planning Services Department management has been strengthened with the addition of an experienced supervisor.

2.-

Training has been provided to the Emergency Planning Services Department staff to stress the importance of the Emergency Plan.

U.S. Nucirr Regul: tory Commission B16953%ttachment 4\\Page 2

' 3.

' Training has been provided to the Emergency Planning Services Department staff concerning the require.nents of 10CFR50.54(q).

4.

Specific items concerning Revision 22 to the Millstone Station Emergency Plan have been addressed in Revision 23, 5.

Emergency Planning Services Department procedures conceming Emergency Plan changes have been revised.

6.

Additional' specific items concerning Revision 22 to the Millstone Station Emergenc) Plan have been addressed in Revision 24 which has been submitted to the NRC Staff for review and approval.

Corrective Steps That Will Be Takon to Avoid Further Violations:

No further corrective actions are necessary.

Date When Full Compliance Will Be Achieved:

NNECO is currently in full compliance regarding this violation.

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Docket Nos. 50-245 50-336 E9;d2.3 B16953 l

. Attachment 5 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 -

Reply to Notice of Violation 50-245,336,423/97-81 Fa' lure Of Internal Audit A25113 To include All Elements Of 10CFR50.54(t) -

4 February 1998

U.S. Nuc!=r Regul: tory Commission B16953\\ Attachment 5\\Page i Restatement of the Violation 10CFR50.54(t) states that; "A nuclear power reactor licensee shall provide for the dev-'opment,

revision, implementation, and maintenance of its emergency preparedness program. To this end, the licensee shall provide for a review of its emergency preparedness program at least every 12 months by persons who have no direct responsibility for implementation of the emergency proparedness program. The review shall include an evaluation for adequacy of interfaces with state and local governments and of licensee drills, exercises, capabilities, and procedures..."

Contrary to the above, the Audit Report No. A25113, entitled " Connecticut Yankee / Millstone Emergency Plan Audit and 10CFR50.54(t) Review for 1996" dated January 24,1997, did not include all elements of 10CFR50.54(t) such as adequacy of interfaces with state and local governments, emergency preparedness program

- capabilities, and procedures.

This is a Severity Level IV violation (Supplement Vill-Emergency Preparedness).

Reason for the Violation:

The root cause for this violation was a failure of the Quality Assessment Services l

(QAS) Department management to provide adequate and effective oversight of the Emergency Preparedness Program audit. During the course of this audit, the QAS l

management charged with providing oversight of this audit changed seven times and l

the applicable OAS audit procedure was revised five times. The OAS audit procedures put in place during the conduct of the audit were not prescriptive or detailed with respect to standards and expectations for audit scope, planning, or implemente n. At the completion of this audit, QAS approved an ar 'it report that was recognized to be inadequate.

- Corrective Steps Taken and Results Achieved:

The following actions have been taken to resolve the non-compliances described in this notice of violation:

1.

A new management team has been put into place in the OAS organization.

2.

The Audits and Evaluations Group, as part of the newly formed Nuclear Oversight Department, has been reorganized into SALP areas to provide more focus on the audit process and assign more responsibility.

3.

The total number of assigned auditors has been increased from 7 to 22 to allow more depth of review in all audit areas.

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.U.S. Nuclxr R;gulitory Commission -

B18953%ttachment 5\\Page 2 4i * ' Nuclear Oversight audit procedures have been revised and upgraded to include prescriptive guidance concerning the types and sources of items to be addressed during an audit and to require more active participation in the planning and scope of the audit by the Audits and Evaluation managers and Director.

5.

The expectations for audit scope, planning, and implementation of Emergency

. Planning audits has been communicated to the auditors.

6.

Expectations concerning the increased use of inestry technical specialists for the conduct of audits has been established.

7.

A new Emergency Planning Audit that was boul rigorous and properly scoped was conducted in 1997 and included the use of two industry' experts.

l Emergency-Planning commitments were identified and verified including the requirements of 10CFR50.54(t).

l Corrective Steps That Will Be Taken to Avoid Further Violations:

The recent Emergency Planning Audit was a culmination of numerous corrective

- actions taken to address the concerns identified both by the Notice of Violation and by -

other assessments which identified the Nuclear Oversight organization as a major-contributor to the sitewide problems at Millstone. While the corrective actions have addressed the specific issues raised in the referenced NOV, the most important change has been to the culture which encourages continuous improvement.

No further specific corrective actions are necessary, Date When Full Compliance Will Be Achieved:

NNECO is currently in full compliance regarding this violation.

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