ML20216G059

Provides Preliminary Results of Insp Conducted 980209-20. Detailed Findings of Team Insp Will Be Documented in Insp Rept 50-423/97-82.Insp Team Leader Provided Results of Insp at 980226 Public Meeting

ML20216G059
Person / Time
Site:	Millstone
Issue date:	04/14/1998
From:	Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
References
50-423-97-82, NUDOCS 9804170322
Download: ML20216G059 (7)

See also: IR 05000423/1997082

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April 14,1998

Mr. Martin L. Bowling, Recovery Officer - Millstone Unit 2

c/o Ms. Patricia Loftus, Director - Regulatory Affairs

Northeast Nuclear Energy Company

P.O. Box 128

Waterford, CT 06385-0128

Dear Mr. Bowling:

SUBJECT: PRELIMINARY INSPECTION RESULTS

This letter provides the preliminary results of the NRC Region I team inspection of

Northeast Utilities (NU) controls in identifying, resolving and preventing issues that degrade

the quality of plant operations or safety at Millstone Unit 3. This team inspection was

performed onsite from February 9 through February 20,1998, using NRC inspection

procedure 40500, " Effectiveness of Licensee Controls in Identifying, Resolving and

Preventing Problems." The detailed findings of the team inspection will be documented in

inspection report 50-423/97-82. The inspection team leader provided you with the rer.ults

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of the inspection at a public meeting on February 26,1998.

Inspection Scope

Our inspection examined the management processes used to provide direction to the plant

staff in order to facilitate effective and safe plant operations. This was accomplished by

reviewing your goals and expectations, communications and teamwork, receptiveness to

problems brought forward, performance monitoring, and your commitment to resolve safety

committee recommendations and audit / assessment findings.

Our inspection also assessed the adequacy of your corrective actions program including

processes for identification, analysis and resolution of plant deficiencies. The inspectors

evaluated your organization's responsiveness in dealing with issues brought forward by

employees through various channels including your employee concerns program. The team

examined the backlog of open problem reports to verify that safety significant issues are

being tracked to completion, reviewed the process to prioritize corrective actions based on

risk, and evaluated your process for assessing the effectiveness of corrective actions.

The inspectors evaluated your process for site and departmental self-assessments. The

team reviewed the corrective actions that were implemented for several significant self-

assessments and third party audits including actions applicable to Unit 3 from the ACR-

7007 Event Response Team Report, and the actions to improve the Nuclear Oversight

Department taken in response to the 1996 Joint Utilities Management Assessment. In

addition, the inspectors examined the effectiveness of your Performance and Evaluations

Group in their audit, surveillance and quality control function.

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The team observed activities involving the Nuclear Safety Advisory Board (NSAB), the Site

Operations Review Committee (SORC) and the Unit 3 Plant Operations Review Committee

(PORC). The inspectors reviewed your operating experience program, including the

programs for evaluation of industry data and site experience.

Preliminary Assessment of the Management Process

The team found that management communications methods with the plant staff were a

strength. There was a common understanding of management's expectations by plant

personnel. However,it was noted that a strategic plan and vision statement on where the

plant is headed were stillin draft. This is considered a weakness in view of the fact that

the current management has been in place since late 1996. Overall, the Nuclear Group

policies and standards were considered good. Teamwork initiatives at the first line

supervisor and above were developed, but have not been fully extended to the worker

level.

Observations and interviews show that managers and supervisors encourage employees to

identify problems. The plant staff feels that management is receptive to problems brought

forward and individuals generally characterized the environment as improved and currently

receptive to problem identification. There is no reluctance or reservation expressed by

individuals to identify problems, either through the Corrective Actions Condition Report

process, the Employee Concems Program (ECP), or to the NRC.

The handling of individual HIRD cases by the Employee Concerns Program and the Safety

Conscious Work Environment (SCWE) program is adequately responsive to specific case

needs. Both technical and human-side problems are generally well addressed. The ECP

case intakes and the Employee Concerns Oversight Panel (ECOP) oversight activities and

surveys are used to identify potential or actual HIRD problems or organizational units which

exhibit barriers to free identification and reporting of problems. These are positive

contributions to the overall process. These mechanisms are effective, especially for the

more significant issues identified as problem areas. However, NU management has not

been fully effective in addressing trends and common causes for HIRD allegations

genersted organization-wide to ECP. A significant backlog of HIRD allegations was

pending investigation and the backlog and emergent HIRD allegations had not been

analyzed by NU for broad trends or patterns, and common causes. As a result, the actions

taken to date had not effectively assessed the nature and substance of the continuing high

incidence rate of HIRD allegations at the time of the inspection. Further, the SCWE

processes have not yet been formalized. That is, the program lacks structure in the form

of procedures, formal processes and documentation requirements.

Preliminary Assessment of the Corrective Actions Process

Overall, the team saw evidence that the corrective actions program is functioning, but it is

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clear that the program will continue to require careful monitoring by NU management to

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ensure sustained performance. For example, the team found a notable number of

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additionalissues in a relatively small sample size of Condition Reports, after NU had

completed their own extensive self-assessment preparing for this team inspection. In

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general, the current findings represent minor process problems with the exception of the

boric acid tank level finding discussed below.

The team found a structurud framework in place that 'provided a strong' definition for the

corrective actions program. There is evidence of a good deal of management attention

applied to infuse quality into the program implementation process. The team observed a

general improving trend in quality over the last year for most program aspects, including

issue identification, classification, analysis and actions to prevent recurrence. However,

deficient conditions were found to exist in some specific root cause analyses and

corrective actions.

The team found that the Corrective Actions Program lacked controls when it combined

Condition Reports such that they did not preserve issues and that they did not maintain

their appropriate significance level. This weakness was evident in the handling of multiple

condition reports concerning deficiencies in the Nonconformance Report process. The

team considers this activity to be a program weakness.

The team noted that the licensee had established a generally low threshold for recording

issues but that there was a tendency to assign a lowur Significance Level classification

than appropriate and to waive root cau.se analysis to similar issues. The team is concerned

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that this practice has the potential to cause trends to be missed and possibly result in

ineffective corrective actions.

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' incomplete corrective actions and root cause analysis were identified during the team's

review of several Condition Reports including the repetitive air binding of the Boric Acid

Transfer pumps. The team noted that NU engineering failed to recognize the potential

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unreviewed safety questir. (USO) which resulted from their initial conclusion of a more

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restrictive Boric Acid 'Iank level requirement relative to the Technical Specification. The

team also observed that the reportability evaluation of the event was incomplete and that

NU failed to consider industry operating experience in their evaluation of the problem.

The team found that long term compensatory measures are in effect for fire protection

systems because surveillance testing which verifies operability of these systems has been

suspended. Compensatory measures are being taken to allow restoration of a fire

protection system, but in this case, are being used inappropriately to substitute for long

term system inoperability.

Preliminary Assessment of Site and Departmental Self-Assessment Process

The team found that self-assessments were typically of high quality. It noted that the

quality assurance and quality control functions of the Nuclear Oversight organization have

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improved as a direct result of improved staffing, qualifications, and knowledge level. Of

note is the Nuclear Oversight Restart Verification Assessment, which the team considered

to be a strong initiative. That Nuclear Oversight now has the opportunity to concur on

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corrective actions taken as a result of its audit findings and nonconformance reports is also

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considered to be a substantive improvement.

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Preliminary Assessment of Safety Review Committse/ Operating Experience Programs

The team found that all three safety review committees (Nudear Safety Advisory Board,

Site Operations Review Committee, and Plant Operations Review Committee) operated

effectively, were well prepared for their meetings, and provided quality input in addressing

the issues before them. The team also noted that the independent Safety Engineering

Group has made considerable progress, albeit at the expense of performing safety reviews,

in reducing the backlog of operating experience (OE) reviews. The backlog of OE reviews

on Unit 3 has been reduced from several hundred to approximately 40. However, the

number of ISEG reviews done in 1997 was only 12, down from 24 the previous year.

Preliminary Findings identified by the NRC Team

The NRC inspection nm identified regulatory issues. Based on our preliminary evaluation,

the following finding m.e being considered as potential violations:

• In the area of design control, the team found problems in the Master Setpoint List

(MSL), in that it was inconsistent and did not contain all of the setpoints and the

calculatiun references as required by NGP 5.23. Also, a potential deficiency with the

sub-cooling margin setpoints was found. In addition, the findings callinto question the

adequacy of setpoint control.

• There were two procedural problems identified with maintaining accurate design basis

documents. The Safety Functional Requirements Manual and the Design Basis

Summaries were not maintained as required by NGP 5.28 and PI-29, respectively.

• The team found problems with meeting the organizationalindependence required by

Section 6 of the Millstone Unit 3 Technical Specifications because of the reporting

relationship between the Radiation Protection Manager and the Maintenance Manager.

These requirements are established in TS 6.2.1.d, the Updated Final Safety Analysis

Report and Regulatory Guide 8.8. Also, the independence required for persons

cerforming the independent Safety Engineering Group (ISEG) reviews for human

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performance issues did not meet the intent of TS 6.2.3.3.

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• The inspection identified several individual problems within the Millstone Corrective

Action Program. _ These problems include: (1) incomplete corrective actions and root

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cause analyses, as illustrated by the repetitive air binding of the boric acid transfer

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pumps, and (2) issue closure without completion of all corrective actions, as was the

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case with Design Change Notice (DCN) review required by CR M3-97-0506and the

closure of an Automated Work Order (AWO) to correct service water flow instrument

anomalies that was associated with Operator Work Around 96-03. The team noted that

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completion of the DCN review was an Adverse Condition Report (ACR) 7007 and

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Configuration Management Program restart commitment.

• The team identified some procedural problems with assigning inappropriate significance

levels for Condition Reports. These included the following: incomplete action on

Generic Letter (GL; 89-13, Service Water Fouling, and GL 90-03, Vendor Technical

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Information Program. These are commitments to the NRC and should have been

classified as at least Level 2. The team also observed that some actions on the

Condition Reports for the incompleto Generic Letter issues had been inappropriately

coded as ' Deferred' until after plant restart.

The team reviewed NU actions c7 four issues related to two NRC Significant items List

-(SIL) items (SIL ltems 41 and 73), and has recommended that all four be closed. These

four issues include: ACR-7007 issues relevant to Unit 3; trending of NCRs; the Technical

Specification audit program; and the adequacy of the Nuclear Oversight Program. The

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closure of these issues also results in the final closure of SIL items 41 and 73.

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The NRC's overall assessment of the effectiveness of your corrective action program will

be based on the results of this inspection, as well as additional evaluations such as the

ongoing inspection of ICAVP corrective actions, the NRC's review of the Employee

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Concerns Program, and the upcoming Operational Safety Team Inspection (OSTI).

The SPO staff willinclude these findings within NRC Inspection Report 50-245/97-82,

which will provide the final observations, findings, and any enforcement actions to which

you will be required to respond based on the results of the subject inspection. No

response to the issues discussed in this letter are required at this time; however, any

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potential enforcement items which warrant prompt corrective actions should be addressed

in a timely manner rather than waiting for the final report.

Should you have any questions or comments regarding the issues discussed in this letter,

please contact me at (610) 337-5126.

Sincerely,

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ORIGINAL SIG ED BY

Wayne D. Lanning

Deputy Director of Inspections

Special Projects Office

Office of Nuclear Reactor Regulation

Docket No. 50-423

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M. L. Bowling

cc:

B. Kenyon, President and Chief Executive Officer

M. H. Brothers, Vice President - Operations

J. McElwain, Unit 1 Recovery Officer

J. Streeter, Recovery Officer Nuclear Oversight

G. D. Hicks, Unit Director - Millstone Unit 3

J. A. Price, Unit Director - Millstone Unit 2

D. Amerine, Vice President for Engineering and Support Services

P. D. Hinnenkamp, Director, Unit 1 Operations

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F. C. Rothen, Vice President, Work Services

J. Cantrell, Director - Nuclear Training

S.-J. Sherman, Audits and Evaluation

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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M. L. Bowling

Distribution w/ encl:

Region i Docket Room (with .c_gny of concurrences)

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Nuclear Safety Information Center (NSIC)

PUBLIC

FILE CENTER, NRR (with Oriainal concurrences)

SPO Secretarial File, Region i

NRC Resident inspector

B. Jones, PIMB/ DISP

W. Lanning, Deputy Director of Inspections, SPO, RI

D. Screncl, PAO

W. Travers, Director, SPO, NRR

Distribution w/enci (VIA E-MAIL):

J. Andersen, PM, SPO, NRR

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M. Callahan, OCA

R. Correia, NRR

B. McCabe, OEDO

S. Dembek, PM, SPO, NRR

G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR

D. Mcdonald, PM, SPO, NRR

P. McKee, Deputy Director of Licensing, SPO, NRR

S. Reynolds, Chief, ICAVP Oversight, SPO, NRR

D. Screnci, PAO

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Inspection Program Branch (IPAS)

DOCUMENT NAME: G:tempfile\\405quc2.410

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