ML20154F599

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-423/98-82 Issue on 980611

ML20154F599
Person / Time
Site:	Millstone
Issue date:	10/01/1998
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO.
References
50-423-98-82, NUDOCS 9810090276
Download: ML20154F599 (2)

See also: IR 05000423/1998082

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UNITED STATE 9

NUCLEAR REGULATORY COMMISSION

. t & rj REGloN I

U 0, 475 ALLENDALE ROAD

KING oF PRusslA, PENNSYLVANIA 19406 1415

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October 1, 1998

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! Mr. M. _ L. Bowling, Recovery Officer - Technical Services

j c/o Ms. P. A. Loftus, Director - Regulatory

Affairs for Millstone Station

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NORTHEAST NUCLEAR ENERGY COMPANY

PO Box 128

,

Waterford, CT 06385

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SUBJECT: NRC INSPECTION NO. 50-423/97-82- REPLY l

i Dear Mr. Bowling:

This letter refers to your July 15,1998 correspondence, in response to our June 11, )

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.  !

Your cooperation with us is appreciated.

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Sincerely,

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Jacque P. Durr, Chief

Inspections Branch

Millstone inspection Directorate  ;

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

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cc:

B. Kenyon, President and Chief Executive Officer - Nuclear Group

M. H. Brothers, Vice President - Operations l

J. McElwain, Recovery Officer - Millstone Unit 2

J. Streeter, Recovery Officer - Nuclear Oversight f .- .. nb U ;+ l

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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 Assessment Group

F. C. Rothen, Vice President, Work Services j

J. Cantrell, Director - Nuclear Training (CT)

S. J. Sherman, Audits and Evaluation l

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98100902/6 981001

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Mr. M. L. Bowling 2

cc,w/ cv of Licensee Resoonce Ltr:

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. Concennon

E. Woollacott, Co-Chairman, NEAC

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Mr. M. L. Bowling 2

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l cc w/ cv of Licensee Resoonse Ltr:

l L. M. Cuoco, Esquire

J. R. Egan, Esquire

V. Juliano, Waterford Library

J. Buckingharn, Department of Public Utility Control

S. B. Comley, We The People

State of Connecticut SLO Designee

D. Katz, Citizens Awareness Network (CAN)

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R. Bassilakis, CAN

J. M. Block, Attorney, CAN

, S. P. Luxton, Citizens Regulatory Commission (CRC)

l Representative T. Concannon

E. Woollacott, Co-Chairman, NEAC

Distribution w/cv of Licensee Resoonse L"n

Region i Docket Room (with coov of concurrences)

Nuclear Safety Information Center (NSIC}

PUBLIC -

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' [%iNhkN. EMTE' retan11fSec%f; j@Ptte? Region I

eel 6555Efich'Diiiictorate

l NRC Resident inspector

H. Miller, Regional Administrator, R1

B. Jones, PIMB/ DISP

W. Lanning, Director, Millstone inspectiol Directorate, R1

D. Screnci, PAO

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" P* '*"7 "dd" "'* '50' *d"a. m 6383

Northeast .

Nuclear Energy wiii.too, sociear Power station

Northeast Nuclear Energy Corupany

P.O. Box 128

Waterford ar 06385-0128

(860) 447 1791

fas (860) 444 4277

%c N. rtheast litilitics System

Docket No. 50 423

B17225

July 15,1998

U.S. Nuclear Regulatory Commission

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Attention: Document Control Desk

Washington, DC 20555

Millstone Nuclear Power Station, Unit No. 3

NRC 40500 Inspection Report No. 50-423/97-82

Repiv to a Notice of Violation

By letter dated June 11, 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) activities were

not in compliance with Nuclear Regulatory Commission regulations. NNECO

recognizes that the Corrective Action Program is still maturing and requires continued

management attention to sustain continuous improvements.

Attachment 1 provides a summary of NNECO's commitments contained in this

submittal. Attachment 2 provides NNECO's response to the Notice of Violation items.  !

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Should you have any questions regarding the information contained herein, please l

contact Mr. David A. Smith at (860) 437-5840.

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Ver/ truly yours, l;

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NORTHEAST NUCLEAP ENERGY COMPANY

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Martin L. Bowling, Jr. j i

Recovey Officer - Technical Services

Attachments (2)

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cc: H. J. Miller, Region I Administrator ,  !

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. 3 1

W. D. Travers, Ph.D., Director, Special Projects Office 1

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Docket No. 50-423 ^

B17225

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Attachment 1

Millstone Nuclear Power Station, Unit No. 3

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NRC 40500 Inspection Report No. 50-423/97-82

Summary of Cenmitments

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U.S. Nuclear Regulatory Commission

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B17225%ttachment 1\Page 1

List of Regulatory Commitments

The following table identifies those actions committed to by NNECO in this document.

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.

Description Committed Date

Commitment

or Outage

Number

Chemistry Procedure SP 3851, " BAST /RWST Complete

B17225-1

Boron Concentration" has been revised to direct

Chemistry technicians to obtain boron samples

frorn the discharge side of the pump at the

instmmentation root block valve.

A special procedure (SPROC EN98-3-07) was Complete

B17225-2

implemented to demonstrate the effectiveness

of the changes in the preclusion of air being

entrained into the system during the batching

process. This was successfully completed and

appropriate modifications have been

incorporated into Operating Procedure (OP)

3304C.

B17225-3 OP 3260E will be revised to clarify the July 27,1998

requirements for closecut of Operator

Workarounds.

OP 3260E will be revised to require that July 27,1998

B17225-4

Operator Workarounds will result in the initiation

of a Condition RP aort in accordance with RP 4,

" Corrective Actia Program"

B17225-5 Initiate a Condition Report for each existing July 24,1998

Operator Workaround.

NOQP 3.04 has been revised to identify the Complete

B17225-6

requirement that the procedure requires SORC

review.

NOOP 1.02, " Nuclear Oversight Department Complete

B17225-7

and Quality Program implementing Procedures"

has been revised to include performing a review

of new procedures e scope changes for

existing procedures to determine if SORC

review is required.

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U.S. Nuclear Regulatory Commission

. B17225\ Attachment 1\Page 2

Commitment Description Committed Date 1

Number or Outage l

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B17225-8 Procedure OA 10 " Millstone Station Complete

Maintenance Rule Program" was revised to add

the requirement for the Maintenance Rule

Group to notify the owner of the DBS when

there is a change to the Group 1 and Group 2

lists.

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B17225-9 NNECO has determined that thirteen MP3 February 28,1999 ,

systems, or portions of systems, associated with . I

Maintenance Rule Group 1 and Group 2

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systems do not have DBSs. Among these I

thirteen systems are Emergency Lighting and l

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portions of the Chemical and Volume and

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Control System. DBSs will be developed for ,

i these systems. I

i B1722510 The Design Control Manual (DCM) will be September 30,1998 1

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revised to incorporste U3 Pl 29 to transfer the

j development and maintenance of DBSs from

j Configuration Management Program (CMP) l

l activities to the permanent design process. This  ;

revision will include clarification and procedural  !

j requirements for work practices concerning

Maintenance Rule Group 1 and 2 systems  ;

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without DBSs. This revision will include I

i guidance on actions required in the interim  ;

period between when a new or revised DBS is '

required and when it is finally issued.  !

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B17225-11 The Design Control Manual (DCM) has been Complete 4

i revised to incorporate instructions on updating l

j and handling the SFR Manual. I

B17225-12 Perform coaching for Nuclear Engineering August 31,1998

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personnel, including management, to

communicate the expectations for procedural l

compliance per DC-4, processing of DBDP - l

SFR Manuals per NGP 5.28, processing of the

SFR Manual per DCM Chapter 12, and the use

of the DCM in general. l

B17225-13 Perform a sample review of Nuclear December 1,1998 i

Engineering design change products issued

after June 30,1997 to verify that they have

been administratively processed and controlled .

in accordance with appropriate procedures. I

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U.S. Nuclear Regulatory Commission

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B17225%ttachment 1\Page 3

Commitment Description Committed Date

Number or Outage 1

817225-14 On December 18,1997, NNECO implemented a Complete ,

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new station procedure RAC 13, " Organizational

Changes." This procedure describes the

process'to evaluate and implement

organizational changes to ensure changes are

made in compliance with all regulatory

requirements. The use of this procedure will

avoid implementing organizational changes that

are contrary to the Licensing Basis.

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Docket No. 50-423

B17225

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Attac' nent 2

Millstone Nuclear Power Station, Unit No. 3

NRC 40500 inspection Report No. 50-423/97-82

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Response to a Notice of Violation

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July 1998

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U.S. Nuclear Regulatory Commission

B1705\ Attachment 2\Page 1 ,

Nuclear Reaulatory Cpmmission Violation "A.1" (50 423/97-82-06)

Restatement of the Violation

Criterion XVI of 10 CFR 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 nonmnformances are

promptly identified and corrected. For significant conditions aaveise to quality,

measures shall assure that the cause of the condition is determined and corrective

action taken to preclude repetition.

Contrary to the above, between 1992 and 1998, appropriate corrective actions were not

taken to prevent a recurring air binding problem for the boric acid transfer pumps. T'ie

boric acid transfer pumps are part of Technical Specification required reactivity control

systems and provide a boron injection flow path to the Reactor Coolant System. There

has been a chronic air binding problem with the pumps that periodically rendered the

, sub-system inoperable. The condition had been identified six times, but had not been

corrected.

NNECO's Response

NNECO agrees with this violation.

Reason for the Violation

Root cause investigations were not procedurally required to be completed for events

prior to 1997 and, therefore, were not consistently performed. Condition Report (CR)

M3-98-0975 was initiated to re-evaluate the initial root cause investigation performed ,

! under CR M3-97-0954. This subsequent investigation was more detailed, and involved

! testing to confirm the sources of air into the Boric Acid piping (SPROC EN98-3-07).

l The final root cause investigation determined that the air binding of the Boric Acid

transfer pumps was due to an inadequate initial design of the Boric Acid system piping

configuration which allowed air to be introduced during the Boric Acid batching

process. This design inadequacy was compensuted for by procedural and work

practice barriers which were ineffective in preventing air intrusion into the system.

This violaO.' was addressed by NNECO in Millstone Unit No. 3 Licensee Event Report

(LER) 98416-11, dated May 18,1998. (Reference NNECO letter to USNRC, B17173).

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U.S. Nuclear Regulatory Commission

B17225%ttachment 2\Page 2

.Qorrective Actions That Have Been Taken and Results Achieved

Vent valves have been installed in the gravity boration piping to preclude a build up of

air / gas in the system followinD maintenance activities.

' Chemistry Procedure SP 3851, " BAST /RWST Boron Concentration" has been revised

to direct Chemistry technicians to obtain boron aan pies from the discharge side of the

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pump at the instrumentation root block valve.

A briefing sheet was provided to Unit 3 Operations, Maintenance and Chemistry

. personnel to communicate the findings of the root cause investigation. I

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A special procedure (SPROC EN98-3-07) was implemented to demonstrate the

, effactiveness of the changes in the preclusion of air being entrained into the system

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during the batching process. This was successfully completed and appropriate j

modifications' have been incorporated into Operating Procedure (OP) 3304C. The i

, revision to OP 3304C has reduced the potential to entrain air in the boric acid piping

during the batching process. In addition, OP 3304C directs operators to start the

transfer pump on mini-flow recirculation, and to flush any gas bubbles that may have

becorr:s entrained out of the system.

Root cause evaluations are required to be performed on significant conditions adverse

to quality in accordance with the RP 4, " Corrective Action Program." RP 6, " Root

Cause Analysis," provides guidance on the performance of root cause analysis.

Cc:Tective Actions That Will Be Taken to Avoid Further Violations

No further corrective actions will be taken.

Date When Full Compliance Will Be Achieved

NNECO is in full compliance.

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U.S. Nuclear Regulatory Commission

B17225\ Attachment 2\Page 3 ,

Nuclear Reaulatory Commission Violation "A.2" (50-423/97-82-08)

Restatement of the Violation

Criterion XVI of 10 CFR 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, appropriate corrective actions were not completed prior to

closing an automated work order (AWO) associated with a modification to correct flow

indication anomalies on service water instrumentation. Specifically, final setpoint

calibrations for flow indicators 3SWP-FI-059 A, B and C had not been accomplished

, prior to closing the AWO.

NNECO's Response

NNECO agrees with the violation.

Reason for the Violation

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NNECO has reviewed the Automated Work Orders (MNO) associated with the

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modification to correct flow anomalies in the service water inst'umentation and has

determined that the wcrk orders were closed in accordance with program implementing

procedures. However, NNECO agrees that the Operator Workaround (OWA)96-603,

associated with this modification was not closed in accordance with the program

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l impismenting procedures. At the time of occurrence, the Operator Workaround

process was not included in the Corrective Action Program (RP 4).

The inappropriate closure of Operator Workaround 96 003 was caused by human error

through procedural non-compliance due to a lack of ki owledge of requirements and

insufficient procedural guidance. The Unit Supervisor directed the Shift Technician to

close Operator Workaround (OWA)96-003 without the proper procedural steps of

Operating Procedure (OP) 3260E being performed.

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U.S. Nucl:ar Regulatory Commission

. B17225\ Attachment 2\Page 4

Corrective Actions That Have Been Taken and Results Achieved

Operator Work Around 96-003 was reinstated and then closed on April 4,1998, in

accordance with program implementing procedure OP 3260E.

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A briefing sheet was provided to the Unit 3 Operations department personnel, including

the Unit Supervisor, to provide clearer direction on closure of OWAs in reference to l

OP 3260E. I

Corrective Actions That Will Be Taken to Avoid Further Violations

OP 3260E will be revised to clarify the requirements for closeout of Operator

Workarounds. This will be completed by July 27,1998.

OP 3260E will be revised to require that all Operator Workarounds will result in the

, initiation of a Condition Repurt in accordance with RP 4, " Corrective Action Program".

This will be completed by July 27,1998.

Initiate a Condition Report for each existing Operator Workaround. This will be

completed by July 24,1998.

Date When Full Compliance will be Achieved

Full compliance has been achieved.

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U.S. Nuclear Regulatory Commission

B17225\ Attachment 2\Page 5 ,

Nuclear Reaulatory Commission Violation "B" (50-423/97-82-05)

Restatement of the Violation

Technical Specifications 6.2.3.1 and 6.5.2.6 require the Site Operations Review

Committee (SORC) to review independent Safety Engineering Group (ISEG)

procedures.

Contrary to the above, some ISEG procedures were not reviewed by the SORC. For

example, on November 11,1997, Condition Report M3-97-3974 documented an audit

finding that NOQP 3.04, Nuclear Safety Engineering Group Functions and

Responsibilities - ISEG and OE Assessment, had not been reviewed by the SORC.

NNECO's Response

. NNECO agrees with the violation.

Reason for the Violation

A decision was made (human error), during the revision of ISEG procedures in 1997, to

obtain SORC review of NSE-1 to be in compliance with Technical Specifications 6.2.3.1

and 6.5.2.6. This was a new site procedure for the Operating Experience Program. It

was not recognized, at the time, that approval of NSE-1 only partially covered the

functions requiring SORC review, and that NOQP 3.04 still included some functions of

ISEG that required SORC review per Technical Specification requirements.

Corrective Actions That Have Been Taken and Results Achieved

NOOP 3.04, Revision 2, " Nuclear Safety Engineering Group Functions and

Responsibilities-ISEG and OE Assessment", was reviewed and approved by SORC on

March 25,1998.

As a result of several Technical Specification Section 6 deficiencies being identified,

Level 1 Condition Report, M3-97-4644, was generated. As a result of the root cause

investigation, an assessment of compliance to Section 6 of the Technical Specifications

was performed. This assessment, ESAR 3CMT-98-001 identified other procedures

requiring SORC cpproval. Corrective actions have been completed to address the

deficiencies. .

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, B17225%ttachment 2\Page 6

NOOP 3.04 has been revised to identify the requirement that the procedure requires

SORC revia >w.

NOOP 1.02, " Nuclear Oversight Department and Quality Program implementing

Procedures" has been revised to include performing a review of new procedures or

scope changes for existing procedures to determine if SORC review is required.

Corrective Actions That Will Be Taken to Avc,' ? further Violations

No further corrective actions will be taken.

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Date When Full ComDliance Will Be Achieved

NNECO is in full ceinpliance.

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B17225\ Attachment 2\Page 7 .,

Nuclear Reaulaten/ commission Violation "C.1.A" (50 423/97-82-10)

Restatement of the Violation

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Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality

be prescribed by instructions or procedures of a type appropriate to the circumstances.

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Further, it requires that these activities be accomplished in accordance with these

instructions or proco.'1res.

Contrary to the above, written procedures for design bases documents were not

adhered to in the following instances:

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PI 29, Development of Millstone Unit 3 Design Bases Summary Documents, requires

. Design Basis Summaries (DBS) for Maintenance Rule (MR) Group 1 and 2 systems,

However, in the surc.:aer of 1997 when the Emergency Lighting System was moved

from MR Group 3 to 2, a DBS was not developed. Additionally the Chemical and

, Volume Control System, a MR Group 1/2 system, was not completely included in a

DBS.

NNECO's Respon_se

NNECO agrees with the violation.

Reason for the Violation

The root cause investigation concluded that the reason for the violation was human

error, specifically classified as " Inadequate Work Practice". Although the owner of the

Design Base? Summaries (DBSs) was aware of the MR Group 2 systems that did not

have DBSs, tne owner's interpretation of U3 PI 29 was that these systems could be

completed at a later date.

DBS developmant was a defined scope, one time project, that processed a large

volume of data under an cqgressive schedule. The U3 PI 29 procedure was

inadequate in that there was vagueness in the procedure that allowed interpretation.

Specifically, there was an attachment to the procedure that defined the scope of the

project that conflicted with the guidance in the body of the procedure. There was

inadequate feedback to revise the procedure to account for this gap. This was

evidenced by not updating the attachment to include the new scope of MR Group 2

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. B17225\ Attachment 2\Page 8

Corrective Actions That Have Been Taken and Results Achieved

Procedure OA 10 " Millstone Station Maintenance Rule Program" was revised to add the l

requirement for the Maintenance Ruta Group to notify the owner of the DBS when there  !

is a chan0e to the Group 1 and Group 2 lists.

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Corrective Actions That Will Be Taken to Avoid Further Violations

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NNECO has determined that thirteen MP3 systems, or portions of systems associated

with Maintenance Rule Group 1 and Group 2 systems, do not have DBSs. Among

these thirteen systems are Emergency Lighting and portions of the Chemical and j

Volume and Control System. DBSs for the thirteen systems will be developed. This

will be completed by February 28,1999.

The Design Control Manual (DCM) will be revised to incorporate U3 PI 29 to transfer

the development and maintenance of DBSs from Configuration Management Program

, (CMP) activities to the permanent design process. This revision will include i

clarification and procedural requirements for work practices conceming Maintenance

Rule Group 1 and 2 systems without DBSs. This revision will include guidance on

actions required in the interim period between when a new or revised DBS is required

and when it is finally issued. This wili be completed by September 30,1998.

Date When Full Compliance Will Be Achieved

NNECO will be in compliance upon the revisicn to the DCM that provides guidance for

actions required from the time it is determirad that a DBS is required and currently

does not exist 3 the DBS is finalized. This will be completed by September 30,

1998. This schedule is acceptable based on the fact that the DBS is not in itself a

source of design basis information. This tool serves as a " Road Map" to aid the

engineer to Leating information. This information is readily available through other

means which the engineer can review for design changes.

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B17225%ttachment 2\Page 9 ,

Nuclear Raoulatory Comm!ssion Violation "C.1.B" (50 423/97-82-10)

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Restatement of the Violation

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Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality

be prescribed by instructions or procedures of a type appropriate to the circumstances.

Further, it requires that these activities be accomplished in accordance with these

instructions or procedures.

Contrary to the above, written procedures for design bases documents were not

adhered to in the following instance: NGP S.28, Design Basis Documentation

Packages, Rev 3,10/15/97, Step 1.1.2, requires documenting changes to the Safety

Functional Requirements (SFR) Manual as Design Change Notices (DCN) and then

entering the DCN numbers into the Generation Records information and Tracking

System (GRITS). As of February 1998, two revisions to the SFR Manual were issued

without issuing DCNs or updating the GRITS.

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NNECO's Response

NNECO agrees with the violation.

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Reason for the Violation

A root cause investigation concluded the reason for the violation was human error,

specifically classified as " inadequate Written Communication". An Engineering Record

Correspondence (ERC) with the SFR Manual attached was sent to Design Engineering

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and Nuclear Document Services (NDS) with no specific instructions other than stating a

i DCN was required to update GRITS in accordance with NGP 5.28. This was

l inadequate to convay the message that an additional task was also required to revise

l the SFR Manua!. The ERC stipulated that it was processed in accordance with NGP

j. 5.31, " Engineering Rtcord Correspondence and Technical Specifications," and made

no reference to NGP 5.28. As a result, Design Engineering assumed the task was

completed and distributed for use without having the latest revision number posted in

GRITS. .

Corrective Actions That Have Been Taken and Results Achieved:.

The Design Control Manual (DCM) has been revised to incorporate instructions on *

updating and handling the SFR Manual.

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U.S. Nuclear Regulatory Commission  !

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B17225\ Attachment 2\Page 10

GRITS has been updated to reflect the current revision of the SFR Manual per DCM

Chapter 12. <

Corrective Actions That Will Be Taken to Avoid Further Violations:

Perform coaching for Nuclear Engineering personnel, including management, to

communicate the expectations for procedural compliance per DC-4, processing of

DBDP - SFR Manuals per NGP 5.28, processing of the SFR Manual per DCM Chapter

12, and the use of the DCM in general. This item will be completed by August 31,

1998.

Perform a sample review of Nuclear Engine 4 ling design change products issued after

June 30,1997 to verify that they have been administratively processed and controlled

in accordance with appropriate procedures. This item will be completed by

December 1,1998.

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' Date When Full Compliance Will Be Achieved

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NNECO is in full compliance.

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B17225\ Attachment 2\Page 11 ,

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Nuclear Reaulatory Commission Viciation "C.2" (50-423/97-82-07)

Restatement of the Violation

Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality

be prescribed by instructions or procedures of a type appropriate to the circumstances.

Further, it requires that these activities be accomplished in accordance with these

instructions or procedures.

RP4, Rev 5, Attachment 3, Condition Report (CR) Initiation and Classification

Guidelines, includes in the Level 2 guidelines, an extemal station commitment not

adhered to: or a deficiency in materiai that, if left uncorrected, could affect t,afe reliable

plant operation.

Contrary to the above, in 1997, CR M3-97-4672, which is related to an extemal station

commitment not adhered to (NRC Generic Letter GL 89-13), and CR M3-97 4346,

' which is related to a material deficiency that, if left uncorrected, could affect safe

reliable plant cperation (inadequate corrosion control), were inappropriately classified

as Level 3 CRs.

NNECO's Response

NNECO agrees with the violation.

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Reason for the Violation

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CR M3-97-4346 and M3-97-4672 were each categorized improperly as significance

level 3 CRs, due to a failure to recognize that external commitments were involved and

had not been adhered to. The Unit 3 Management Review Team (MRT) assigned a

level 3 to these CRs, based on the initiator's description of the events. The connection

to a regulatory commitment for GL 89-13 was not made apparent in either Condition

Report. A root cause determined that the cauce of this was human error resulting from

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a lack of sufficient procedural guidance.

Corrective Actions That Have Been Taken and Results Achieved

CRs M3-97-4346 and M3-97-4672 were upgraded to level 2 significance on March 9, *

1998.

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U.S. Nucl=r Regul: tory Commission

B17225\ Attachment 2\Page 12

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NRC commitments associated with GL 89-13 were reviewed to determine if deferral

dispositions were appropriate and if any reporting to the NRC was required. It was ,

determined that no regulatory commitments were missed. This review verified the

dispositions and determined that no further reporting was necessary.

RP 4, " Corrective Action Program", was revised to clarify the conditions which warrant a

level 2 or level 3 significance, to include guidance on upcreding a hvel 3 CR if an '

adverse condition is identified during the investigation of the CR, and to have

Regulatory Affairs and Compliance department involved in tin dispositioning of items

that may impact the Licensing or Design Basis of the unit, and requlatory commitments.

Corrective Actions That Will Be Taken to Avoid Further Violations

No further actions are required.

Date When Full Compliance will be Achieved

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NNECO is in full compliance.

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U.S. Nuclur Regulttory Commission

B17225%ttachment 2\Page 13 ,

Nuclear 3eaulatory Commission Violation "D" (50-423/97-82-02)

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Restatement of the Violation

Technical Specification 6.2.1.d requires, in part, that those who carry out health physics

functions have sufficient organizational freedom to ensure their independence from

operating pressures.

Contrary to the above, the Radiation Protection Manager reports to the Maintenance

Manager, which does not ensure independence from operating pressures. Also,

Regulatory Guide 8.8, Section C.1.b(3), states in part, that: The Radiation Protection

Manager (RPM) (onsite) has a safety function and responsibility to both employees and

management that can best be fulfilled if the individual is independent of station

divisions, such as operations, maintenance, or technical support, whose prime

responsibility is continuity or improvement of station operability.

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NNECO's Respont,e

CO agrees with the violation.

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Reason for the Violation

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Technical Specification 6.2.id requires the following:

"The individuals who train the operating staff and those who carry out health

physics and quality assurance functions may report to the appropriate onsite

manager; however, they shall have sufficient organizational freedom to ensure

their independence from operating pressures."

Regulatory Guide 8.8, Section C.1.b(3), states in part, that:

"The Radiation Protection Manager (RPM) (onsite) has a safety function and

responsibility to both employees and management that can best be fulfilled if the

individual is independent of station divisions, such as operations, maintenance,

or technical support, whose prime responsibility is continuity or improvement of

station operability."

The violation occurred because an inadequate review of the Licensing Basis for the *

, reporting requirements was performed and procedural requirements to evaluate

organizational changes were not formalized. In addition, Technical Specification

verbiage does not specifically state which onsite manager is appropriate. At the time of

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U.S. Nuclarr Regulttory Commission

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B17225\ Attachment 2\Page 14

the NRC inspection, the Millstone Unit No. 3 Radiation Protection Manager carried out -

the health physics function while reporting to the Millstone Unit No. 3 Maintenance

Manager. NNECO believed that this arrangement was in concert with the Technical

Specifications. However, it was not in concert with Regulatory Guide 8.8, Section

C.1.b(3). It is important to note that radiological decisions were made by the Radiation

Protection Manager and not by the Maintenance Manager.

Corrective Actions That Have Been Taken and Results Achieved

NNECO re-assigned the Unit 3 Radiation Protection Manager to report to the Unit

Director. This action was completed on March 12,1998.

Corrective Actions That Will Be Taken to Avoid Further Violations

On December 18, 1997, NNECO implemented a new station procedure RAC 13,

" Organizational Changes." This procedure describes the process to evaluate and

implement organizational changes to ensure changes are made in compliance with all

regulatory requirements. The use of this procedure will avoid implementing

organizational changes that are contrary to the Licensing Basis.

Date When Full Compliance Will Be Achieved

NNECO is in full compliance.

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