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{{Adams | |||
| number = ML20151P168 | |||
| issue date = 11/04/1985 | |||
| title = SALP Rept 50-423/85-99 for Sept 1984 - Aug 1985 | |||
| author name = | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000423 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-423-85-99, NUDOCS 8601030319 | |||
| package number = ML20151P154 | |||
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 48 | |||
}} | |||
See also: [[see also::IR 05000423/1985099]] | |||
=Text= | |||
{{#Wiki_filter:__ | |||
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-U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE | |||
INSPECTION REPORT 50-423/85-99 | |||
- | |||
NORTHEAST NUCLEAR ENERGY COMPANY (NNECo) | |||
MILLSTONE NUCLEAR POWER STATION, UNIT 3 | |||
ASSESSMENT PERIOD: SEPTEMBER 1, 1984 - AUGUST 31, 1985 | |||
BOARD MEETING DATE: NOVEMBER 4, 1985 | |||
8601030319 851227'' | |||
gDR ADOCM 0 3' | |||
p V | |||
TABLE OF CONTENTS | |||
PAGE | |||
I. INTRODUCTION.......................................................... 1 | |||
A. Purpose and 0verview.....................'........................ 1 | |||
B. SALP Review Board and Attendees.................................. 1 | |||
C. Background....................................................... 1 | |||
II. CRITERIA.............................................................. 4 | |||
.III. SUMMARY OF RESULTS.................................................... 5 | |||
IV. PERFORMANCE ANALYSIS...... ............................... ........... 7 | |||
A. Operations Support............................................... 7 | |||
B. Radiological Controls............................................ 10 | |||
~C. Maintenance............................. ......... .............. 12 | |||
D. Surveillance............ ........................................ 14 | |||
E. Preoperational Testing........................................... 16 | |||
F. Fire Protection and Housekeeping................................. 19 | |||
G. Emergency Preparedness........................................... 21 | |||
H. Security......................................................... 22 | |||
I. Construction..................................................... 24 | |||
J. -Licensing Activities.... ........................................ 28 | |||
V. SUPPORTING DATA AND SUMMARIES......................................... 30 | |||
A. Construction Deficiency Reports.. ............................... 30 | |||
B. Investigation Activities......................................... 30 | |||
C. Escalated Enforcement Actions.................................... 30 | |||
0. Management Meetings.............................................. 30 | |||
TABLES | |||
. TABLE 1 - Construction Deficiency Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 | |||
TABLE 2 - Inspection-Hours Summary......................................... 4 | |||
TABLE 3 - Inspector Activities (Tabulation of Inspection Reports).......... 5 | |||
TABLE 4 - Enforcement Data................................................. 13 | |||
' | |||
f ' | |||
I. INTRODUCTION | |||
A. Purpose and Overview | |||
The Systematic Assessment of Licensee Performance (SALP) is an | |||
integrated NRC staff effort to periodically collect observations | |||
and evaluate licensee performance. SALP objectives are to improve | |||
the NRC Regulatory Program and licensee performance. | |||
This SALP differs substantially in emphasis from previous Millstone 3 | |||
SALPs. Most construction activities are now combined into one | |||
functional area. Functional areas were added to address aspects | |||
related to future plant operations. The puroose was to focus this | |||
one year SALP (9/1/84 - 8/31/85) heavily on operational readiness and | |||
operational performance, with post-SALP period observations included | |||
where pertinent. | |||
The SALP evaluation criteria are discussed in Section II and were | |||
applied using the " Attributes for Assessment of Licensee Performance" | |||
of NRC Manual Chapter 0516. | |||
B. SALP Review Board and Attendees | |||
SALP Review Board Members | |||
R. Starostecki, Director, Division of Reactor Projects (DRP), Chairman | |||
S. Ebneter, Director, Division of Reactor Safety (DRS) | |||
E. Wenzinger, Chief, Projects Branch No. 3, DRP | |||
L. Bettenhausen, Chief, Operations Branch, DRS | |||
R. Bellamy, Chief, Emergency Preparedness and Rad.ation Protection | |||
Branch, Division of Radiation Safety and Safeguards (DRSS) | |||
E. McCabe, Chief, Reactor Projects Section 3B, DRP | |||
T. Rebelowski, Senior Resident Inspector, Millstone 3 | |||
E. Doolittle, Licensing Project Manager, NRR | |||
Other Attendees | |||
K. Ferlic, Project Engineer, DRP | |||
R. Summers, Project Engineer, DRP | |||
- | |||
. C. Background | |||
- | |||
1. Licensee Activities | |||
During this SALP period, the thrust of activities shifted from | |||
construction towards preoperational activities. One hundred | |||
nine systems were " turned over" from construction to operations | |||
t i | |||
'2 | |||
for test performance, and 237 of the 238 systems had been turned | |||
over by the end of the SALP period. Also, eight major mile- | |||
stones were completed (plant on permanent power, Reactor Coolant | |||
System hydrostatic test, Steam Generator hydrostatic test, fuel | |||
receipt, emergency drill, Containment Structural Integrity and | |||
Integrated Leak Rate Test, Turbine Building Hot Functional Test | |||
to the capacity of the boiler, and Engineered Safety Features | |||
Tests). The craft staffing decreased from approximately 3200 to | |||
about 1400. | |||
The licensee considered Millstone 3 to be approximately 98% | |||
complete as compared with 88'; at the end of the previous SALP | |||
period. (No NRC estimate of completion status was made.) | |||
Northeast Utilities' current estimate for fuel loading is | |||
November 1985. The Integrated Hot Functional Testing which is | |||
scheduled for September / October 1985 is critical to achieving | |||
this date. Equally important is generation and implementation | |||
of plant procedures and qualification of the operating staff. | |||
After the SALP period, the integrated hot functional test (IHFT) | |||
was begun on September 27. | |||
2. Inspection Activities | |||
One NRC Senior Resident Inspector was assigned throughout the | |||
SALP period. Resident Inspector assistance was provided by the | |||
Millstone 1/2 Resident Inspector until a full time Resident | |||
Inspector was assigned to Millstone 3 in August 1985. Team | |||
inspections were conducted by a Headquarters Construction | |||
Assessment Team (CAT), a Technical Specifications Review Team, | |||
an NDE Independent Measurements Team, a Fire Protection Team | |||
(including safe shutdown capability), an allegations Review | |||
Team,and an as-built review team (at the end of the assess- | |||
ment period). There was also an Environmental Qualification | |||
inspection and numerous NRR visits to evaluate SER concerns. | |||
The NRC inspection effort during the period totalled 7723 hours: | |||
5523 hours were by resident and region-based inspectors; and | |||
2200 hours were for the CAT inspection. The distribution of | |||
inspection hours is shown in Table 2. Inspection activities and | |||
enforcement data are summarized in Tables 3 and 4, respectively. | |||
Quality assurance was an integral element of all inspections | |||
performed during the assessment period. In addition, two | |||
inspections were devoted specifically to the QA/QC program. | |||
; | |||
: | |||
l | |||
l | |||
i | |||
3 | |||
l | |||
3. Other Activities | |||
On September 10, 1984 the ACRS reported to the NRC Chairman | |||
that, subject to resolution of open NRC items and to the | |||
satisfactory completion of construction, staffing, and | |||
preoperational testing, the ACRS believes that there is | |||
reasonable assurance that Millstone 3 can be operated up to 3411 | |||
Mwt without undue risk to public health and safety. | |||
The Millstone 3 simulator is operational and has been used for | |||
the initial operator licensing process. | |||
Public officials in Waterford, Connecticut have been routinely | |||
informed of major Millstone 3 evolutions by utility officials | |||
and separately by the senior resident inspector. | |||
The Safety Evaluation Report (SER), NUREG-1031 was issued by NRR | |||
during July 1984. Supplements 1 and 2 were issued in March 1985 | |||
and September 1985. Supplement 3 was in draft form at the end | |||
of the assessment period. | |||
On March 22, 1985, the applicant established a more formal and | |||
comprehensive allegation program after discussions of the need | |||
for this with Region I. | |||
On June 5, 1985, an exemption was granted to General Design | |||
Criterion 4, allowing NNECo to forgo the installation of pipe | |||
whip restraints for primary loop piping. | |||
The 29 Construction Deficiency Reports (CDRs) for this | |||
assessment period are summarized in Table 1. Three of these | |||
have currently been determined not to be reportable by the | |||
licensee. | |||
. | |||
l I | |||
4 | |||
II. CRITERIA | |||
Licensee performance is assessed in prescribed functional areas based on | |||
whether the facility is in a construction, preoperational, or operational | |||
phase. Other areas may be added as appropriate. Each area normally repre- | |||
sents aspects significant to. nuclear safety and the environment. One or more | |||
of the following criteria were applied in each area: | |||
1. Management involvement and control in assuring quality. | |||
2. Approach to resolution of technical issues from a safety standpoint. | |||
3. Responsiveness to NRC initiatives. | |||
4. Enforcement history. | |||
5. Reporting and analysis of reportable events. | |||
6. Staffing (including management). | |||
7. Training effectiveness and qualification. | |||
Each area was classified into one of the following three categories. | |||
1 | |||
Category 1. Reduced NRC attention may be appropriate. Licensee management | |||
attention and involvement are aggressive and oriented toward nuclear safety; | |||
licensee resources are ample and effectively used so that there is a high | |||
level of performance wi+3h respect to construction and operational safety. | |||
Category 2. Normal NRCtattention should be maintained. Licensee management | |||
attention and involvemeht are evident and are concerned with nuclear safety; | |||
licensee resources are adequate and reasonably effective so that there is | |||
satisfactory performance with respect to construction and operational safety. | |||
Category 3. Both NRC and licensee attention should be increased. Licensee | |||
management attention or involvement is acceptable and considers nuclear safety, | |||
but weaknesses are evident; licensee resources appear to be strained or not | |||
effectively used so that there is minimally satisfactory performance with re- | |||
spect to construction and operational safety. | |||
The SALP Board also as~sessed each functional area to compare the licensee's | |||
performance for the last quarter of the assessment period to that during the | |||
entire SALP period in order to determine the recent trend for each functional | |||
area. The trend categories are: | |||
Improving. Licensee performance has generally improved over the last | |||
quarter of the current SALP ass.:ssment period. | |||
Y | |||
Consistent. Licessee performance has remained essentially constant over | |||
the last quarter f the current SALP assessment period. | |||
Dy: lining. Licendae performance has generally declined over the last | |||
quarter pf the current SALP assessment period. | |||
l 5 | |||
5 | |||
III. SUMMARY OF RESULTS | |||
Category Last Category This | |||
Period Period Recent | |||
Functional Area (9/1/83-8/31/84) (9/1/84-8/31/85) Trend | |||
A. Operations Support N/A 2 Consistent | |||
B. Radiological Controls N/A 2 Consistent | |||
C. Maintenance N/A 2 Consistent | |||
D. Surveillance N/A 3 Consistent | |||
E. Preoperational Testing 1 1 Consistent | |||
F. Fire Protection & Housekeeping N/A 1 Consistent | |||
G. Emergency Preparedness N/A 2 Consistent | |||
H. Security N/A 1 Consistent | |||
I. Construction 1 1 Consistent | |||
J. Licensing 2 2 Consistent | |||
Overview | |||
During this transitional period, licensee performance has generally been | |||
characterized by management involvement in facility activities, strong QA/QC | |||
presence, commitment to training, appropriate corrective action, responsive- | |||
ness to NRC concerns, and technical competence. Construction quality and | |||
preoperational testing has been good. The licensee has been effective at | |||
maintaining control over contractor activities. Construction and preopera- | |||
tional testing program development and staffing kept pace with activities | |||
and the licensee generally anticipated changes in manning requirements. | |||
Transitions to operating phase programs generally progressed smoothly, with | |||
carryover from Millstone 1.and 2 being a substantive aid in the development | |||
of Unit 3 programs. Resolution of fire protection issues was particularly | |||
well done. | |||
Problems identified included nondestructive examination inadequacies, minor | |||
flooding incidents, failures on initial operator licensing examinations, and | |||
slow development of procedures to support plant startup and operation. How- | |||
ever, it was evident that, while the construction completion schedule was very | |||
important to the applicant, safety considerations were resolved without sub- | |||
ordination of quality to schedule. | |||
I | |||
_. -. | |||
. | |||
i 5 | |||
6 | |||
This assessment has not evaluated the licensee's organization as it will exist | |||
during ascension to full power. Shift staffing and organizational changes | |||
are expected to occur as Unit 3 becomes operational. Continued management | |||
attention is needed to ensure a smooth transition. | |||
Training Overview | |||
The applicant's commitment to training has been high. As noted in the Mill- | |||
stone 1/2 SALP (9/1/83 - 2/28/85), organizational training initiatives have | |||
been notable and included an upgrading through training staff expansion in | |||
size and authority. The licensee is providing simulators for all four | |||
facilities and the Millstone 3 simulator is operational. | |||
There was a high failure rate on-the initial licensed operator examinations | |||
which can be attributed to the use of the simulator in the examination process | |||
and'some lapses in the operations / training interface. After meetings with | |||
the NRC and program revisions to resolve these lapses and increase simulator | |||
usage, significant improvement in candidate performance was noted on the | |||
second set of examinations. | |||
Overall observation of work performance in all phases of plant activities in- | |||
dicated a well trained and qualified work force. Few problems arose as a re- | |||
sult of unqualified personnel or lack of training. Review of training records | |||
to verify qualifications and receipt of training and retraining found the | |||
records were complete and met program requirements. The effectiveness of | |||
training will continue to be monitored after INP0 accreditation. | |||
Quality Assurance Programs and Controls Overview | |||
Management of Millstone-3 made an initial strong commitment to assure quality | |||
and has maintained that commitment throughout the design, procurement, con- | |||
struction, and preoperational phases. The training and knowledge of QA/QC | |||
personnel was found acceptable during all phases. Staffing was generally | |||
sufficient and adequate to conduct the QA/QC programs during the transition | |||
from construction to operations. Management involvment has been clearly | |||
evident in knowledge of QA/QC programs and their status, in onsite presence, | |||
and in emphasis on corrective actions. | |||
QA coverage for operations is to be based on acceptable programs in place at | |||
Millstone 1 and 2. QA programs for operations, surveillance, and maintenance | |||
have not been completed for Millstone 3. Their completion is dependent upon | |||
completion of the procedures governing these activities. | |||
QA violations which have occurred during this assessment period relate to the | |||
broad spectrum of~ construction and preoperational activities involved in the | |||
latter stages of facility construction. They do not indicate a breakdown in | |||
quality programs or serious individual quality problems. | |||
-- -- - | |||
- . - - __ | |||
_ _ _ _ - _ _ . __ __ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - - . | |||
c' | |||
f | |||
, 7 | |||
1 | |||
a t | |||
i | |||
i | |||
IV. PERFORMANCE ANALYSIS | |||
A. Operations Support (552 Hours, 7%) | |||
This area addresses compliance with commitments and procedural re- | |||
quirements, " turned-over" systems, reporting, staffing, engineering | |||
support, design change and modification control, operator training, | |||
and safety review committee activities. Fuel receipt, core load pre- | |||
parations, operational aspects of testing, and onsite management of | |||
j facility evolutions are also included. | |||
l This area was under routine review by resident and region-based | |||
inspectors throughout the assessment period. The analysis is based | |||
! in part on review of operations-related aspects of inspections of | |||
' | |||
other Functional Areas and therefore involves a larger inspection . | |||
4 | |||
basis than was allocated. ! | |||
; | |||
' | |||
Observation of control room activities found personnel knowledgeable | |||
of their current assigned duties and responsibilities (e.g., response | |||
to facility emergencies [ containment fire], manipulation of controls | |||
during preoperational testing, hanging and removal of tags and | |||
' | |||
jumpers). | |||
; A formal method of processing design changes and written administra- | |||
! tive controls for controlling temporary modifications, jumpers, and , | |||
; bypasses, including controls for maintaining logs, was in place | |||
, throughout the assessment period. These are the framework for con- | |||
trol during operations and were effective during testing. Improve- | |||
i ments have been made as deficiencies were found (e.g., changes to | |||
jumper controls to establish a one time, unique tag number.) How- | |||
, | |||
ever, review of recent plant incident reports found multiple' tagging | |||
problems, and administrative procedural controls should be reviewed | |||
by the licensee to assure their adequacy for operations. Similarly, | |||
licensee reviews should be performed to assure log keeping require- | |||
4 ments and shift turnover protocols provide the mcre rigorous controls | |||
needed for operation. | |||
j Although no violations were cited in the operations area, several | |||
- | |||
aspects of three flooding events which occurred are related to opera- | |||
tional controls. In a Service Building flooding event, the elapsed | |||
.. | |||
' | |||
time between the Shift Supervisor's release for test performance | |||
(signifying the plant systems had been verified and ready for test) | |||
, and the actual performance of the test was nine months with no re- | |||
' | |||
verification, and changed system status resulted in the event. In a i | |||
: flooding event in the Control Building, failure to follow pro- i' | |||
, | |||
cedural controls resulted in isolating a section of service water | |||
! pipe without emptying the pipe, which then was drained to the Control | |||
Building. In an Engineered Safety Features Building flooding event, | |||
. failure of to fol. low the automated work order tag requirements caused | |||
flooding. Corrective action was initiated for each of these events. | |||
i No similar events have occurred recently. However, operational | |||
i | |||
! | |||
, , - --- - . . .- - - _ - - , - - _ - - - - - , - _ _ _ _ _ . _ _ _ - - - - - | |||
/ I | |||
8 | |||
controls and staff training in these areas should be re-reviewed by the | |||
licensee prior to power operations to further safeguard against such | |||
occurrences. | |||
New fuel receipt occurred during the SALP period. Few problems were | |||
encountered with fuel receipt, transfer, cleaning, storage, and docu- | |||
mentation of these activities. Personnel involved were knowledgeable | |||
of their responsibilities and of program and NRC license require- | |||
ments. The licensee was cognizant of IE Information Notices concern- | |||
ing fuel handling and had incorporated the recommended actions into | |||
procedural, alarm, and interlock provisions. Personnel training was | |||
found adequate in associated areas (fire protection, health physics, | |||
security, preoperational testing). QA/QC coverage was provided. | |||
Initial cold license operator examinations were conducted during May. | |||
A second set of examinations in September immediately followed the | |||
close of the SALP period. The simulator was used during the exami- | |||
nations. The initial set of examinations resulted in an approxi- | |||
mately 50% failure rate. The failures tended to be concentrated in | |||
the simulator portion of the operating test. A meeting with the | |||
candidates who failed the test was held by hRC supervisors to both | |||
further understand what transpired and to explain how examiners ex- | |||
pect the candidates to perform for upccming tests. Some of the | |||
failures can be attributed to the fact that the simulator was very | |||
recently placed in service and a comprehensive training program in- | |||
tegrating the simulator was not in place for the candidates. Con- | |||
sequently, the candidates may not have been sufficiently familiar | |||
with both the simulator and the newly developed emergency operating | |||
procedures. Further analysis of the operator training program indi- | |||
cated that another weakness may be poor communications between the | |||
training organization and the operations department in that there was | |||
not a mutual understanding regarding operating philosophy and train- | |||
ing needs, and the technical feedback required to assure that the | |||
training desired is being achieved was lacking. An example was the | |||
confusion generated regarding the role of the shift supervisor (SS) | |||
and the supervising control room operator (SCRO) which caused some | |||
problems in examining the senior reactor operator (SR0) candidates | |||
since the two positions had divided responsibilities. The licensee | |||
didn't anticipate that the SS may in fact not be in the control room | |||
or readily available at all times and that the SCR0 may have to per- | |||
form both functions. Consequently, emphasizing the duties of the | |||
SCR0 as being a subset of SS duties resulted in confusion. This, | |||
coupled with the problems between operations and training, resulted | |||
in the high failure rate. A management meeting was held to discuss | |||
these problems and, subsequently, the examinations conducted in Sep- | |||
tember and the retake examinations given in October reflected an im- | |||
provement in training and performance on the simulator. Meetings | |||
were held between the NRC examiners and the candidates before the | |||
second set of examinations to explain scope and conduct of the test. | |||
1 | |||
- | |||
. | |||
o 8 | |||
9 | |||
, | |||
Two events near the end of the assessment period are potentially | |||
! significant. These were a condenser chloride intrusion and a diesel | |||
fuel oil spill. The chloride intrusion was caused by corrosion of | |||
bolts fastening the air reduction pipe to the condenser tube sheet. | |||
[ During the recovery, examination revealed that additional bracing was | |||
; needed. This was a major task. Management response was extremely | |||
l thorough, technically sound, and provided long term corrective action | |||
I | |||
to both corrosion and bracing problems. Inspector review found that | |||
licensee actions exceeded those required to fix the " broken part" and | |||
demonstrated an aggressive " correct the root cause" approach. The | |||
l second event was a fuel oil spill caused by over-filling the 'B' fuel | |||
l storage tank while transferring from the 'A' fuel storage tank via | |||
l the day tank. Procedural inadequacies appeared to be involved. | |||
, Licensee investigation was in progress at the end of the SALP period. | |||
! | |||
However, concern for the fuel spill did not appear to be approached | |||
with as thorough a " correct the root cause" approach as the chloride | |||
intrusion. Although the fuel spill was much less important than the | |||
' | |||
chloride intrusion, it indicates that correcting root causes could | |||
be more thoroughly ingrained in plant personnel. | |||
Conclusion | |||
Category 2, consistent. | |||
Board Recommendation | |||
l Licensee: | |||
l 1. Review control of and training for jumpers and lifted leads, | |||
l | |||
tagging, log keeping, and shift turnover requirements to assure | |||
controls are adequate for power operation. | |||
2. Assess whether formal metheds and personnel orientation on | |||
correcting root causes are sufficient. | |||
NRC: | |||
Conduct a special team inspection to assess the functional opera- | |||
tional performance of the plant operating staff during the power | |||
ascension program and/or early during operation at high power. | |||
l | |||
s | |||
, | |||
l | |||
, . | |||
8 | |||
t | |||
10 | |||
B. Radiation Control (181 Hours, 2*4) | |||
Preoperational inspections of radiological controls were initiated in | |||
th's SALP period. Programs reviewed were radiation protection, radio- | |||
active waste management, radioactive material transportation, effluent | |||
control and monitoring, and radiochemistry. These programs have been | |||
used at of Unit 1 and 2 and are being applied to Unit 3. Radiological | |||
controls for Units 1 and 2 were Category 2 for the last assessment | |||
period (9/1/83 - 2/28/85), and the programs are well established and | |||
operationally sound. | |||
Procedures for Unit 1 and 2 radiation protection are generally well | |||
stated and provide explicit directions for controlling radiological | |||
activities. All of the procedures applied to Unit 3 were subject to | |||
management review before incorporation to assure that radiological | |||
control was not over generalized. Minor examples of procedural deft- | |||
ciencies have been identified in NRC reviews but programmatic weak- | |||
ness is not indicated. However, detailed radiological controls for | |||
handling of contaminated individuals exiting the Unit 3 containment | |||
and their transfer to a decontamination area have not been established. | |||
The radiation protection program was not fully implemented for fuel | |||
receipt. Nevertheless, the licensee's fuel receipt efforts demon- | |||
strated good planning and effective procedure development. The per- | |||
sonnel involved were adequately trained and able to establish | |||
thorough and complete radiological controls. Records of this activ- | |||
ity were complete, well maintained, and available for review. | |||
Personnel who implement the radiation protection program at Unit 3 | |||
undergo the same formal training as at Units 1 and 2. Additionally, | |||
all personnel received special unit specific training in plant systems | |||
and layouts. The training program is well defined and implemented | |||
for the entire staff. | |||
The licensee's chemistry / radiochemistry program is based on proven | |||
procedures adopted from the program for the operating units. Personnel | |||
are trained and qualified. A consistently good performance has been | |||
noted in this area at Millstone 1 and 2. | |||
The radioactive waste management program, common for the site, has | |||
not yet been implemented for Unit 3. All radwaste systems have been | |||
turned over to the utility. Preoperational testing is in progress. | |||
Liquid waste, gaseous waste, and boron recovery systems remain to be | |||
tested. The test program appears technically sound and sufficient. | |||
Several operational deficiencies have been identified, but there is a | |||
concerted effort to resolve and correct them. Waste system operating | |||
and surveillance procedures h<ve not been finalized and, consequently, | |||
were not reviewed. | |||
. | |||
.. | |||
* | |||
i | |||
11 | |||
Support activities such as external dosimetry, whole body counting, | |||
maintenance and calibration of radiation instrumentation are common | |||
to the site. The respiratory protection program, although also | |||
common, has not been reviewed for how the Unit 3 subatmospheric | |||
containment and associated changes in controls, if any, will be | |||
addressed. | |||
. | |||
The Radiological Environmental Monitoring Program for the operating | |||
units will also apply to Unit 3. This program has been effectively | |||
implemented and is technically sound. Only minor discrepancies have | |||
been noted. These have received immediate attention. | |||
Immediately after the SALP period, NRC inspectors identified a | |||
radwaste program concern. The FSAR solid radwaste system description | |||
and the SER did not refect the installed system. Differences included | |||
(1) the binder system used to supplement solidification as described | |||
in the FSAR was essentially eliminated in 1983, (2) several system | |||
components have been eliminated during startup testing, and (3) | |||
the FSAR failed to describe resin dewatering by the primary waste | |||
process and how much volume could be handled. Changes to the FSAR | |||
had not been submitted. Upon identification, the applicant was quick | |||
to draft an FSAR revision. | |||
Conclusion | |||
Category 2, consistent. | |||
Board Recommendation | |||
Licensee: | |||
1. Assure the FSAR accurately describes the solid radwaste system. | |||
NRC: None | |||
- -- -- . - .. . .. . - _- | |||
. . | |||
' | |||
. | |||
12 | |||
C. Maintenance (169 Hours, 2%) | |||
Resident and region-based inspectors observed corrective and pre- | |||
' | |||
ventive maintenance and reviewed the programs for maintenance support | |||
planned for use during power operations. Pre-turnover and post- | |||
turnover maintenance activities were observed in the areas of me- | |||
chanical, electrical, and instrumentation'and control systems. The | |||
inspection effort consisted of one program inspection by a region- | |||
based inspector and review of maintenance activities during other | |||
! | |||
inspection efforts. | |||
Both the Maintenance Department (mechanical and electrical) and the | |||
Instrument and Controls (I&C) Department were fully staffed based on | |||
current manning projections. Training programs were established | |||
for I&C personnel and a comprehensive written test was given to all | |||
, | |||
I&C contract technicians prior to performance of activities (instead | |||
, | |||
of relying on vendor certification programs). Maintenance Department | |||
, | |||
training procedures were in existence at the time of the program | |||
' | |||
inspection, but the training program was still being developed. | |||
The mair.tenance organizations are established. Programs for cor- | |||
rective maintenance, preventive maintenance, and instrumentation and- | |||
control maintenance were functioning in support of pre-operational | |||
] testing and system turnovers. Procedures have been in place for ini- | |||
l tiating, approving, reviewing, and scheduling of plant and preventive | |||
maintenance for equipment protection. Administrative controls were | |||
established for preparation and retention of maintenance records. | |||
Weaknesses identified during the CAT inspection in the corrective | |||
action taken to control preventive maintenance after components had | |||
been turned ove- for testing / operations were promptly addressed by | |||
the applicant. Never, a large backlog in the generation of main- | |||
tenance, prevent e maintenance, and plant instrument calibration | |||
1 | |||
procedures existed at the end of the SALP period. | |||
Maintenance is controlled by a computerized system in use at all | |||
Northeast Utilities Companies and accessible throughout the company. | |||
This system is called the Production Maintenance Management System | |||
(PMMS). Each department has a PMMS planner trained to make entries | |||
to the system. PMMS information includes the frequency of preventive | |||
maintenance and the maintenance history files. The system can review | |||
maintenance records for generic failure implications and identify | |||
periodic replacement of plant components based on environmental qual- | |||
ification service time limits. Work orders are issued by the system, | |||
including preventive maintenance and calibration activities. Manual | |||
backup is used if the computer is down and for emergency maintenance. | |||
As of June, a backlog existed on | |||
, | |||
, , - ,. - - - - - , . - - - - - - , _ . , - - , - , . - - . , _ , - - _ , .-,-m . . , . - -----------,,-,y._- - - - . . . - , -, | |||
,, - - . - * - - - , ---.-.----,,,..w - | |||
.. __ _ _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ , _ _ _ - - . _ _ _ _ _ _ _ _ _ _ | |||
' | |||
. | |||
. | |||
, , * | |||
13 | |||
computer input activities for the PMMS of Unit 3 mechanical equip- | |||
ment. Much of the work in this area was being performed on manually | |||
prepared work orders to give the PMMS time to catch up. Adequacy of | |||
the automated aspects of pMMS therefore remains to be proven. | |||
7 | |||
Observation of maintenance (e.g., component cooling water pump coup- | |||
ling and thrust bearing repairs, service water pump disassembly and | |||
! | |||
inspection, steam generator "J" tube replacement, service water inlet | |||
- | |||
elbow repairs on CCW heat exchanger) found the program effective. | |||
, | |||
Controls were sufficient to assure preoperational test results were | |||
r | |||
not invalidated and that retesting was conducted on equipment for | |||
which work orders were issued. | |||
Conclusion | |||
Category 2, consistent. | |||
1 Board Recommendation | |||
i | |||
i Licensee: Establish a schedule for the completion and implementation | |||
of maintenance related procedures and training programs. | |||
j NRC: None | |||
. | |||
! | |||
i | |||
; | |||
1 | |||
1 | |||
a | |||
i | |||
! | |||
1 | |||
! | |||
1 | |||
- - . _ . - - _ _ _ . _ _ . _ _ _ _ , . ___, . . _ - _ _ _ - , _-.___--,_m _ _ - . - - - - - _ . _ _ _ _ _ _ . . . - - _ , - - | |||
-- | |||
. | |||
. | |||
, * | |||
14 | |||
D. Surveillance (195 Hours, 2*4) | |||
Surveillance activities necessary to support plant operations were | |||
reviewed. Particular attention was given to development and imple- | |||
mentation of the surveillance program for Technical Specification | |||
requirements, availability and development of surveillance proce- | |||
dures, availability and retention of equipment baseline data, and the | |||
pre-service and inservice inspection programs. Inspections in this | |||
area involved a program review in May, as-built review for conform- | |||
ance to Technical Specifications in July, and examination of parts | |||
of the surveillance program during other inspections. | |||
For the most part, surveillance programs have been developed. Staf- | |||
fing was in progress or complete and personnel were knowledgeable of | |||
their responsibilities. Development of a master surveillance index, | |||
a computerized production and implementation schedule, and inter- | |||
departmental coordination methods had not been completed. | |||
In July 1985, a special team inspection found that surveillance pro- | |||
cedures were largely in draft form, varied substantially in quality, | |||
and were generally not ready for inspection. That condition per- | |||
sisted beyond the SALP period. (I&C surveillance procedures were | |||
significantly ahead of the others.) The license pointed out that | |||
delays in final Technical Specification issuance was a significant | |||
factor in delaying the facility procedures. NRC review concluded that | |||
the lack of procedure readiness included work that either did not | |||
depend on Technical Specifications or could have been put in near | |||
final form with provisions made for required validation upon Tech- | |||
nical Specification issuance (a feature also needed for future TS | |||
changes). Development of facility procedures was therefore evaluated | |||
as a tardy effort which did not properly support operations on the | |||
licensee's planned schedule. (As recently as early November 1985, the | |||
NRC postponed inspections in this area because procedures were not | |||
ready.) | |||
The applicant has provided a satisfactory program to obtain baseline | |||
information on plant equipment. In addition to obtaining field data | |||
(e.g., steam generator eddy current base line data), procedures and | |||
programs are being developed to maintain equipment history as | |||
discussed under the maintenance section. | |||
Conclusion | |||
Category 3, consistent. | |||
- | |||
. | |||
* | |||
o | |||
15 | |||
Board Recommendation | |||
Licensee: | |||
Assure surveillance procedures support future planned testing | |||
and operations. Particular emphasis should be placed on orderly | |||
development and review of procedures. - | |||
NRC: | |||
Conduct special follow-up inspection of surveillance program | |||
and procedure adequacy. | |||
- -- . . . - . - . _. . _ - . | |||
. | |||
. | |||
' | |||
. | |||
" | |||
16 | |||
- | |||
E. Preoperational Testing (1835 Hours, 23%) | |||
Preoperational Testing was rated Category 1 during the last SALP. It | |||
was characterized as a well-defined program with an adequate staff | |||
- | |||
and experienced senior managers. Adequate controls existed for plant | |||
maintenance, preventive maintenance, training, and documentation. | |||
' | |||
i The QA/QC program was evaluated as well-cbnceived. The supporting | |||
organizational elements, NUSCo-QA and NNECo-QA/QC, were staffed with | |||
experienced personnel. | |||
' | |||
During this SALP period, there were fifteen region-based inspections | |||
i plus routine observations by the resident inspector. In addition to | |||
; test program adequacy, test witnessing, and test results evaluation, | |||
NRC independent measurements were performed. Preoperational proce- | |||
dures were generally consistent with regulatory requirements, gui- | |||
dance, and commitments. An exception was the Chemical Tank drawdown | |||
test, which did not reflect all FSAR commitments. The applicant ini- | |||
1 tiated prompt corrective action. | |||
Management involvement has been evident in planning, procedure de- | |||
velopment, staffing, training, and results review. Also, the startup | |||
program was modified to improve performance. Three notable examples | |||
l were (1) assignment of an auxiliary system test coordinator to accept | |||
I | |||
selected responsibilities from the nuclear system balance-of plant | |||
test coordinators during high activity, (2) requiring the NNECo | |||
Operations Department to review system test results as well as the | |||
Startup Department, and (3) reorganization from a discipline- | |||
orientated to a task-orientated organization. | |||
Several tests have had a great number of changes (exceptions). These | |||
included the Chemical Addition Tank test, Engineered Safety Features | |||
test, RCS hydrostatic test, and Steam Generator hydrostatic test. | |||
Based on the changes reviewed, exceptions did not affect test results | |||
; or change basic test objectives. Changes were found to be properly | |||
; reviewed, approved, and documented. Throughout the SALP period, the | |||
NRC has had to review draft procedures. However, only approved pro- | |||
cedures have been found in use during testing. Based on the test | |||
results reviewed by the NRC inspectors, no problems have occurred | |||
' | |||
because of late procedure generation. | |||
Technical solutions to problems have been well defined and executed | |||
except for a few isolated examples where resolution was incomplete or | |||
4 slow. An example is valve indication on manual and motor-operated | |||
valves (slip of butterfly valve indication arrows, reverse installa- | |||
tion of indicators, reverse raised letter indication, no labelling | |||
' | |||
for position indicator, and handwheel operation contrary to normal | |||
convention). The containment sump flooding in May was in part a | |||
' | |||
result of failure to establish the position in the Containment Sump / | |||
Containment Recirculation Pump suction isolation valve. The valve | |||
stop for the butterfly valve had not been installed and the operator | |||
positioned the butterfly valve past the closed position by following | |||
the position indication (arrow). | |||
i | |||
_ ,. , . - . , - . . ,. | |||
. . ._ ._ _ ._- | |||
, | |||
, . | |||
, | |||
* | |||
17 | |||
During this SALP' period, the containment Local Leak Rate Testing | |||
(LLRT), Integrated Leak Rate Testing (ILRT), and Structural Integrity | |||
"; Test (SIT) were completed. Test procedures and results get require- | |||
ments. Personnel were knowledgeable of the procedures and equipment. | |||
Staffing was adequate. Test personnel made tours to look for leaks. | |||
The applicant exercised good engineering judgement. Only one Con- | |||
j struction Deficiency was identified: two 3/4 inch leakage monitoring | |||
* | |||
lines were improperly installed and left open to the atmosphere. | |||
That Deficiency was corrected. | |||
Test personnel and management involved with the SIT were committed to | |||
4 | |||
assuring an accurate, high quality test. Comparison to the predicted | |||
analytical deflections was done by crack mapping and crack width . | |||
< | |||
measurements in accessible unpainted areas. The applicant also | |||
measured exterior containment deflections across seismic (" rattle | |||
space") separations between the containment and adjacent structures. | |||
Preliminary. indications were that actual ~ deflections agreed with | |||
predicted ones. Overall, SIT efforts exceeded the provisions of SIT | |||
Regulatory Guide 1.18. | |||
; During the SALP period, preoperational testing proceeded without | |||
; serious delay. The only safety-related system encountering signif- | |||
icant difficulties was the Emergency Diesel Generators (EDGs), which | |||
experienced repeated seizing of the fuel injection pumps. Subsequent | |||
fuel system cleaning and flushing, and modifications to the fuel | |||
, | |||
' | |||
filters, appeared to resolve this problem. An EDG delay resulted | |||
when Stone and Webster Engineering review of Colt Industries QA/QC | |||
activities found it was necessary to replace numerous crimps in EDG | |||
panels. The rework proceeded in a thorough manner without sacri- | |||
ficing quality for time. | |||
QA/QC involvement was observed during preoperational testing. QC | |||
hold points are not included in preoperational test procedures. | |||
Rather, the QA/QC program consists of surveillances timed to give | |||
broad QA coverage of the preoperational test program. This moni- | |||
I | |||
toring program includes in process verifications, test witnessing, | |||
checks on instrument calibration, receiving and storage of test | |||
equipment, etc. No significant problems were noted. | |||
A trending / tracking program was established during preopeational | |||
testing for outstanding items, QA audit reports, completed actions, | |||
and other similar items. This program was found effective. | |||
Conclusion | |||
Category 1, consistent. | |||
' | |||
Board Reccmmendations | |||
-- . - . - _ _ _ _ . | |||
-. -. __ , . _ - - | |||
_, .-. .. | |||
-. . . _ . . . -~ . . . . . . . . , - _ - - . - - | |||
. | |||
,- . | |||
.: | |||
* | |||
4 18 | |||
! | |||
' | |||
Licensee: | |||
1. Upgrade timeliness of issuance of startup and power ascension | |||
! test procedures and of evaluation of test | |||
results. | |||
: | |||
1 2. Assure that any as-built plant, SAR,' and Technical Specifica- | |||
tions discrepancies revealed by preop tests are corrected. | |||
1 | |||
, | |||
NRC: None | |||
i | |||
+ | |||
t | |||
'9 | |||
- | |||
.. | |||
$ | |||
, | |||
e | |||
a | |||
A' | |||
e | |||
I | |||
! | |||
. . - . . _ _ _ . _ _ _ - . . . - . _ . _ _ . | |||
- - | |||
_ __ _ _ - _ _ . _ _ _ _ _ . _ _ - _ . . _ _ ___ . - . _ , _ . _ _ _ - . - - | |||
._ _ __ -_ _ _ _ _ _ _ .___________________ __________ | |||
_ | |||
. | |||
. | |||
, = | |||
19 | |||
F. Fire Protection and Housekeeping (172 Hours, 2%) | |||
Fire protection and housekeeping are also routinely reviewed by most | |||
NRC personnel who visit the site, making the actual data base greater | |||
than is recorded in inspection hour records. During this SALP | |||
period, there was one team inspection plus routine inspections by the | |||
resident and region based inspectors. The inspections confirmed that | |||
the applicant was implementing an effective program for fire preven- | |||
tion and fire protection. Licensee coverage included control of | |||
combustible materials, storage and use of flammable liquids, avail- | |||
ability and maintenance of fire fighting equipment, operations in- | |||
volving open flames or arcs and fire prevention for temporary ser- | |||
vices and work activities. Throughout the SALP period, fire pre- | |||
vention and fire protection was well implemented and maintained, and | |||
housekeeping and cleanliness were satisfactory. | |||
The NRC team inspection confirmed the ability to shutdown safely in | |||
the event of a design basis fire. Management involvement in assuring | |||
a safe shutdown capability was evident throughout the licensee's | |||
effort involved in applying the NUREG 800 Guidelines. The applicant | |||
formed a fire protection inspection team of hand picked specialists | |||
from his staff and contractor personnel. This team addressed shutdown | |||
concerns and capabilities, design changes, and compliance with guide- | |||
lines. Management attention resulted in an efficient licensee team | |||
which adequately addressed all NRC concerns. The applicant demon- | |||
strated a clear understanding of safe shutdown issues and concerns. | |||
Their analysis was comprehensive and well documented. Such thorough- | |||
ness was also reflected in the supporting calculations reviewed by | |||
the NRC. Throughout the NRC team inspection, applicant responses | |||
were timely and technically sound. | |||
In November 1984, a small fire in containment was caused by a short | |||
in a temporary lighting cable, apparently due to crimping of the | |||
cable by scaffoldin! planks. The damage was minor. No permanent | |||
plant equipment was clamaged. The applicant's response was prompt and | |||
well organized. A reflash watch was stationed for several hours. | |||
Corrective action implemented after a September 1981 fire limited the | |||
scope of this fire. This event demonstrated an effective fire re- | |||
sponse capability. | |||
One concern was the licensee's Hot Functional Testing approach which | |||
waived fire protection for areas protected by carbon dioxide due to | |||
problems with fire control panels. The licensee committed to addi- | |||
tional patrols of the potential hazard areas to provide minimum pro- | |||
tection. The carbon dioxide system has yet to be demonstrated. As | |||
late as November, this system was not tested due to a problem | |||
with the Heating, Ventilation and Air Conditioning System. | |||
Staff responsibilities were evaluated as well defined and authorized | |||
manning levels as ample to meet those responsibilities. | |||
.. . . | |||
. | |||
. .. | |||
_ - _ - _ _ _ | |||
- | |||
. | |||
. * | |||
20 | |||
Conclusion | |||
Category 1, consistent. | |||
Board Recommendation | |||
Licensee: None | |||
NRC: Follow-up CO2 | |||
System testing and associated damper testing. | |||
__- - - - - - - - - - _ | |||
. | |||
. * | |||
21 | |||
G. Emergency Preparedness (140 Hours, 2%) | |||
This is the first SALP evaluation for Millstone 3 in this area. Unit | |||
3 is an additional unit in the common site Emergency Plan and is in | |||
part dependent on the program for Units 1 and 2. The site program | |||
was rated as Category 2 (period 9/1/83 - 2/28/85) with the recommenda- | |||
tion that the licensee evaluate measures for the timely completion of | |||
action items. The major issue was the establishment of an integrated | |||
emergency plan training / retraining program to ensure that lesson plans | |||
were developed and training accomplished for each functional area of | |||
4 | |||
emergency activity. At the end of the Unit 1/2 assessment period, the | |||
" Emergency Preparedness Training Program" was only available in draft | |||
form but contained the revised training lesson plan format and testing | |||
requirements. This program, which was to be implemented by June 30, | |||
1985, was late but acceptable in quality, | |||
i | |||
A Unit 3 Emergency Preparedness Implementation Appraisal was conducted | |||
in July 1985. It covered facilities and equipment, organization, | |||
procedures, and training. Afterwards, a meeting was held in Region I | |||
to discuss deviations from current guidelines. During that meeting, | |||
the applicant presented information which resolved the concerns or | |||
4 proposed acceptable corrective action. In many cases, a more com- | |||
plete description in the Emergency Plan or implementing procedures | |||
would have allowed an earlier resolution. | |||
On May 15, 1985, the NRC observed an emergency drill for Millstone 3. | |||
! | |||
Participation was limited to utility personnel. This drill imple- | |||
mented selected response aspects including operator response, tech- | |||
nical support activities, event classification and reporting, and | |||
coordination of emergency response activities. Overall performance | |||
was acceptable. Personnel $were appropriately trained and qualified | |||
to perform the emergency functions observed. Areas noted as | |||
needing improvement were coordination of emergency repair activities | |||
between the Technical and Operational Support Centers and crowding of | |||
some facilities in the OSC. The crowding was in part due to the | |||
dispatching of repair crews from the OSC. | |||
Management commitment and close involvement in assuring an adequate | |||
level of emergency preparedness was shown during the emergency drill | |||
and program reviews. | |||
Conclus r3 | |||
Category 2, consistent. | |||
Board Recommendation | |||
4 | |||
Licensee: Increase management attention to assure corrective actions | |||
are accomplished in a timely manner. | |||
NRC: None. | |||
_ - . - . | |||
-_ | |||
- . - _ - - -- - -_ - - . - - . - - . -- | |||
_ | |||
- | |||
. | |||
. | |||
22 | |||
, | |||
H. Security (84 Hours, 1%) | |||
; This was the first SALP evaluation of Unit 3 Security and reviewed | |||
' | |||
the development of a physical protection program for Unit 3 and | |||
preparations for integration of the Unit 3 program into a site (Units | |||
1, 2 and 3) security program. Also assessed was the licensee's | |||
developing and implementing of a program for receipt and storage of | |||
l new fuel. Three announced preoperational security program reviews, | |||
including two inspections of new fuel were performed by a | |||
region-based physical security inspector. Continued review of the | |||
program was conducted by NRC resident inspectors. | |||
The development of the physical security program and its integration | |||
into the program for Units 1 and 2 included modification of the | |||
security management organization; the procurement, installation and | |||
acceptance testing of new equipment and the operational interface of | |||
the Unit 3 equipment and systems with the existing system; and the | |||
hiring and training of additional contract security personnel. | |||
A major rewrite of the site physical protection plan was completed | |||
and submitted to the NRC in May 1985. NRC review identified some | |||
, minor issues which required rework by the licensee. All of these | |||
issues have been resolved. In addition, the licensee submitted its | |||
Plan for Receipt of New Fuel in March 1985. It required little | |||
rework and was approved by NRC in April 1985. The licensee is | |||
currently reviewing its Suitability, Training and Qualification, and | |||
. Safeguards Contingency plans to provide for the integration of Unit | |||
i | |||
3. It appears that only minor administrative changes will be neces- | |||
sary. All security program plans were observed to be professionally | |||
prepared, well organized, responsive to regulatory requirements, and | |||
submitted in a timely manner. Minor changes necessitated as a result | |||
of NRC review were accomplished in a timely and professional manner. | |||
The design engineering and layout of the Unit 3 security equipment | |||
and systems are well conceived. Practical applications and utiliza- | |||
tion of state-of-the-art equipment are evident. Quality assurance | |||
4 | |||
oversight of program-related activities was evident throughout the ' | |||
assessment period. Project engineers and security supervisors were | |||
l knowledgeable of program status, turnover dates and NRC performance | |||
criteria. Procedures were in place to assure the proper acquisition , | |||
i | |||
and retention of acceptance testing documentation. Documentation was ' | |||
found easily retrievable during NRC reviews. These reviews indicated | |||
close coordination and oversight by licensee management for all | |||
activities. The newly constructed site security facilities were well | |||
planned with an adequate allocation of space. Human factors con- | |||
sideration was evident. | |||
4 | |||
e | |||
,-- - | |||
,>~m - - - - - - m ~- | |||
. _ _ _ _ _ _ _ _ _ | |||
. | |||
.. | |||
. * | |||
23 | |||
. | |||
The hiring of new contract guards and watchpersons is complete. The | |||
security organization has increased by approximately one third, to | |||
about 280 personnel, including both proprietary and contract | |||
staffing. The training and. qualification of new security personnel | |||
has been in progress since March 1985 and is scheduled for completion | |||
in September 1985. Specialized training being administered to the | |||
new personnel was observed during Region I program reviews and was | |||
found consistent with the licensee's NRC approved Suitability, | |||
Training and Qualification Program. Experienced Unit 1 and 2 | |||
personnel are in line for command and access control positions. | |||
The last two Preoperational Security Program Reviews during the | |||
assessment period included implementation inspections of the Plan for | |||
Receipt of New Fuel and associated control procedures. No problems | |||
were identified. | |||
Corporate and site management involvement in planning, procurement, | |||
installation, hiring of employees, budgetary support, quality | |||
assurance and audit have been evident throughout the assessment ' | |||
period. Presentations on the status of projects were professional | |||
and technically competent. Sufficient personnel are trained, | |||
qualified and available to compensate for unplanned system or | |||
equipment failures. | |||
The licensee promptly informed the NRC of occurrences in the security | |||
area during the construction of Unit 3. | |||
Conclusion | |||
Category 1, consistent. | |||
Board Recommendation | |||
Licensee: None. | |||
NRC: None. | |||
_ | |||
. | |||
., . | |||
. | |||
24 | |||
I. Construction (4774 Hours, 59's) | |||
The previous SALP assessment evaluated six areas of construction | |||
separately. These were Containment and Other Safety-Related Struc- | |||
tures; Piping Systems and Supports; Safety-Related Components; | |||
Support Systems; Electrical Power, Instrumentation and Controls; and | |||
Engineering-Construction Interfaces. All areas were rated Category 1 | |||
except Piping Systems and Supports which was re.ted Category 2. All | |||
six areas have been combined under one functional area for this SALP. | |||
Concerns addressed in the previous SALP included: (1) assumed pipe | |||
and fitting sizes were used in stress calculations (2) lack of | |||
aggressive action to correct deficiencies in the control of NDE qual- | |||
ity, (3) minor delays in correcting deficiencies in safety-related | |||
components and (4) choice of the proper Non-Destructive Examination | |||
(NDE) method for inspecting of containment electrical penetration and | |||
end plate welds. | |||
Inspection of construction involved eighteen inspections in addition | |||
to routine review by the resident inspcclors. There was a team in- | |||
spection from NRC Headquarters and one from the Region. Three team | |||
inspections involved the Enoineering Assessment In-Depth Technical | |||
Audit. Ten construction violations wer~e identified. None of these | |||
were considered serious or indicative of a breakdown in the quality | |||
of construction. | |||
Most electrical systems were energized during this SALP period to | |||
support testing. Although there were problems with control of elec- | |||
trical and I&C equipment due to dirt, aggressive management attention | |||
was effective in correcting this. Overall, electrical construction | |||
has been good. Design requirements'and specifications were generally | |||
met. Deficiencies noted included not meeting electrical separation | |||
criteria for some raceways and cables, some Class IE cable termina- | |||
tions not in accord with design drawings, some main control board | |||
redundant wires in contact with each other, and random use of color | |||
tape to identify cable channels. The applicant quickly initiated | |||
acceptable corfective actions. Vendor wire termination problems | |||
were , uncovered'by the licensee and resulted in an aggressive 100% | |||
reinspection program of four vendors. The associated rework has been | |||
completed for the main control board and the Systems Control vendors | |||
and was in progress for the other two. | |||
Work observation, as-built verifications, and independent measure- | |||
ments and calculations have found the instrumentation and controls to | |||
be in compliance with drawings and commitments. | |||
- | |||
. | |||
. * | |||
25 | |||
Containment and other safety-related structures have been constructed | |||
with only minor problems / weaknesses found. These have included | |||
rattle spaces smaller than committed, concrete in the rattle space | |||
between Containment and the Main Steam Valve Room, and some steel | |||
connections not in accordance with design drawings. Repair of con- | |||
tainment liner damage from a September 1981 fire were acceptably com- | |||
pleted. Overall, structural construction <was in accordance with | |||
applicable codes, commitments, and requirements. | |||
Engineering-construction interfaces have generally been good and have | |||
effectively functioned during operational turnovers. Although a | |||
large number of open items may be present on turnover, there are | |||
controls to determine how these items will be dispositioned. Manage- | |||
ment has been very responsive. Improvements were noted in post-turn- | |||
over control of wiring changes and preventive maintenance deficien- | |||
cies. The applicant has knowledgeable personnel who are aware of re- | |||
quirements involved with turnover documentation, but some files are | |||
incomplete and it was very time consuming to assemble the data. No | |||
major problems were experienced as a result. | |||
Problems associated with the vendor radiographic program, identified | |||
by the NRC Van inspection during the last SALP period, indicated that | |||
management was not sufficiently involved in control of non-destructive | |||
examination (NDE) quality and that technical evaluations were not | |||
adequate. Additional problems were identified during this SALP | |||
period. These include drawing control, missed radiographic indica- | |||
tions in site and vendor welds, and failure of the licensee to have | |||
the independent authorized nuclear inspector review final re-radio- | |||
graphs of welds. These involved 600-700 vendor (Tubeco) weld radio- | |||
graphs. The applicant initiated corrective action. Relief from code | |||
requirements was requested from NRR for 30 welds imbedded in con- | |||
crete. As of this writing, no substantive rework has been required | |||
to assure the ability to meet functional design requirements. Never- | |||
theless, continued management attention is warranted to NDE record | |||
quality. | |||
In August 1985, selected results of Preservice Inspection (PSI) | |||
ultrasonic examinations of centrifugally cast stainless steel for the | |||
reactor coolant piping were reviewed. The review identified dis- | |||
crepancies involving documentation of examination limitations and the | |||
disposition of indications attributed to geometric reflectors. These | |||
indicate a need for additional licensee management attention to the | |||
review of Westinghouse PSI data. | |||
, | |||
' | |||
. | |||
. | |||
... * | |||
' | |||
26 | |||
; | |||
4 | |||
' , During the CAT inspection discrepancies were identified in pipe sup- | |||
port / restraints and mechanical equipment foundations, and between | |||
' | |||
as-built drawings and piping configurations. The team also identi- | |||
fied a need for more thorough engineering review activities, and | |||
additionaFreinspection and/or reanalysis. In' August 1985, an ex- | |||
tensive inspection was performed on structbral steel bolting and | |||
welding, pipe support welding, vendor tank welding, and stress recon- | |||
ciliation. This inspection included independent measurements and | |||
followup of licensee activities in response'to CAT findings. Over- | |||
all, the results indicate good onsite welding quality and an adequate | |||
program for response to the CAT findings. | |||
Immediately after the SdLP period a multidisciplinary team inspection | |||
,' assessed whether selected, as-built systems substantially agreed with | |||
the'l descriptions contained in the FSAR and the SER. It was concluded | |||
that overall workmanship was good and that the systems generally con- | |||
form to the F5hk and SER. Capacity and seismic mounting discrepan- | |||
cies were, however, identified in the control room air pressurization | |||
system. | |||
,' | |||
.~ \ | |||
, .The senior resident inspector and Region I managers have found.that, | |||
in general, submitted Construction Deficiency Reports were timely, | |||
thorough, and of good quality. Technical solutions for Construction | |||
s0eficiencies has been sound. Corrective action has been performed | |||
; by properly trained personnel using approved procedures. However, | |||
' ' | |||
resolution of a number of items has continued to proceed slowly | |||
and needs, additional management attention, | |||
* | |||
s Nonconformance and Disposition reports are usually resolved in a | |||
, timely manner, with positive corrective action being taken. Design | |||
modifications-and modification requests were handled in accordance | |||
, with procedures. ' Disposition of these requests were based on | |||
engineering justification and review by members of the Joint Test | |||
Group. Engineering and Design Coordination Reports have been | |||
, generally effective. . | |||
NNECo contracted Stone and Webster Engineering Corporai. ion (SWEC), | |||
the AE for Millstone 3, to conduct an Engineering Assurance Program | |||
Technical Audit. NRC review found the audit to be in accordance with | |||
the approved program plan and of sufficient technical depth to | |||
achieve the program objectives. There was a concern that reviewers | |||
~) were not deviating from the review plan as necessary to thoroughly | |||
p[ evaluate.both the adequacy of the design and the adequacy'of the | |||
N desigrc process when potential problems were identif,ied. Also, | |||
interfaces between the major disciplines of the AE audit team needed | |||
improvement to ensure that potential discrepancies in one discipline | |||
was reflected in others. As an outgrowth of the AE audit, NRC is | |||
'/e reviewing the applicant's Seismic II/I program. This consideration | |||
is included in the Licensing Functional Area. | |||
. | |||
- . .- .-_ . . .- . _. . .. _-. | |||
- | |||
. | |||
. | |||
27 | |||
QA/QC personnel were rountinely observed to be performing construc- | |||
tion and preoperational testing functions. During construction, | |||
, | |||
" hold points" for inspection of completed work were readily apparent. | |||
Subsequent reviews of the QA/QC involvement (quality examination, | |||
' | |||
procedure reviews, surveillance, and auditing) indicated logs and/or | |||
i records were being maintained and the results reported. Nonconform- | |||
., ing or unsatisfactory conditions were being followed for corrective | |||
, | |||
action, | |||
, | |||
Overall, the construction at Millstone 3 has been in accordance with | |||
; the applicant's commitments and applicable codes and regulations. | |||
; Conclusion | |||
Category 1, consistent. | |||
' | |||
- Board Recommendation | |||
. Licensee: Assure more timely closecut of CDRs and outstanding items. | |||
! | |||
l NRC: None. | |||
1 | |||
1 | |||
i . | |||
4 | |||
3 | |||
h' | |||
r | |||
d | |||
--.._,.-_,....-..--._,-,,._,.-,..,_,--.m._.m_-_, ,.._.,-.c., , - - . . . . | |||
,,,-,4 -- | |||
4._,,_ m.-,,_,,--- . - - ,,__, .,. , , _ . , _ . , ,-,_ | |||
. . | |||
. | |||
' | |||
28 | |||
J. Licensing Activities | |||
This area was rated Category 2 during the previous SALP, with | |||
recommendations that the licensee continue to take the initiative to | |||
resolve fuel load items and to provide appropriate management involve- | |||
ment in significant review areas. During the current period, NRR | |||
review supported issuance of Safety Evaluation Report Supplements 1 | |||
and 2 (March and September 1985) toward resolution of 19 SER open | |||
items, 70 confirmatory items, and 7 license conditions. There were | |||
several NRR on-site, in-depth technical audits in addition to meetings, | |||
conference calls, and review of applicant inputs. | |||
For those items identified as part of the staff's safety review, the | |||
applicant demonstrated prior planning and assignment of priorities. | |||
The applicant continues to take an aggressive approach to complete | |||
unresoived items identified in the staff's SER. There were well- | |||
stated and explicit applicant procedures for activity control. In | |||
general, NNECO assigned technical people as needed to develop com- | |||
plete high quality responses. The fire protection review effort was | |||
a good example of this. Additionally, evidence of prior planning and | |||
assignment of priorities was demonstrated during several on-site | |||
technical audits. Audits were held on schedule and the appropriate | |||
technical and management support was involved so that the NRC staff's | |||
questions were answered with a minimum number of open items after the | |||
audits. | |||
Generally, the applicant exhibited conservatism in its decisions where | |||
safety significance existed. An example of this is the Engineering | |||
Assurance Program. The applicant, on its own initiative, took a sound | |||
and thorough approach to the independent design review, using an | |||
engineering assurance technical audit program performed by Stone & | |||
Webster. Open items identified by S&W during this audit were | |||
vigorously pursued by the utility. | |||
In contrast to the approach taken by the applicant on many SER items, | |||
there were a significant number of review matters for which the | |||
applicant was unresponstve. The applicant did not come forward with | |||
several potential review concerns early in the review process until | |||
NRC forced the issue. In other cases, the applicant persisted in | |||
supporting a position contrary to the staff's requirements. As a | |||
result, several items of potentially high safety significance sur- | |||
faced or remained unresolved late in the review process. High level | |||
NRC management involvement was then necessary to accelerate the | |||
review and assess potential impact on licensing. An example of this | |||
is the Seismic Interaction Program. In this case, the applicant | |||
failed to notify the staff of its planned approach to meet NRC | |||
criteria until that approach was identified by the staff during the | |||
Engineering Assurance Program Audit. It was not until after several | |||
meetings with NRC staff to discuss and agree upon supplementary | |||
. . - _ .- -. - . . - - _ - _ .. - _ _ . - ._-- -- | |||
. | |||
. | |||
. | |||
. | |||
29 | |||
< | |||
information that progress was made toward resolution. Other examples | |||
are the shift staffing / operating experience on shift issue and the | |||
Technical Specification review. The position taken by the applicant | |||
on both these matters was that the staff was aware of the applicant's | |||
position early. The applicant did not pursue interaction with | |||
1' | |||
the staff to assure that NRC requirements were met. NRC repeatedly | |||
attempted to work with the utility on shift staffing before the | |||
utility began to be responsive. As a consequence, an inordinate | |||
amount of staff involvement was necessary to complete this review. | |||
The applicant was also unresponsive in regard to the Technical | |||
Specification review. The applicant did not submit the justifi- | |||
cations needed for non-Standard Technical Specifications in a timely | |||
manner. An accelerated review schedule became necessary. | |||
In summary, the applicant has provided satisfactory inputs to the | |||
NRC, but too many items have not been timely. | |||
Conclusion | |||
Category 2, consistent | |||
Recommendation | |||
Licensee: Increase management involvement in the licensing review | |||
process in order to assure more timely resolution of licensing issues. | |||
I | |||
NRC: None | |||
! | |||
t | |||
I | |||
. . _ _ . . _ . _ . _ _ _ - . , _ . . . - , , , _ . _ . . _ , _ . _ , _ . _ _ _ _ _ . _ . _ , _ _ _ | |||
_ | |||
.. _ _ _ _ . _ . . _ . _ _ _ _ . . . _ _ , _ _ . . - . , . | |||
- . -. - ..- _ - - - - -- . - .. - . . __ - - . . . | |||
- | |||
. | |||
' | |||
.- | |||
30 | |||
V. SUPPORTING DATA AND SUMMARIES | |||
A. Construction Deficiency Reports (CORs) | |||
4 | |||
The applicant identified 29 items of potentially significant | |||
deficiencies during the assessment period. Subsequently, 3 were | |||
evaluated as not to be reportable by the applicant. At the end of | |||
; ' | |||
the assessment period, 15 remain open pending resolution of the | |||
issue. The CDRs are listed in Table 1. | |||
{ B. Investigation Activities | |||
One investigation of a painter qualification incident was completed. | |||
' | |||
The report has not been released for public distribution. Another | |||
investigation was in progress but not completed. | |||
C. Escalated Enforcement Action | |||
No escalated enforcement actions were taken this SALP period. | |||
D. Management Meetings | |||
On September 13 and 14, 1984, NRC staff met with Northeast Nuclear | |||
Energy Company at Millstone 3 to discuss LOCA loads and load | |||
combinations used in design of Millstone 3 pipe and component | |||
supports. | |||
On December 17, 1984 at Millstone 3, Waterford, Connecticut, a | |||
management meeting was held to present the results of the Systematic | |||
Assessment of Licensee Performance (SALP) for the assessment period | |||
9/1/83 - 8/31/85. | |||
A periodic management meeting requested by Millstone 3 and Northeast | |||
, Utilities management to discuss the project status and progress was | |||
held on February 8, 1985 at the Region I office. | |||
4 | |||
' | |||
A Seismic Qualification Review Team (SQRT) and Pump and Valve | |||
: Operability (PVORT) audit was conducted during the week of March 4, | |||
1985 by the NRC staff. | |||
On May 21, 1985, a meeting was held at the Millstone 3 site with the | |||
; NRC Radiological Assessment Branch to discuss and verify FSAR | |||
; commitments relating to the radiation protection program. | |||
! | |||
: On June 21, 1985, a meeting was held at NRC Headquarters to discuss | |||
Seismic II/I design considerations for Millstone 3. | |||
On July 2, 1985, a meeting was conducted at NRC Headquarters to , | |||
, discuss the Millstone 3 environmental qualification report. | |||
, , | |||
1 | |||
. - - - - ,----r - | |||
y ,, ,,,,.._..,_.-.,,_,.,_,..,_,,,.~,.y ...,._,,ym-~, - - , , . _ , _ . _ _. - , _ , , _ , | |||
.-.__,...-..y_,,-.,.m., --___..-.....-..-,,,,.,.,,-.,,,m,. - - | |||
. . | |||
. | |||
.- | |||
31 | |||
On July 9, 1985, a meeting was. held at the NRC Region I Office to | |||
discuss the status of licensed operator training and of the Millstone | |||
3 project. | |||
On July 11, 1985, a meeting was held with Northeast Utilities to | |||
discuss the Millstone 3 fire protection at NRC Headquarters. | |||
On July 29 and July 30, 1985, an audit of the Millstone 3 Safety | |||
Parameters Display System (SPDS) to perform design verification and | |||
design validation was conducted at the Northeast Utilities General | |||
Offices in Berlin, Connecticut. | |||
On August 1, 1985, a working meeting was held at the NRC Region I | |||
office to resolve emergency planning pre-licensing issues for | |||
Millstone 3. | |||
'A meeting was held on August 6, 1985 at NRC Headquarters to discuss | |||
the applicant's response to questions resulting from the staff's | |||
review of the Millstone Nuclear Power Station Emergency Plan, Draft | |||
2, to Revision No. O, dated January 1985. | |||
. . | |||
, . | |||
TA9LE I | |||
CONSTRUCTION DEFICIENCY rep 0RTS | |||
(September 1, 1984 - August 31, 1985) | |||
MILLSTONE NUCLEAR p0WER STATION, UNIT 3 | |||
CAUSE | |||
CRD NO. OEFICIENCY STATUS CODE | |||
84-00-10 Eleven Westinghouse process control cabinets had in- Closed A | |||
ternal wiring which should have been removed at tha | |||
factory | |||
84-00-11 Unqualified motors on safety-related motor-operated Closed A | |||
valves | |||
84-00-12 Potential leakage path in seal of Rosemont Model 1153 Closed * B | |||
Series B pressure transmitters | |||
84-00-13 Problems with Flakt-Bahnson air conditioning units Open* B | |||
84-00-14 Potential failure of auxiliary feedpump wear rings Open B | |||
84-00-15 Oil leak and broken upper bearing housing in contain- Closed B | |||
ment recirculation spray pump motors | |||
84-00-16 GE relays potentially operating in less time than Closed B | |||
the set time delay | |||
84-00-17 Potential cracking of emergency diesel generator Closed A | |||
engine driven lube oil pump discharge nozzle due to | |||
over-torquing | |||
84-00-18 Improper installation of conduit seal for Rosemount Closed F | |||
Pressure Transmitter | |||
85-00-01 Possible material problems with Parker-Hannifin Open B | |||
stainless steel fittings | |||
85-00-02 Jafety grade power supplies tied to control grade Closed B | |||
cables without appropriate isolation devices in | |||
Westinghouse Model 7300 Process Control Cabinets | |||
85-00-03 Potentially inoperable non-motor-operated curtain Open B | |||
type fire damper | |||
- .. - . . - . . - - . - -.- --- .-- .. . . - - - - _ _ _ _ - - . . | |||
d | |||
a | |||
j . | |||
o t | |||
i | |||
E | |||
CAUSE | |||
, CRD NO. OEFICIENCY STATUS CODE | |||
4 | |||
i | |||
85-00-04 Improper operation of the emergency generator load Closed B | |||
sequencers | |||
, | |||
85-00-05 No drain holes in Foxboro Transmitter junction boxes Closed F | |||
! 85-00-06 Failure of emergency diesel generator 1 sad sequencer Closed B | |||
to shed required loads | |||
, | |||
; | |||
' | |||
85-00-07 Non-seismically qualified auxiliary. feed pump lube Open B | |||
oil pressure switches | |||
85-00-08 Nonconforming terminations in CVI corporation equip- Open B | |||
; ment | |||
4 | |||
i | |||
85-00-09 Cooper and Turner load indicating washers with preload Closed * B | |||
out of compliance with design | |||
. | |||
85-00-10 Broken tack welds on feedwater check valves Open E | |||
* | |||
85-00-11 Emergency diesel generator fuel oil injection pump Open E | |||
. | |||
failures | |||
85-00-12 Improper cable separation for Reactor Protection Closed B | |||
System cables | |||
j 85-00-13 Improper dimensioning of fillet welds on tube steel Closed F | |||
4 | |||
connections where skewed angle is less than 45 degrees | |||
t | |||
85-00-14 Structural steel connections in the Main Steam Valve Closed F | |||
Building installed to incorrect welding detail | |||
; , | |||
! 85-00-15 Core exit thermocouple total system error exceeds Open B | |||
. error assumed in Westinghouse Emergency Response | |||
4 | |||
Guidelines | |||
t | |||
85-00-16 Improper installation of upper reactor internal core Open F | |||
, thermocouple compretsing fitting | |||
i | |||
85-00-17 Seismic failure of Amphenol Triax Connector Open E ! | |||
85-00-18 Potential seismic interaction between the Flux Open B | |||
Mapping System and Seal Table | |||
: | |||
. | |||
J | |||
' , | |||
1 | |||
- - _ _ _ _ . . _ _ _ . _ . _ _ _ _ _ _ _ _ , , _ , , _ _ _ _ _ _ _ . - _ _ . , _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ . - - _ - , _ | |||
. | |||
. | |||
. | |||
3 | |||
CAUSE | |||
CDR NO. DEFICIENCY STATUS CAUSE | |||
85-00-19 Potential seismic failure of GE Type PVD21 Differ- Open E | |||
ential Relays | |||
85-00-20 Improper Emergency Diesel generator sequencing Open B | |||
* Licensee subsequently classified item as not reportable | |||
CAUSE CODES | |||
A - Personnel Error | |||
B - Design / Fabrication Error | |||
C - External Cause | |||
D - Defective Procedure | |||
E - Component Failure | |||
F - Site Construction Error | |||
l | |||
1 | |||
i | |||
,_ _ . - _ _ - ,-_ .__ | |||
. . | |||
. | |||
* | |||
! | |||
4 | |||
TABLE 2 | |||
INSPECTION HOURS SUMMARY (9/1/84 - 8/31/85) | |||
MILLSTONE NUCLEAR POWER STATION, UNIT 3 | |||
Functional Area Hours % of Time | |||
A.: Operations Supports 552 7 | |||
B. Radiological Controls 181 2 | |||
C. Maintenance 169 2 | |||
! | |||
D. Surveillance 195 2 | |||
' | |||
E. Preoperational Testing 1865 23 | |||
F. Fire Protection 172 2 ! | |||
G. Emergency Preparedness 140 2 | |||
H. Security 84 1 . | |||
I. Construction 4774 59 | |||
J. Licensing Activities -- -- l | |||
3 TOTAL 8201 100 | |||
; | |||
' | |||
NOTE: The above values are approximate. | |||
t | |||
I | |||
! | |||
l | |||
- l | |||
[ | |||
i | |||
i | |||
: | |||
! | |||
[ l | |||
1 | |||
' | |||
f | |||
, | |||
- + < mm u -m__,*.=>w~--,,+y-----w~~.--me-- ,w-e------n-w-+mv-wwm, % mvv - ~ . - %4we,--,-we-m, >----ev---+-r--- - - , | |||
- - _ _ . - _ _ __. - . - . -- - _ _ - - _ _ . . ~ . | |||
. | |||
. | |||
_, . | |||
5 | |||
i | |||
TABLE 3 | |||
INSPECTION ACTIVITIES | |||
MILLSTONE NUCLEAR POWER STATION, UNIT 3 | |||
' | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
: 84-14 Resident Open items; preoperational testing; incore | |||
: 8/19 - 9/29/84 114 hours thermocouples; structural settlement monitoring | |||
program; procedures; diesel fuel storage; lic- | |||
ensee/ contractor self audits; significant deft- | |||
ciencies; ACRS items. | |||
84-15 Specialist Previous SALP period. | |||
84-16 CANCELLED | |||
84-17 Specialists Preoperational test program review including i | |||
9/17 - 21/84 37 hours program requirements, control of documents, test | |||
procedures, engineering drawings, manuals, de- | |||
sign changes and modifications, jumpers and by- | |||
passes; plant maintenance, preventive mainten- | |||
ance, and maintenance records; test procedure | |||
, reviews and test results evaluations. | |||
84-18 Specialists Followup on previous inspection findings; work | |||
: 9/17 - 21/84 32 hours observation; review of QC of pipe supports. | |||
84-19- 1984 Millstone Unit 3 SALP. | |||
84-20 Resident Follow-up on previous inspection findings; start- | |||
9/30 - 11/10/84 266 hours up test program review and observation; event | |||
follow-up; welding electrode control; training; | |||
i | |||
maintenance; construction; and housekeeping. | |||
I | |||
84-21 Specialists Facility tour; pipe and pipe support welding; | |||
10/15-19/84 36 hours copper-nickel welding; repair welding; and | |||
follow-up on open items. | |||
' | |||
84-22 Specialists Follow-up on open items; preoperational test | |||
10/15-19/84 39 hours program requirements and implementation; test | |||
procedure review and witnessing emergency diesel | |||
generator set test verification; and facility | |||
tour. | |||
84-23 Specialists Installation of safety-related electrical and l | |||
10/22-26/84 66 hours instrumentation system components. | |||
l | |||
I | |||
' | |||
. - - - . - - - _- - _ ----__ -_ - - - -.. . - -. --- - - - | |||
_ _ - _ _ _ _ _ _ _ _ _ _ _ __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
! | |||
. - | |||
. | |||
l | |||
. , | |||
' | |||
( | |||
6 , | |||
r | |||
4 | |||
INSPECTION REPORT INSPECTION / | |||
, | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
. 84-24 Specialists Preoperational test program requirements and | |||
l 11/5-9/84 29 hours implementation; test results evaluation and | |||
witnessing; auxiliary boiler repair and testing; | |||
. | |||
preparations for' steam generator hydrostatic | |||
. | |||
I | |||
testing; quality assurance and quality control; | |||
facility tour. | |||
84-25 Resident Preoperational testing; follow-up on open items; | |||
11/11/84-1/7/85 192 hours control room practices; plant tours; control | |||
. rod drive fabrication review; event follow-up; ! | |||
IE Notice review; implementation of security i | |||
measures; audit activities; fire protection i | |||
testing; hazards program review; changes to i | |||
plant management; and Tubeco repairs, | |||
i | |||
84-26 Specialists Preoperational test program requirements and | |||
. 11/26-12/5/84 134 hours implementation; test procedures and results | |||
i | |||
12/ 3- 5/84 results review; steam generator hydrostatic | |||
I | |||
12/10-12/84 testing; quality assurance and quality control; | |||
, | |||
and facility tours. | |||
+ 85-01 Specialists Construction Deficiency Reports | |||
j 1/8-10/85 64 hours | |||
.85-02 Resident Preoperational testing; previous inspection , | |||
1/9-2/4-85 151 hours findings; control room practices; plant tours; ' | |||
potential significant deficiencies; flushing | |||
' | |||
program activities; IE Bulletins; allegations; | |||
' valve positioning anomalies; fuel receipt pre- | |||
parations; service water hydraulic testing; | |||
safety injection plump test ar.o aly. ' | |||
85-03 Specialists Preoperational test program requirements and | |||
, 1/21-?5/85 70 hours implementation; test procedure and results re- | |||
i | |||
views; test witnessing; auxiliary boiler status; | |||
quality assurance and quality control; and | |||
l facility tours. | |||
} 85-04 Specialists Construction appraisal team: Electrical and in- | |||
2/19-3/1/85 2200 hours strumentation construction; mechanical con- | |||
3/11-22/85 struction; welding and non-destructive examin- | |||
' ation; civil and structural construction; mate- , | |||
rial traceability and control; design change ! | |||
control; corrective action systems. i | |||
1 | |||
l | |||
i | |||
l | |||
! | |||
! | |||
, | |||
- .. | |||
- | |||
. | |||
. * | |||
7 | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
85-05 Resident Review of activities including refueling cavity | |||
2/5-3/18/85 183 hours seal ring leak test, emergency diesel generator | |||
EDG-A gage repair, EDG-A lubrication system | |||
performance, system flushes, hydraulic expansion | |||
of steam generator tubes, emergency plan train- | |||
ing, and FSAR/ design verification maintenance | |||
training; open items; NRC Bulletins, steam | |||
generator field service report; construction | |||
deficiencies; and allegation followup. | |||
85-06 Specialists Preoperational test program requirements and | |||
2/12-15/ 63 hours implementation; test procedures and results re- | |||
2/25-3/1/85 view; test witnessing; open items; and plant | |||
tour. | |||
85-07 Specialists Combined report for Units 1, 2 and 3: Preopera- | |||
2/11-15/85 31/10 hours ** tional program for operational environmental | |||
monitoring program including management controls, | |||
quality control of analytical measurements, | |||
meteorological monitoring, radiological environ- | |||
mental monitoring program. | |||
85-08 Specialists Installation of safety-related instrumentation. | |||
2/4-7/85 31 hours | |||
85-09 . Specialists Physical security plan and implementing proce- | |||
2/11-15/85 33 hours dures for security and audits program, records | |||
and reports, testing and maintenance, locks, | |||
keys, physical barriers, security system power | |||
supply, lighting, assessment aids, access con- | |||
trol, detection aids, alarm stations, communi- | |||
cations, training and qualifications, security | |||
contingency plans and proposed 10 CFR 73.55 and | |||
73.67 plan commitments. | |||
85-10 Specialists Preoperational test program requirements and | |||
, 3/18-22/85 66 hours implementation; test procedure reviews; test | |||
' | |||
witnessing; open items; reactor coolant systen | |||
hydrostatic test; new fuel receipt and storage; | |||
l quality assurance and quality control; facility | |||
tours. | |||
85-11 Specialists Procedure review, test witnessing, and evalu- | |||
3/25-28/85 56 hours ation of the preoperational Integrated Leak Rate | |||
Test, Structural Integrity Test, and Local Leak | |||
Rate Test; facility tour. | |||
l | |||
l | |||
t | |||
i | |||
I. | |||
. _ _._ _._ _ _ __ _ _ _ __ _ _ . . _ _ . _ . _ . __ _ _ _ __ __._ | |||
. | |||
. | |||
' | |||
. | |||
8 I | |||
i | |||
i | |||
INSPECTION REPORT INSPECTION / ' | |||
l NUMBER AND DATES HOURS AREAS INSPECTED L | |||
85-12 Resident Primary cold hydrostatic test and Chemical Ad- | |||
3/18-4/22/85 222 hours dition Tank Drawdown test witnessing; event I | |||
followup; open items; potential significant : | |||
deficiencies; IE Bulletins; IE Information No- | |||
tices; steam generator "J" tube inspection; and | |||
; | |||
preparations for initial fuel receipt. | |||
85-13 Specialists Installation of safety-related electrical and | |||
4/8-12/85 102 hours instrumentation equipment; quality control | |||
documentation; training of personnel; status , | |||
of audits and findings. C | |||
85-14 Specialists Preoperational test program review; test proce- | |||
4/8-27/85 121 hours dural review, witnessing, and evaluation; open ! | |||
items; emergency diesel generator status; reac- ! | |||
tor coolant system cold hydrostatic test wit- i | |||
ness; new fuel receipt inspection and storage; | |||
l quality assurance and quality control inter- } | |||
j faces; facility tour. | |||
[ 85-15 Examiner Oral, written and simulator examinations for , | |||
i | |||
5/14-17/85 sixteen Senior R(actor Operators and five Reac- l | |||
l tor Operators. | |||
! | |||
l 85-16 Resident Observation of limited emergency exercise; event ! | |||
l 4/23-5/27/85 268 hours followup; auxiliary feedwater pump flushing; | |||
field welding; ultrasonic testing of low pres- | |||
sure safety injection system; and eddy current ' | |||
testing of a steam generator. | |||
l 85-17 Examiner Use of Millstone 3 simulator for NRC operator I | |||
3/25/85 licensing examinations, i | |||
( | |||
' | |||
85-18 Specialists Preoperational test program implementation; | |||
5/6-10/85 80 hours engineered safety feature test status; emergency i | |||
diesel generator status; pre-core hot functional l | |||
test status; test procedure review and verifi- ! | |||
cation; new fuel receipt, inspection and stor- | |||
age; turbine building hot functional test status; | |||
quality assurance and quality control; facility i | |||
tours. | |||
85-19 Specialists Preoperational status pertaining to radiation | |||
t 5/7-10/85 70 hours protection and radioactive waste management, l | |||
l | |||
including organization, personnel training and | |||
qualifications, facilities and equipment, and | |||
procodure development. | |||
I | |||
l | |||
# | |||
l | |||
l | |||
_ _ _ _ _ _ - - __ | |||
, | |||
" | |||
* | |||
, . | |||
1 | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
85-20 Specialists Safety-related pipe welding; Post Weld Heat | |||
5/13-17/85 37 hours Treatment of containment shell penetrations; | |||
reactor vessel clevis hard surfacing; review | |||
: of in progress work including welding; allega- | |||
tion followup; and review of service water clad | |||
l elbow leakage. | |||
85-21 Specialists Maintenance program; I&C program; and quality | |||
5/13-17/85 30 hours assurance and quality control interfaces. | |||
85-22 Specialists NRC independent measurements inspection using | |||
5/20-6/14/85 575 hours the Mobile Nondestructive Examination Laboratory | |||
on selected safety-related piping fabricated | |||
to ASME Code Section III, Classes 1, 2, and 3. | |||
l 85-23 Resident Open items; facility events; Type C leak rate | |||
! 5/20-6/14/85 95 hours testing; and vital batteries. | |||
! | |||
85-24 Specialists Preoperational test program implementations; | |||
5/20-24/85 67 hours emergency diesel generator status; pre-core hot | |||
functional test status; test procedure review | |||
and verification; new fuel receipt, inspection | |||
i | |||
' | |||
and storage; quality assurance and quality con- | |||
trol interfaces; facility tours. | |||
85-25 Specialists Preoperational test program; test procedure re- | |||
6/24-27/85 82 hours views and witnessing. Emergency diesel genera- | |||
i 8/8-11/85 tor status; quality assurance and quality con- | |||
trol; end identification of new EDG components. | |||
l | |||
85-26 Resident Steam generator "J" tube modifications; eddy | |||
5/28-8/8/85 (31 hours current testing and tube plugging; preparations | |||
for Containment Structural Integrety Test; IE | |||
Bulletins; Preoperational testing. | |||
85-27 Specialists Prooperational test program; EDG status; pro- | |||
6/3-7/85 102 hours posed technical specifications status and re- | |||
view; test procedure review and verification; | |||
! engineered safety features tests; pre-core hot | |||
l functional tests; valve problems; turbine | |||
l building hot functional tests; containment HVAC; | |||
l new fuel receipt, inspection and storage; qual- | |||
I | |||
ity control and quality assurance interfaces; | |||
facility tours. | |||
85-28 Specialists Installation of safety-related instrumentation | |||
6/3-7/85 34 hours and associated control circuits. | |||
1 | |||
! | |||
I | |||
- . | |||
. | |||
. _ . _ .. . _ _ _ _ . _- _ _ . -- - _- .- -_ | |||
- | |||
. | |||
. | |||
* | |||
10 | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
85-29 Specialists Engineering Assurance In-Depth Technical Audit: | |||
5/28-29/85 inspection of the program preparation. | |||
85-30 Specialists Continuation of Preoperation Security Reviews; | |||
6/17-21/85 26 hours review of receipt, storage, and protection of | |||
new fuel. | |||
85-31 Specialists Engineering Assurance Program Technical Audit | |||
6/24-28/85 Implementation: inspection of program | |||
85-32 Specialists Followup of violations, unresolved and construc- | |||
8/8-12/85 58 hours tion deficiency reports; verification of FSAR | |||
commitment to Reg. Guide 1.94 for exemptions | |||
from concrete testing. | |||
85-33 Specialists Containment leakage testing program: review, | |||
7/5-15/85 106 hours witnessing and evaluation of integrated leak | |||
rate test, structural integrity test, and local | |||
leak rate test, and online primary containment | |||
leakage monitoring; facility tour. | |||
85-34 Specialists Installation of safety-related electrical /in- | |||
7/8-12/85 68 hours strumentation components and associated cir- | |||
cuits; quality control documentation and open | |||
items. | |||
85-35 Resident Preoperational inspections; repairs to condenser | |||
7/9-8/12/85 201 hours air piping; auxiliary feed pump endurance runs; | |||
allegations; electrical termination for diesel | |||
generators; event follow up; steam generator | |||
wet layup; status of reactor water level moni- | |||
toring; and status of Safety Paramater Display | |||
System. | |||
85-36 Specialists QA/QC administration; audit program; procurement | |||
7/22-26/85 111 hours program; receipt, storage and handling program; | |||
record storage program and document control | |||
program. | |||
85-37 Contractor inspection / evaluation of specific aspects of | |||
l 7/8-19/85 240 hours licensee's Probabilistic Safety Study to assess | |||
l | |||
whether significant discrepancies exist between | |||
l Technical Specifications, the Final Safety An- | |||
l alysis Report, the Safety Evaluatien Report, | |||
' | |||
and the as-built configuration. | |||
l | |||
l | |||
l | |||
l | |||
-_ - - - - _ _ _ . - - -- _. ~ _ - . ._ _ - - - | |||
l . | |||
- | |||
, * | |||
[ | |||
11 | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
85-38 Specialists Preoperational test program procedure review, | |||
7/15-19/85 44 hours test witnessing and evaluation; ESF test status; | |||
l | |||
Emergency Diesel Generator status; Quality As- | |||
surance and Quality Control; ESF valve testing. | |||
85-39 Specialists Emergency Planning Implementation Appraisal; | |||
1 7/22-26/85 organization, training, emergency facilities, | |||
! equipment and emergency implementing procedures. | |||
85-40 Examiner NRC licensee meeting to discuss operator lic- | |||
7/8/85 ensing examinations for Millstone 3. ' | |||
85-41 Specialists Quality records and work activities related to | |||
8/5-9/85 35 hours the inspection and testing of safety-related | |||
electrical equipment and open items. | |||
85-42 Specialists Chemistry and radioactive effluent control pro- | |||
8/5-9/85 76 hours grams organization, and staffing, training and | |||
qualification facilities, equipment, plans, and | |||
procedures. | |||
85-43 Specialists Preoperational test program procedure review, | |||
8/5-9/84 87 hours test witnessing, and evaluation; review status | |||
emergency diesel generators; engineered safe- | |||
guards test status; quality assurance and | |||
quality control. | |||
85-44 Examiners Oral, written, and simulator examinations for | |||
Senior Reactor Operators and Reactor Operators. | |||
! 85-45 Examiners October 1985 examinations, outside the SALP | |||
assessment period. | |||
85-46 Specialists Open item followup; ASME Code N-5 certification | |||
l 8/12-16/85 226 hours program; stress reconciliation program, struc- | |||
tural steel bolting; welding (structural steel, | |||
pipe support, tack weld); preservice inspection | |||
data for RCS piping; applicants response to IE | |||
l Bulletin 79-02. | |||
85-47 Specialist Dosimetry program: open items, organization | |||
8/5-9/85 75/25 hours ** personnel selection, facilities and equipment, | |||
calibrations, dose assessment, quality assur- | |||
ance, documentation and recordkeeping, indepen- | |||
dent performance. | |||
l | |||
. | |||
. | |||
. | |||
* | |||
12 | |||
INSPECTION REPORT INSPECTION / | |||
NUMBER AND DATES HOURS AREAS INSPECTED | |||
85-48 Specialists Continuation of preoperational security reviews; | |||
8/5-9/85 25 hours review of receipt, storage and protection of | |||
new fuel, review of proposed consolidated site | |||
' | |||
security. | |||
85-49 Specialists Operational Quality Assurance Program for design | |||
8/19-23/85 107 hours changes and modifications, tests and experiments, | |||
measuring and test equipment, and Safety Com- | |||
mittee activities. | |||
85-50 Specialists Allegation and open item followup in electrical | |||
8/12-16/85 24 hours area. | |||
85-51 Specialists Preoperational test program OIL witnessing of | |||
8/19-9/13/85 184 hours Engineered Safeguards Features (ESF) tests, | |||
reactor plant component cooling water pump per- | |||
formance test, normal service station transfor- | |||
mer test, and the 24 hour testing of Emergency | |||
Diesel Generator EDG-3; test result evaluation; | |||
and assessment of EDG status. | |||
85-52 Resident Review of Main Condenser Structural | |||
8/13-9/23/85 238 hours Reports, diesel generator reliability, Three | |||
Mile Island items, main steam indication | |||
and cable repair, Safety Evaluation Report | |||
Items, prevention of cable damage, | |||
potentially significant deficiencies and | |||
open items. | |||
85-53 Specialists Capability to shutdown plant in event of design | |||
8/19-9/23/85 172 hours basis fire; emergency lighting; reactor coolant | |||
pump oil collection system. | |||
** - Site inspection; Millstone 3 one-third of total hours. | |||
i | |||
i - | |||
_ _ -_ | |||
. | |||
. | |||
. | |||
* | |||
13 | |||
TABLE 4 | |||
ENFORCEMENT DATA | |||
(September 1, 1984 - August 31, 1985) | |||
MILLSTONE NUCLEAR POWER STATION, UNIT 3 | |||
A. Number and Severity level of Violations and Deviations | |||
1. Severity Level | |||
Severity Level I 0 | |||
Severity Level II 0 | |||
Severity Level III 0 | |||
Severity Level IV 11 | |||
Severity Level V 2 | |||
Deviations _1 | |||
14 | |||
B. Violations and Deviations vs. Functional Area | |||
Severity Level | |||
Functional Area IV V Deviations | |||
A. Operations 0 0 0 | |||
B. Radiological Controls 0 0 0 | |||
C. Maintenance 0 0 0 | |||
D. Surveillance 0 0 0 | |||
E. Preoperational Testing 3 0 0 | |||
F. Fire Protection 0 0 1 | |||
G. Emergency Preparedness 0 0 0 | |||
H. Security 0 0 0 | |||
I. Construction 8 2 0 | |||
J. Licensing Activities 0 0 0 | |||
TOTAL 11 2 1 | |||
. . | |||
, ., | |||
14 | |||
C. Listing of Violations and Deviations | |||
SEVERITY FUNCTIONAL | |||
REPORTS DATES SUBJECT REFERENCE LEVEL AREA | |||
84-20 9/30-11/10/85 Failure to maintain Appendix B IV I | |||
control of low hydrogen Crit. IX | |||
welding electrodes | |||
84-23 10/22-26/85 Failure to follow elec- Appendix B V I | |||
trical installation Crit. V | |||
procedures | |||
85-04 2/19-3/1/85 Failure to translate Appendix B IV I | |||
3/11-22/85 class IE wiring design Crit. III | |||
requirements into docu- | |||
ments | |||
Failure to follow in- Appendix B IV I | |||
tructions for post- Crit. V | |||
wiring changes and | |||
document control | |||
Failure to establish Appendix B IV I | |||
measures to assure pur- Crit. VII | |||
chased equipment con- | |||
forms to procurement | |||
documents | |||
Failure to establish con- Appendix B IV I | |||
trols to prevent use of Crit. VIII | |||
incorrect / defective | |||
items | |||
Inspection program did Appendix B IV I | |||
not verify conformance Crit. X | |||
with design documents | |||
Failure to assure con- Appendix B IV I | |||
ditions adverse to Crit. XVI | |||
quality promptly identi- | |||
fled | |||
85-12 3/18-4/22/85 Failure to provide ade- Appendix B IV E | |||
quate procedure for Crit. V | |||
testing and flushing | |||
85-16 4/23-5/27/85 Failure to provide ade- Appendix B. IV E | |||
quate procedure for Crit. V | |||
flushing | |||
. _ _ . _ ._. . _ . . - - - _ _ _ _ _ _ . - - . . _ _ - . _ _ . _ _ - - _ _ _ . _ _ _ _ _ _ _ _ _ . - ~ | |||
! - | |||
. . | |||
; . . | |||
4 | |||
1 | |||
l 15 | |||
i- | |||
SEVERITY FUNCTIONAL | |||
: REPORTS DATES SUBJECT REFERENCE LEVEL AREA | |||
l | |||
85-22 5/20-6/14/85 Failure to properly con- Appendix B. IV I | |||
4 | |||
! | |||
trol nondestructive ex- Crit. IX | |||
aminations | |||
% | |||
Failure to properly Appendix B V I | |||
identify welds on con- Crit. V | |||
; trol drawings * | |||
i | |||
j 85-23 5/20-6/14 Failure to provide ade- Appendix B IV E , | |||
* | |||
quate procedure for Crit. V 4 | |||
; flushing | |||
85-33 8/19-8/23 Failure to provide hy- Fire Protec- DEV F ! | |||
, drogen recombiner area tion Evalu- | |||
i | |||
' | |||
and several floor levels ation Report | |||
of main steam valve en- | |||
closure with fire detec- | |||
, tion and steel members | |||
; of ESF building walls | |||
: not fire proofed. | |||
l | |||
4 | |||
: | |||
I | |||
4 | |||
4 | |||
2 | |||
4 | |||
c | |||
t | |||
! | |||
: | |||
' | |||
i | |||
! | |||
! | |||
4 | |||
l | |||
l | |||
i | |||
: | |||
; | |||
' | |||
. . - . , _ . _ _ _ _ . . . . _ _ _ . . . . _ . . _ . _ . _ - - _ _ - - . _ . . _ - -- . . _ - _ _ _ _ _ . . - _ _ . , . - _ . _ _ . | |||
. | |||
. | |||
. - | |||
NORTHEAST UTILITIES o.n. ome...s.e.nsu..,e.mn conn.ci,cui | |||
.7.C... . .![ .*[N2. | |||
I.. "I,$' ,C | |||
. | |||
P O BOX 270 | |||
k L J s.....u.......,4... H A ATFO AD. CONN ECTICUT 06141-0270 | |||
(203) C6s s000 | |||
September 17,1985 | |||
Docket No. 50-423 | |||
B11640 | |||
Mr. R. W. S tarostecki, Director | |||
SALP Board Chairman | |||
Division of Project and Resident Programs | |||
U. S. Nuclear Regulatory Comrnission | |||
631 Park Avenue | |||
King of Prussia, PA 19406 | |||
Gentlemen: | |||
Millstone Nuclear Power Station, Unit No. 3 | |||
Svstematic Appraisal of Licensee Performance (SALP) | |||
As we have stressed in previous meetings with you regarding the SALP program, | |||
Northeast | |||
of Utilities (NU) places high priority on achieving excellence in all areas | |||
performance. | |||
performance in those The SALP ratings provide NU with one assessment of our | |||
areas of activity evaluated by that program and | |||
achievement of superior ratings provides an indication that our management | |||
controls are functioning properly and that our primary corporate goal of striving | |||
for excellence in the maintenance of nuclear safety is being realized. | |||
In the past, we have met to discuss the SALP ratings and NRC's evaluation of our | |||
strengths and potential areas for improvement subsequent to publication of the | |||
initial NRC SALP report. As a result, the initial reports have at times not | |||
considered important information that otherwise could have been strengthened | |||
by an exchange between ourselves and NRC. To maximize the potential for full | |||
consideration of relevant views, we are taking this opportunity to provide some | |||
of | |||
theour | |||
pastperspectives | |||
year. on our level of performance on Millstone Unit No. 3 during | |||
We believe it necessary for us to interact positively with the Staff whenever it is | |||
given the finite resources at the disposal of both NU and the | |||
the interest of further improving the regulatory process and assuring that | |||
through discussion, all aspects of a proposed action are understood and | |||
considered by NRC and NU. A significant f actor which should be considered in | |||
assessing licensee performance is NU's consistent atternpts to further the depth | |||
and quality of the exchange with the regulators, both in terms of interacting | |||
with the NRC and participating actively in efforts to disseminate needed | |||
information to the industry. Northeast Utilities executive management is active | |||
in numerous industry initiatives, having made presentations at public meetings | |||
before the Commission as well as meeting with individual Commissioners where | |||
appropriate. The NU management team is active in, and in some instances chair, | |||
various industry groups addressing a broad range of nuclear issues. We also | |||
.;Q +4. J dl Y'' | |||
- ... .- .- . . . - . _ . - . -- ._. .- . _ _ . _ _ _ _ . | |||
. . | |||
. * | |||
2 | |||
consistently attempt to further improve the quality of the regulatory proce | |||
taking the opportunity to provide comments on proposed rulemakings and g | |||
letters as evidenced in the examples provided in Attachment I. | |||
During this SALP assessment period all major construction and test milestone | |||
have been met to support the November,1985 fuel 16ad date. | |||
As of the end of | |||
the management target. August, the Millstone Unit No. 3 project is 98 | |||
that have occurred during this SALP period are as follows:Some of the | |||
o | |||
Completed Steam Generator Hydrostatic Test | |||
o | |||
o Completed Reactor Coolant System Hydrostatic Test | |||
o Completed Millstone Unit No. 3 Emergency Drill | |||
o Completed Structural Integrity Test and integrated Leak Rate Test | |||
o | |||
Completed Engineering Safety Features Test | |||
Conducting Turbine Building Hot Functional Test | |||
In June,1985 a!! system turnovers were completed and any building turnove | |||
thatload | |||
fuel remain date.will be completed on a schedule that supports the November ,1985 | |||
Licensing activities during this SALP period have been at a high Thelevel. | |||
Mllistone Unit No. 3 Safety Evaluation Report (SER) was issued in July,1934 | |||
The SER | |||
conditions. identified 19 open items, 70 confirmatory items and 7 licensin | |||
Most of these items have been resolved and have been or wi | |||
documented in SER supplements. The remaining issuer, have resolution sched | |||
which sup | |||
meetlngs, port the November,1985 fuel load date. During this period numerous | |||
site audits and reviews and conference calls have been held | |||
licensing activities. to suppor | |||
, Also, during thh period several amendments to the FSAR | |||
and to the ER have been submitted to the NRC. NU's responses to SER iss | |||
well as NRC questions resulting from site audits or reviews, show high-leve | |||
and responsiveness to NRC initiatives. management involvement, clea | |||
demonstrating this are provided in Attachment I to this letter. Examples of indivi | |||
Regarding day-to-day licensing activities, our licensing staff is consiste | |||
responsive to the NRC Licensing Project Manager. | |||
As a result of a | |||
been made to improve the interface with NRC by estab ; | |||
contact within the NU !! censing staff. This has centralized and helped prioritize | |||
the many day-to-day licensing activities occurring between the NRC Lice | |||
routinely Manager and our licensing staff. The NRC Licensing Project Mana | |||
Project | |||
> | |||
j NU's licensing activity status and schedule for response to | |||
! | |||
remaining SER ltems and identified licensing actions to OL issuance. | |||
! | |||
! | |||
l | |||
l \ | |||
, , | |||
. | |||
, .. | |||
-3- | |||
In general, we believe that this information may prove useful in your | |||
deliberations | |||
you when the | |||
have any questions, SALP | |||
please contactBoard | |||
us. convenes for Millstone Unit No. 3. | |||
Should | |||
Very truly yours, | |||
- | |||
LE ('uk) c | |||
J. F. Opeka 'l | |||
_ _ . | |||
Senior Vice President | |||
I | |||
_ _ _ 'e - | |||
t) | |||
By: E.M roczka N | |||
Vice Pre ent | |||
cc E. L. Doolittle, Licensing Project Manager, NRR | |||
E. B. McCabe, Chief, Reactor Projects Section 3B, DPRP | |||
T. E. Murley, Regional Administrator | |||
T. Rebelowski, Senior Resident inspector, Millstone Unit No. 3 | |||
l | |||
1 | |||
i | |||
; | |||
_ _ | |||
.. . | |||
., - | |||
ATTACHMENTI | |||
Inputs to SALP Evaluation Process | |||
The following items provide summary examples of some of the meetings, letters | |||
and other | |||
process activities | |||
for Millstone Unit which | |||
No. 3. we believe are relevant to the SALP evalu | |||
The list is not a complete compilation of | |||
pertinent issues and documents and is not intended to suggest that other items | |||
not discussed herein are less important. | |||
- | |||
The NRC staff performed Seismic Qualification Review Team (SQRT) | |||
and Pump | |||
March and Valve Operability (PVORT) Audits during the week of | |||
4,1985. | |||
At the audit exit meeting, the Staff praised the | |||
responsiveness and diligence of NNECO personnel in | |||
questions | |||
audit. raised by the Staff during the document review phase of theanswering | |||
The Staff indicated that all questions raised during the audit | |||
were successfully resolved. The Staff observed that NNECO has a good | |||
qualification program and a thorough understanding of what is required | |||
to maintain seismic qualification throughout the life of the plant. | |||
* | |||
During the Construction A n sal Team (CAT) Inspection, conducted | |||
between February 19 and | |||
a 22,1985, four Construction Weaknesses | |||
were noted and nubsequeo .. ' ihntified in the Inspection Report (50- | |||
423/85-04). | |||
Although no specific response was required by the | |||
inspection Report, NU provided the NRC our planned course of action | |||
for each of these items in a letter dated July 11, 1985. | |||
We | |||
subsequently received a request from NRC to provide a response to | |||
these weaknesses and to six violations that were identified separately. | |||
Our advanced response to the Identified weaknesses is an example of | |||
Millstone 3 management's commitment to take an aggressive attitude in | |||
responding to NRC concerns and proposing timely corrective actions. | |||
We subsequently responded to the | |||
docketed iollow-up letter. violations in an appropriately | |||
* | |||
On May 21,1985, a site visit was conducted by the NRC Radiological | |||
Assessment Branch (RAB). The purpose of the visit was to verify FSAR | |||
staffing, radiation monitoring and plant design feature | |||
maintain radiation exposures ALARA. Various aspects of the Radiation | |||
Protection Program and the Health Physics Organization were discussed | |||
with the Health Physics Supervisor and a tour of tne plant was | |||
conducted. The NRC reviewer was very satisfied with the Radiation | |||
Protection Program and the facilities. | |||
The reviewer hdicated that | |||
NNECO had qualified personnel and was well prepared to implement its | |||
Radiation Protection Program. | |||
* | |||
On June 5,1985 NNECO was granted a schedular exemption to General | |||
Design Criterion (GDC) 4 allowing us to forego the installation of pipe | |||
whip restraints for primary loop piping. This exemption was granted | |||
! based on information provided by NU, Westinghouse and other industry | |||
and agency studies which allowed the NRC Staff to conclude that "the | |||
placement of pipe whip restralnts and jet impingement shields degrades | |||
plant safety, reduces the accessibility for and effectiveness of in- | |||
! | |||
! | |||
< | |||
T | |||
, 4 0 | |||
. .. | |||
-2- | |||
l | |||
} | |||
} | |||
! | |||
service inspection, increases in-service inspection radiation dosages, | |||
and adversely affects construction and maintenance economics." The | |||
NRC | |||
Federal published the proposed modification to GDC 4 in a July 1,1985 | |||
Register notice. | |||
- | |||
At NU's option, since this is not a licensinj; requirement, a simulator | |||
training and examination program was developed and implemented for | |||
Millstone Unit No. 3. The Millstone Unit No. 3 simulator was deli | |||
to the site in December 1984. Following installation, the simulator | |||
l | |||
entered | |||
1985. a verification test phase which was completed on January 15, | |||
From January 15, to February 11, 1985, the simulator was used | |||
to test the training program curriculum and to validate the simulator | |||
against this curriculum. On February 11,1985 training on the simulator | |||
commenced. Each cold license candidate receives 5 weeks of simulato | |||
training which includes 125 hours of actual simulator experience, along | |||
with 75 hours of classroom training. The accelerated program | |||
cuirainated in the administering of the NRC operator licensing exams | |||
on | |||
on Maythe simulator | |||
13,1985. for our first class of cold license candidates, beginning | |||
examination program is an example of NU's proactive stan | |||
responsiveness to NRC initiatives. | |||
- | |||
An a!!egations | |||
the program was developed and implemented. It consists of | |||
following elements: | |||
- | |||
A full-time administrator has been appointed for providing | |||
overall coordination for allegation reviews. He will report | |||
directly to our Vice President-Generation Engineering and | |||
Construction and is located on site. | |||
- | |||
A visible, on-site facility designated the Quality Concern | |||
Office (QCO) has been established where allegations | |||
regarding project safety can be expressed with an individual | |||
independent of Project Management with a guarantee of | |||
anonymity. | |||
stationed at A full-time consultant has been hired and is | |||
the site to work with us in establishing our | |||
allegations program. This consultant has been involved with | |||
worker allegations in the past and is familiar with the | |||
processes being used at other sites. | |||
- | |||
An Allegation Review Team (Review Team) has been | |||
established to review safety concerns raised and to determine | |||
whether or not there is any basis for the allegation. The | |||
Review Team responsibilities are delineated in a specific | |||
project procedure as well as in a specific charter which has | |||
been established. | |||
The Review Team is comprised of key | |||
management personnel who have a wide range of backgrounds | |||
and extensive experience in the nuclear industry. | |||
- | |||
An Independent Review Board is being assembled to conduct | |||
an independent and detailed investigation of any a!!egation | |||
' | |||
.. . i | |||
. .. .. | |||
l | |||
l | |||
i | |||
! | |||
-3- | |||
which has been deterrnined by the Resiew Team to | |||
potentially have substance. This Board will be comprised of | |||
one or more individuals who have expertise an the areas of | |||
labor relations, law, nuclear construction, and quality | |||
assurance / quality control. | |||
. | |||
NRC regulations do not require that an emergency preparedness | |||
exercise be performed for Millstone Unit No. 3 prior to receipt of a | |||
full-power operating license since the operating license for Millstone | |||
Unit No. 3 will not be the first operating license for the Millstone site. | |||
Nonetheless, an onsite emergency preparedness drill for Millstone Unit | |||
No. 3 was conducted on May 15, 1985 to validate the Millstone Unit | |||
No.3 specific aspects of the Millstone Nuclear Power S tation | |||
Emergency Plan. This drill is illust ative of our efforts (beyond those | |||
necessary to obtain an operating license) to assure ourselves that we | |||
are ready to operate Millstone Unit No. 3 in a manner that will | |||
adequately protect the public health and safety. The Millstene Unit | |||
No. 3 drill was quite successful and demonstrated the readiness of our | |||
organization to respond to an emergency at Millstone Unit No. 3. | |||
. | |||
The NRC 5%ff conducted an audit of the Safety Parameter Display | |||
System (SPDS) for Millstone Unit No. 3 on July 29-30,1985. Although a | |||
formal audit report has not yet been received, the NRC Staff indicated | |||
at the ex t meeting that our overall program was quite good and that | |||
they were impressed with the type of program which we ' had | |||
implemented. On a related matter, unsolicited responses to several | |||
NRC concerns were formally provided to the NRC two (2) menths | |||
before the SPDS audit in an attempt to expedite resolution of; these | |||
items during the audit. | |||
- | |||
In the resolution of fire protection issues we believe we have exhibited | |||
a clear understanding of the issues and conservative, sound technical- | |||
approaches are routinely employed. For example, the informatich | |||
provided in support of the suppression systems in the cable spreacing | |||
area and other areas was judged by the NRC staff to be a valid and | |||
acceptable justification for the existing design. Other examples of our | |||
pro-active approach to addressing issues are the ' docketed submittals | |||
and meetings with the NRC fire protection reYiewer Well in advance of | |||
the Fire Protection Audit. We identified potential deviations to the | |||
NRC along with thorough technical justifications in advance to resolve | |||
them without waiting for the audit to be conducted. The NRC Firs | |||
. | |||
Protection Audit for Millstone Unit No. 3 was conducted at the site | |||
from August 19 through 23,1985. The audit was successful in that NRC | |||
questions were promptly addressed and there were very few significant | |||
items requiring followup af ter the audit. | |||
The staff observed that the | |||
engineering analysis for safe shutdown of the plant was one of the best | |||
observed, to date. | |||
* | |||
There has been a high level of NU management involvement noted by | |||
the auditors for all of the NRR audits conducted at the site. A high | |||
level of management review and approval of all correspondence to the | |||
.<>> | |||
.s.. | |||
-4- | |||
NRC is procedurally required at NU, this ensures a consistently clear | |||
licensee understanding and reponsiveness to NRC initiatives. | |||
- | |||
In letters dated October 26, 1984 and February 19, 1985, NU provided | |||
documentation of our assurance that Millstone Unit No. 3 had been | |||
designed and constructed in accordance with applicable requirements | |||
based on Stone & Webster Engineering Corporation (SWEC) Engineering | |||
Assurance (EA) Program, our strong Quality Assurance Program and | |||
other verification programs. The NRC concurred on April 17,1985 that | |||
a separate Independent Design Verification Program (IDVP) or an | |||
Integrated Design Inspection (IDI) conducted by the Staff was not | |||
necessary to achieve design assurance for Millstone Unit No. 3 and | |||
approved SWEC's EA audit as an acceptable alternative to a third party | |||
review performed at the end of design and construction efforts. | |||
We feel the above examples serve to provide evidence of some of NU's efforts | |||
and accomplishments in the construction, licensing, and testing of Millstone Unit | |||
No. 3 during this SALP period. | |||
. | |||
}} |
Latest revision as of 02:01, 11 December 2021
ML20151P168 | |
Person / Time | |
---|---|
Site: | Millstone |
Issue date: | 11/04/1985 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20151P154 | List: |
References | |
50-423-85-99, NUDOCS 8601030319 | |
Download: ML20151P168 (48) | |
See also: IR 05000423/1985099
Text
__
't Y
,
%
-U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-423/85-99
-
NORTHEAST NUCLEAR ENERGY COMPANY (NNECo)
MILLSTONE NUCLEAR POWER STATION, UNIT 3
ASSESSMENT PERIOD: SEPTEMBER 1, 1984 - AUGUST 31, 1985
BOARD MEETING DATE: NOVEMBER 4, 1985
8601030319 851227
gDR ADOCM 0 3'
p V
TABLE OF CONTENTS
PAGE
I. INTRODUCTION.......................................................... 1
A. Purpose and 0verview.....................'........................ 1
B. SALP Review Board and Attendees.................................. 1
C. Background....................................................... 1
II. CRITERIA.............................................................. 4
.III. SUMMARY OF RESULTS.................................................... 5
IV. PERFORMANCE ANALYSIS...... ............................... ........... 7
A. Operations Support............................................... 7
B. Radiological Controls............................................ 10
~C. Maintenance............................. ......... .............. 12
D. Surveillance............ ........................................ 14
E. Preoperational Testing........................................... 16
F. Fire Protection and Housekeeping................................. 19
G. Emergency Preparedness........................................... 21
H. Security......................................................... 22
I. Construction..................................................... 24
J. -Licensing Activities.... ........................................ 28
V. SUPPORTING DATA AND SUMMARIES......................................... 30
A. Construction Deficiency Reports.. ............................... 30
B. Investigation Activities......................................... 30
C. Escalated Enforcement Actions.................................... 30
0. Management Meetings.............................................. 30
TABLES
. TABLE 1 - Construction Deficiency Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
TABLE 2 - Inspection-Hours Summary......................................... 4
TABLE 3 - Inspector Activities (Tabulation of Inspection Reports).......... 5
TABLE 4 - Enforcement Data................................................. 13
'
f '
I. INTRODUCTION
A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an
integrated NRC staff effort to periodically collect observations
and evaluate licensee performance. SALP objectives are to improve
the NRC Regulatory Program and licensee performance.
This SALP differs substantially in emphasis from previous Millstone 3
SALPs. Most construction activities are now combined into one
functional area. Functional areas were added to address aspects
related to future plant operations. The puroose was to focus this
one year SALP (9/1/84 - 8/31/85) heavily on operational readiness and
operational performance, with post-SALP period observations included
where pertinent.
The SALP evaluation criteria are discussed in Section II and were
applied using the " Attributes for Assessment of Licensee Performance"
B. SALP Review Board and Attendees
SALP Review Board Members
R. Starostecki, Director, Division of Reactor Projects (DRP), Chairman
S. Ebneter, Director, Division of Reactor Safety (DRS)
E. Wenzinger, Chief, Projects Branch No. 3, DRP
L. Bettenhausen, Chief, Operations Branch, DRS
R. Bellamy, Chief, Emergency Preparedness and Rad.ation Protection
Branch, Division of Radiation Safety and Safeguards (DRSS)
E. McCabe, Chief, Reactor Projects Section 3B, DRP
T. Rebelowski, Senior Resident Inspector, Millstone 3
E. Doolittle, Licensing Project Manager, NRR
Other Attendees
K. Ferlic, Project Engineer, DRP
R. Summers, Project Engineer, DRP
-
. C. Background
-
1. Licensee Activities
During this SALP period, the thrust of activities shifted from
construction towards preoperational activities. One hundred
nine systems were " turned over" from construction to operations
t i
'2
for test performance, and 237 of the 238 systems had been turned
over by the end of the SALP period. Also, eight major mile-
stones were completed (plant on permanent power, Reactor Coolant
System hydrostatic test, Steam Generator hydrostatic test, fuel
receipt, emergency drill, Containment Structural Integrity and
Integrated Leak Rate Test, Turbine Building Hot Functional Test
to the capacity of the boiler, and Engineered Safety Features
Tests). The craft staffing decreased from approximately 3200 to
about 1400.
The licensee considered Millstone 3 to be approximately 98%
complete as compared with 88'; at the end of the previous SALP
period. (No NRC estimate of completion status was made.)
Northeast Utilities' current estimate for fuel loading is
November 1985. The Integrated Hot Functional Testing which is
scheduled for September / October 1985 is critical to achieving
this date. Equally important is generation and implementation
of plant procedures and qualification of the operating staff.
After the SALP period, the integrated hot functional test (IHFT)
was begun on September 27.
2. Inspection Activities
One NRC Senior Resident Inspector was assigned throughout the
SALP period. Resident Inspector assistance was provided by the
Millstone 1/2 Resident Inspector until a full time Resident
Inspector was assigned to Millstone 3 in August 1985. Team
inspections were conducted by a Headquarters Construction
Assessment Team (CAT), a Technical Specifications Review Team,
an NDE Independent Measurements Team, a Fire Protection Team
(including safe shutdown capability), an allegations Review
Team,and an as-built review team (at the end of the assess-
ment period). There was also an Environmental Qualification
inspection and numerous NRR visits to evaluate SER concerns.
The NRC inspection effort during the period totalled 7723 hour0.0894 days <br />2.145 hours <br />0.0128 weeks <br />0.00294 months <br />s:
5523 hours0.0639 days <br />1.534 hours <br />0.00913 weeks <br />0.0021 months <br /> were by resident and region-based inspectors; and
2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> were for the CAT inspection. The distribution of
inspection hours is shown in Table 2. Inspection activities and
enforcement data are summarized in Tables 3 and 4, respectively.
Quality assurance was an integral element of all inspections
performed during the assessment period. In addition, two
inspections were devoted specifically to the QA/QC program.
l
l
i
3
l
3. Other Activities
On September 10, 1984 the ACRS reported to the NRC Chairman
that, subject to resolution of open NRC items and to the
satisfactory completion of construction, staffing, and
preoperational testing, the ACRS believes that there is
reasonable assurance that Millstone 3 can be operated up to 3411
Mwt without undue risk to public health and safety.
The Millstone 3 simulator is operational and has been used for
the initial operator licensing process.
Public officials in Waterford, Connecticut have been routinely
informed of major Millstone 3 evolutions by utility officials
and separately by the senior resident inspector.
The Safety Evaluation Report (SER), NUREG-1031 was issued by NRR
during July 1984. Supplements 1 and 2 were issued in March 1985
and September 1985. Supplement 3 was in draft form at the end
of the assessment period.
On March 22, 1985, the applicant established a more formal and
comprehensive allegation program after discussions of the need
for this with Region I.
On June 5, 1985, an exemption was granted to General Design
Criterion 4, allowing NNECo to forgo the installation of pipe
whip restraints for primary loop piping.
The 29 Construction Deficiency Reports (CDRs) for this
assessment period are summarized in Table 1. Three of these
have currently been determined not to be reportable by the
licensee.
.
l I
4
II. CRITERIA
Licensee performance is assessed in prescribed functional areas based on
whether the facility is in a construction, preoperational, or operational
phase. Other areas may be added as appropriate. Each area normally repre-
sents aspects significant to. nuclear safety and the environment. One or more
of the following criteria were applied in each area:
1. Management involvement and control in assuring quality.
2. Approach to resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Reporting and analysis of reportable events.
6. Staffing (including management).
7. Training effectiveness and qualification.
Each area was classified into one of the following three categories.
1
Category 1. Reduced NRC attention may be appropriate. Licensee management
attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that there is a high
level of performance wi+3h respect to construction and operational safety.
Category 2. Normal NRCtattention should be maintained. Licensee management
attention and involvemeht are evident and are concerned with nuclear safety;
licensee resources are adequate and reasonably effective so that there is
satisfactory performance with respect to construction and operational safety.
Category 3. Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear safety,
but weaknesses are evident; licensee resources appear to be strained or not
effectively used so that there is minimally satisfactory performance with re-
spect to construction and operational safety.
The SALP Board also as~sessed each functional area to compare the licensee's
performance for the last quarter of the assessment period to that during the
entire SALP period in order to determine the recent trend for each functional
area. The trend categories are:
Improving. Licensee performance has generally improved over the last
quarter of the current SALP ass.:ssment period.
Y
Consistent. Licessee performance has remained essentially constant over
the last quarter f the current SALP assessment period.
Dy: lining. Licendae performance has generally declined over the last
quarter pf the current SALP assessment period.
l 5
5
III. SUMMARY OF RESULTS
Category Last Category This
Period Period Recent
Functional Area (9/1/83-8/31/84) (9/1/84-8/31/85) Trend
A. Operations Support N/A 2 Consistent
B. Radiological Controls N/A 2 Consistent
C. Maintenance N/A 2 Consistent
D. Surveillance N/A 3 Consistent
E. Preoperational Testing 1 1 Consistent
F. Fire Protection & Housekeeping N/A 1 Consistent
G. Emergency Preparedness N/A 2 Consistent
H. Security N/A 1 Consistent
I. Construction 1 1 Consistent
J. Licensing 2 2 Consistent
Overview
During this transitional period, licensee performance has generally been
characterized by management involvement in facility activities, strong QA/QC
presence, commitment to training, appropriate corrective action, responsive-
ness to NRC concerns, and technical competence. Construction quality and
preoperational testing has been good. The licensee has been effective at
maintaining control over contractor activities. Construction and preopera-
tional testing program development and staffing kept pace with activities
and the licensee generally anticipated changes in manning requirements.
Transitions to operating phase programs generally progressed smoothly, with
carryover from Millstone 1.and 2 being a substantive aid in the development
of Unit 3 programs. Resolution of fire protection issues was particularly
well done.
Problems identified included nondestructive examination inadequacies, minor
flooding incidents, failures on initial operator licensing examinations, and
slow development of procedures to support plant startup and operation. How-
ever, it was evident that, while the construction completion schedule was very
important to the applicant, safety considerations were resolved without sub-
ordination of quality to schedule.
I
_. -.
.
i 5
6
This assessment has not evaluated the licensee's organization as it will exist
during ascension to full power. Shift staffing and organizational changes
are expected to occur as Unit 3 becomes operational. Continued management
attention is needed to ensure a smooth transition.
Training Overview
The applicant's commitment to training has been high. As noted in the Mill-
stone 1/2 SALP (9/1/83 - 2/28/85), organizational training initiatives have
been notable and included an upgrading through training staff expansion in
size and authority. The licensee is providing simulators for all four
facilities and the Millstone 3 simulator is operational.
There was a high failure rate on-the initial licensed operator examinations
which can be attributed to the use of the simulator in the examination process
and'some lapses in the operations / training interface. After meetings with
the NRC and program revisions to resolve these lapses and increase simulator
usage, significant improvement in candidate performance was noted on the
second set of examinations.
Overall observation of work performance in all phases of plant activities in-
dicated a well trained and qualified work force. Few problems arose as a re-
sult of unqualified personnel or lack of training. Review of training records
to verify qualifications and receipt of training and retraining found the
records were complete and met program requirements. The effectiveness of
training will continue to be monitored after INP0 accreditation.
Quality Assurance Programs and Controls Overview
Management of Millstone-3 made an initial strong commitment to assure quality
and has maintained that commitment throughout the design, procurement, con-
struction, and preoperational phases. The training and knowledge of QA/QC
personnel was found acceptable during all phases. Staffing was generally
sufficient and adequate to conduct the QA/QC programs during the transition
from construction to operations. Management involvment has been clearly
evident in knowledge of QA/QC programs and their status, in onsite presence,
and in emphasis on corrective actions.
QA coverage for operations is to be based on acceptable programs in place at
Millstone 1 and 2. QA programs for operations, surveillance, and maintenance
have not been completed for Millstone 3. Their completion is dependent upon
completion of the procedures governing these activities.
QA violations which have occurred during this assessment period relate to the
broad spectrum of~ construction and preoperational activities involved in the
latter stages of facility construction. They do not indicate a breakdown in
quality programs or serious individual quality problems.
-- -- -
- . - - __
_ _ _ _ - _ _ . __ __ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - - .
c'
f
, 7
1
a t
i
i
IV. PERFORMANCE ANALYSIS
A. Operations Support (552 Hours, 7%)
This area addresses compliance with commitments and procedural re-
quirements, " turned-over" systems, reporting, staffing, engineering
support, design change and modification control, operator training,
and safety review committee activities. Fuel receipt, core load pre-
parations, operational aspects of testing, and onsite management of
j facility evolutions are also included.
l This area was under routine review by resident and region-based
inspectors throughout the assessment period. The analysis is based
! in part on review of operations-related aspects of inspections of
'
other Functional Areas and therefore involves a larger inspection .
4
basis than was allocated. !
'
Observation of control room activities found personnel knowledgeable
of their current assigned duties and responsibilities (e.g., response
to facility emergencies [ containment fire], manipulation of controls
during preoperational testing, hanging and removal of tags and
'
jumpers).
- A formal method of processing design changes and written administra-
! tive controls for controlling temporary modifications, jumpers, and ,
- bypasses, including controls for maintaining logs, was in place
, throughout the assessment period. These are the framework for con-
trol during operations and were effective during testing. Improve-
i ments have been made as deficiencies were found (e.g., changes to
jumper controls to establish a one time, unique tag number.) How-
,
ever, review of recent plant incident reports found multiple' tagging
problems, and administrative procedural controls should be reviewed
by the licensee to assure their adequacy for operations. Similarly,
licensee reviews should be performed to assure log keeping require-
4 ments and shift turnover protocols provide the mcre rigorous controls
needed for operation.
j Although no violations were cited in the operations area, several
-
aspects of three flooding events which occurred are related to opera-
tional controls. In a Service Building flooding event, the elapsed
..
'
time between the Shift Supervisor's release for test performance
(signifying the plant systems had been verified and ready for test)
, and the actual performance of the test was nine months with no re-
'
verification, and changed system status resulted in the event. In a i
- flooding event in the Control Building, failure to follow pro- i'
,
cedural controls resulted in isolating a section of service water
! pipe without emptying the pipe, which then was drained to the Control
Building. In an Engineered Safety Features Building flooding event,
. failure of to fol. low the automated work order tag requirements caused
flooding. Corrective action was initiated for each of these events.
i No similar events have occurred recently. However, operational
i
!
, , - --- - . . .- - - _ - - , - - _ - - - - - , - _ _ _ _ _ . _ _ _ - - - - -
/ I
8
controls and staff training in these areas should be re-reviewed by the
licensee prior to power operations to further safeguard against such
occurrences.
New fuel receipt occurred during the SALP period. Few problems were
encountered with fuel receipt, transfer, cleaning, storage, and docu-
mentation of these activities. Personnel involved were knowledgeable
of their responsibilities and of program and NRC license require-
ments. The licensee was cognizant of IE Information Notices concern-
ing fuel handling and had incorporated the recommended actions into
procedural, alarm, and interlock provisions. Personnel training was
found adequate in associated areas (fire protection, health physics,
security, preoperational testing). QA/QC coverage was provided.
Initial cold license operator examinations were conducted during May.
A second set of examinations in September immediately followed the
close of the SALP period. The simulator was used during the exami-
nations. The initial set of examinations resulted in an approxi-
mately 50% failure rate. The failures tended to be concentrated in
the simulator portion of the operating test. A meeting with the
candidates who failed the test was held by hRC supervisors to both
further understand what transpired and to explain how examiners ex-
pect the candidates to perform for upccming tests. Some of the
failures can be attributed to the fact that the simulator was very
recently placed in service and a comprehensive training program in-
tegrating the simulator was not in place for the candidates. Con-
sequently, the candidates may not have been sufficiently familiar
with both the simulator and the newly developed emergency operating
procedures. Further analysis of the operator training program indi-
cated that another weakness may be poor communications between the
training organization and the operations department in that there was
not a mutual understanding regarding operating philosophy and train-
ing needs, and the technical feedback required to assure that the
training desired is being achieved was lacking. An example was the
confusion generated regarding the role of the shift supervisor (SS)
and the supervising control room operator (SCRO) which caused some
problems in examining the senior reactor operator (SR0) candidates
since the two positions had divided responsibilities. The licensee
didn't anticipate that the SS may in fact not be in the control room
or readily available at all times and that the SCR0 may have to per-
form both functions. Consequently, emphasizing the duties of the
SCR0 as being a subset of SS duties resulted in confusion. This,
coupled with the problems between operations and training, resulted
in the high failure rate. A management meeting was held to discuss
these problems and, subsequently, the examinations conducted in Sep-
tember and the retake examinations given in October reflected an im-
provement in training and performance on the simulator. Meetings
were held between the NRC examiners and the candidates before the
second set of examinations to explain scope and conduct of the test.
1
-
.
o 8
9
,
Two events near the end of the assessment period are potentially
! significant. These were a condenser chloride intrusion and a diesel
fuel oil spill. The chloride intrusion was caused by corrosion of
bolts fastening the air reduction pipe to the condenser tube sheet.
[ During the recovery, examination revealed that additional bracing was
- needed. This was a major task. Management response was extremely
l thorough, technically sound, and provided long term corrective action
I
to both corrosion and bracing problems. Inspector review found that
licensee actions exceeded those required to fix the " broken part" and
demonstrated an aggressive " correct the root cause" approach. The
l second event was a fuel oil spill caused by over-filling the 'B' fuel
l storage tank while transferring from the 'A' fuel storage tank via
l the day tank. Procedural inadequacies appeared to be involved.
, Licensee investigation was in progress at the end of the SALP period.
!
However, concern for the fuel spill did not appear to be approached
with as thorough a " correct the root cause" approach as the chloride
intrusion. Although the fuel spill was much less important than the
'
chloride intrusion, it indicates that correcting root causes could
be more thoroughly ingrained in plant personnel.
Conclusion
Category 2, consistent.
Board Recommendation
l Licensee:
l 1. Review control of and training for jumpers and lifted leads,
l
tagging, log keeping, and shift turnover requirements to assure
controls are adequate for power operation.
2. Assess whether formal metheds and personnel orientation on
correcting root causes are sufficient.
NRC:
Conduct a special team inspection to assess the functional opera-
tional performance of the plant operating staff during the power
ascension program and/or early during operation at high power.
l
s
,
l
, .
8
t
10
B. Radiation Control (181 Hours, 2*4)
Preoperational inspections of radiological controls were initiated in
th's SALP period. Programs reviewed were radiation protection, radio-
active waste management, radioactive material transportation, effluent
control and monitoring, and radiochemistry. These programs have been
used at of Unit 1 and 2 and are being applied to Unit 3. Radiological
controls for Units 1 and 2 were Category 2 for the last assessment
period (9/1/83 - 2/28/85), and the programs are well established and
operationally sound.
Procedures for Unit 1 and 2 radiation protection are generally well
stated and provide explicit directions for controlling radiological
activities. All of the procedures applied to Unit 3 were subject to
management review before incorporation to assure that radiological
control was not over generalized. Minor examples of procedural deft-
ciencies have been identified in NRC reviews but programmatic weak-
ness is not indicated. However, detailed radiological controls for
handling of contaminated individuals exiting the Unit 3 containment
and their transfer to a decontamination area have not been established.
The radiation protection program was not fully implemented for fuel
receipt. Nevertheless, the licensee's fuel receipt efforts demon-
strated good planning and effective procedure development. The per-
sonnel involved were adequately trained and able to establish
thorough and complete radiological controls. Records of this activ-
ity were complete, well maintained, and available for review.
Personnel who implement the radiation protection program at Unit 3
undergo the same formal training as at Units 1 and 2. Additionally,
all personnel received special unit specific training in plant systems
and layouts. The training program is well defined and implemented
for the entire staff.
The licensee's chemistry / radiochemistry program is based on proven
procedures adopted from the program for the operating units. Personnel
are trained and qualified. A consistently good performance has been
noted in this area at Millstone 1 and 2.
The radioactive waste management program, common for the site, has
not yet been implemented for Unit 3. All radwaste systems have been
turned over to the utility. Preoperational testing is in progress.
Liquid waste, gaseous waste, and boron recovery systems remain to be
tested. The test program appears technically sound and sufficient.
Several operational deficiencies have been identified, but there is a
concerted effort to resolve and correct them. Waste system operating
and surveillance procedures h<ve not been finalized and, consequently,
were not reviewed.
.
..
i
11
Support activities such as external dosimetry, whole body counting,
maintenance and calibration of radiation instrumentation are common
to the site. The respiratory protection program, although also
common, has not been reviewed for how the Unit 3 subatmospheric
containment and associated changes in controls, if any, will be
addressed.
.
The Radiological Environmental Monitoring Program for the operating
units will also apply to Unit 3. This program has been effectively
implemented and is technically sound. Only minor discrepancies have
been noted. These have received immediate attention.
Immediately after the SALP period, NRC inspectors identified a
radwaste program concern. The FSAR solid radwaste system description
and the SER did not refect the installed system. Differences included
(1) the binder system used to supplement solidification as described
in the FSAR was essentially eliminated in 1983, (2) several system
components have been eliminated during startup testing, and (3)
the FSAR failed to describe resin dewatering by the primary waste
process and how much volume could be handled. Changes to the FSAR
had not been submitted. Upon identification, the applicant was quick
to draft an FSAR revision.
Conclusion
Category 2, consistent.
Board Recommendation
Licensee:
1. Assure the FSAR accurately describes the solid radwaste system.
NRC: None
- -- -- . - .. . .. . - _-
. .
'
.
12
C. Maintenance (169 Hours, 2%)
Resident and region-based inspectors observed corrective and pre-
'
ventive maintenance and reviewed the programs for maintenance support
planned for use during power operations. Pre-turnover and post-
turnover maintenance activities were observed in the areas of me-
chanical, electrical, and instrumentation'and control systems. The
inspection effort consisted of one program inspection by a region-
based inspector and review of maintenance activities during other
!
inspection efforts.
Both the Maintenance Department (mechanical and electrical) and the
Instrument and Controls (I&C) Department were fully staffed based on
current manning projections. Training programs were established
for I&C personnel and a comprehensive written test was given to all
,
I&C contract technicians prior to performance of activities (instead
,
of relying on vendor certification programs). Maintenance Department
,
training procedures were in existence at the time of the program
'
inspection, but the training program was still being developed.
The mair.tenance organizations are established. Programs for cor-
rective maintenance, preventive maintenance, and instrumentation and-
control maintenance were functioning in support of pre-operational
] testing and system turnovers. Procedures have been in place for ini-
l tiating, approving, reviewing, and scheduling of plant and preventive
maintenance for equipment protection. Administrative controls were
established for preparation and retention of maintenance records.
Weaknesses identified during the CAT inspection in the corrective
action taken to control preventive maintenance after components had
been turned ove- for testing / operations were promptly addressed by
the applicant. Never, a large backlog in the generation of main-
tenance, prevent e maintenance, and plant instrument calibration
1
procedures existed at the end of the SALP period.
Maintenance is controlled by a computerized system in use at all
Northeast Utilities Companies and accessible throughout the company.
This system is called the Production Maintenance Management System
(PMMS). Each department has a PMMS planner trained to make entries
to the system. PMMS information includes the frequency of preventive
maintenance and the maintenance history files. The system can review
maintenance records for generic failure implications and identify
periodic replacement of plant components based on environmental qual-
ification service time limits. Work orders are issued by the system,
including preventive maintenance and calibration activities. Manual
backup is used if the computer is down and for emergency maintenance.
As of June, a backlog existed on
,
, , - ,. - - - - - , . - - - - - - , _ . , - - , - , . - - . , _ , - - _ , .-,-m . . , . - -----------,,-,y._- - - - . . . - , -,
,, - - . - * - - - , ---.-.----,,,..w -
.. __ _ _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ , _ _ _ - - . _ _ _ _ _ _ _ _ _ _
'
.
.
, , *
13
computer input activities for the PMMS of Unit 3 mechanical equip-
ment. Much of the work in this area was being performed on manually
prepared work orders to give the PMMS time to catch up. Adequacy of
the automated aspects of pMMS therefore remains to be proven.
7
Observation of maintenance (e.g., component cooling water pump coup-
ling and thrust bearing repairs, service water pump disassembly and
!
inspection, steam generator "J" tube replacement, service water inlet
-
elbow repairs on CCW heat exchanger) found the program effective.
,
Controls were sufficient to assure preoperational test results were
r
not invalidated and that retesting was conducted on equipment for
which work orders were issued.
Conclusion
Category 2, consistent.
1 Board Recommendation
i
i Licensee: Establish a schedule for the completion and implementation
of maintenance related procedures and training programs.
j NRC: None
.
!
i
1
1
a
i
!
1
!
1
- - . _ . - - _ _ _ . _ _ . _ _ _ _ , . ___, . . _ - _ _ _ - , _-.___--,_m _ _ - . - - - - - _ . _ _ _ _ _ _ . . . - - _ , - -
--
.
.
, *
14
D. Surveillance (195 Hours, 2*4)
Surveillance activities necessary to support plant operations were
reviewed. Particular attention was given to development and imple-
mentation of the surveillance program for Technical Specification
requirements, availability and development of surveillance proce-
dures, availability and retention of equipment baseline data, and the
pre-service and inservice inspection programs. Inspections in this
area involved a program review in May, as-built review for conform-
ance to Technical Specifications in July, and examination of parts
of the surveillance program during other inspections.
For the most part, surveillance programs have been developed. Staf-
fing was in progress or complete and personnel were knowledgeable of
their responsibilities. Development of a master surveillance index,
a computerized production and implementation schedule, and inter-
departmental coordination methods had not been completed.
In July 1985, a special team inspection found that surveillance pro-
cedures were largely in draft form, varied substantially in quality,
and were generally not ready for inspection. That condition per-
sisted beyond the SALP period. (I&C surveillance procedures were
significantly ahead of the others.) The license pointed out that
delays in final Technical Specification issuance was a significant
factor in delaying the facility procedures. NRC review concluded that
the lack of procedure readiness included work that either did not
depend on Technical Specifications or could have been put in near
final form with provisions made for required validation upon Tech-
nical Specification issuance (a feature also needed for future TS
changes). Development of facility procedures was therefore evaluated
as a tardy effort which did not properly support operations on the
licensee's planned schedule. (As recently as early November 1985, the
NRC postponed inspections in this area because procedures were not
ready.)
The applicant has provided a satisfactory program to obtain baseline
information on plant equipment. In addition to obtaining field data
(e.g., steam generator eddy current base line data), procedures and
programs are being developed to maintain equipment history as
discussed under the maintenance section.
Conclusion
Category 3, consistent.
-
.
o
15
Board Recommendation
Licensee:
Assure surveillance procedures support future planned testing
and operations. Particular emphasis should be placed on orderly
development and review of procedures. -
NRC:
Conduct special follow-up inspection of surveillance program
and procedure adequacy.
- -- . . . - . - . _. . _ - .
.
.
'
.
"
16
-
E. Preoperational Testing (1835 Hours, 23%)
Preoperational Testing was rated Category 1 during the last SALP. It
was characterized as a well-defined program with an adequate staff
-
and experienced senior managers. Adequate controls existed for plant
maintenance, preventive maintenance, training, and documentation.
'
i The QA/QC program was evaluated as well-cbnceived. The supporting
organizational elements, NUSCo-QA and NNECo-QA/QC, were staffed with
experienced personnel.
'
During this SALP period, there were fifteen region-based inspections
i plus routine observations by the resident inspector. In addition to
- test program adequacy, test witnessing, and test results evaluation,
NRC independent measurements were performed. Preoperational proce-
dures were generally consistent with regulatory requirements, gui-
dance, and commitments. An exception was the Chemical Tank drawdown
test, which did not reflect all FSAR commitments. The applicant ini-
1 tiated prompt corrective action.
Management involvement has been evident in planning, procedure de-
velopment, staffing, training, and results review. Also, the startup
program was modified to improve performance. Three notable examples
l were (1) assignment of an auxiliary system test coordinator to accept
I
selected responsibilities from the nuclear system balance-of plant
test coordinators during high activity, (2) requiring the NNECo
Operations Department to review system test results as well as the
Startup Department, and (3) reorganization from a discipline-
orientated to a task-orientated organization.
Several tests have had a great number of changes (exceptions). These
included the Chemical Addition Tank test, Engineered Safety Features
test, RCS hydrostatic test, and Steam Generator hydrostatic test.
Based on the changes reviewed, exceptions did not affect test results
- or change basic test objectives. Changes were found to be properly
- reviewed, approved, and documented. Throughout the SALP period, the
NRC has had to review draft procedures. However, only approved pro-
cedures have been found in use during testing. Based on the test
results reviewed by the NRC inspectors, no problems have occurred
'
because of late procedure generation.
Technical solutions to problems have been well defined and executed
except for a few isolated examples where resolution was incomplete or
4 slow. An example is valve indication on manual and motor-operated
valves (slip of butterfly valve indication arrows, reverse installa-
tion of indicators, reverse raised letter indication, no labelling
'
for position indicator, and handwheel operation contrary to normal
convention). The containment sump flooding in May was in part a
'
result of failure to establish the position in the Containment Sump /
Containment Recirculation Pump suction isolation valve. The valve
stop for the butterfly valve had not been installed and the operator
positioned the butterfly valve past the closed position by following
the position indication (arrow).
i
_ ,. , . - . , - . . ,.
. . ._ ._ _ ._-
,
, .
,
17
During this SALP' period, the containment Local Leak Rate Testing
(LLRT), Integrated Leak Rate Testing (ILRT), and Structural Integrity
"; Test (SIT) were completed. Test procedures and results get require-
ments. Personnel were knowledgeable of the procedures and equipment.
Staffing was adequate. Test personnel made tours to look for leaks.
The applicant exercised good engineering judgement. Only one Con-
j struction Deficiency was identified: two 3/4 inch leakage monitoring
lines were improperly installed and left open to the atmosphere.
That Deficiency was corrected.
Test personnel and management involved with the SIT were committed to
4
assuring an accurate, high quality test. Comparison to the predicted
analytical deflections was done by crack mapping and crack width .
<
measurements in accessible unpainted areas. The applicant also
measured exterior containment deflections across seismic (" rattle
space") separations between the containment and adjacent structures.
Preliminary. indications were that actual ~ deflections agreed with
predicted ones. Overall, SIT efforts exceeded the provisions of SIT
- During the SALP period, preoperational testing proceeded without
- serious delay. The only safety-related system encountering signif-
icant difficulties was the Emergency Diesel Generators (EDGs), which
experienced repeated seizing of the fuel injection pumps. Subsequent
fuel system cleaning and flushing, and modifications to the fuel
,
'
filters, appeared to resolve this problem. An EDG delay resulted
when Stone and Webster Engineering review of Colt Industries QA/QC
activities found it was necessary to replace numerous crimps in EDG
panels. The rework proceeded in a thorough manner without sacri-
ficing quality for time.
QA/QC involvement was observed during preoperational testing. QC
hold points are not included in preoperational test procedures.
Rather, the QA/QC program consists of surveillances timed to give
broad QA coverage of the preoperational test program. This moni-
I
toring program includes in process verifications, test witnessing,
checks on instrument calibration, receiving and storage of test
equipment, etc. No significant problems were noted.
A trending / tracking program was established during preopeational
testing for outstanding items, QA audit reports, completed actions,
and other similar items. This program was found effective.
Conclusion
Category 1, consistent.
'
Board Reccmmendations
-- . - . - _ _ _ _ .
-. -. __ , . _ - -
_, .-. ..
-. . . _ . . . -~ . . . . . . . . , - _ - - . - -
.
,- .
.:
4 18
!
'
Licensee:
1. Upgrade timeliness of issuance of startup and power ascension
! test procedures and of evaluation of test
results.
1 2. Assure that any as-built plant, SAR,' and Technical Specifica-
tions discrepancies revealed by preop tests are corrected.
1
,
NRC: None
i
+
t
'9
-
..
$
,
e
a
A'
e
I
!
. . - . . _ _ _ . _ _ _ - . . . - . _ . _ _ .
- -
_ __ _ _ - _ _ . _ _ _ _ _ . _ _ - _ . . _ _ ___ . - . _ , _ . _ _ _ - . - -
._ _ __ -_ _ _ _ _ _ _ .___________________ __________
_
.
.
, =
19
F. Fire Protection and Housekeeping (172 Hours, 2%)
Fire protection and housekeeping are also routinely reviewed by most
NRC personnel who visit the site, making the actual data base greater
than is recorded in inspection hour records. During this SALP
period, there was one team inspection plus routine inspections by the
resident and region based inspectors. The inspections confirmed that
the applicant was implementing an effective program for fire preven-
tion and fire protection. Licensee coverage included control of
combustible materials, storage and use of flammable liquids, avail-
ability and maintenance of fire fighting equipment, operations in-
volving open flames or arcs and fire prevention for temporary ser-
vices and work activities. Throughout the SALP period, fire pre-
vention and fire protection was well implemented and maintained, and
housekeeping and cleanliness were satisfactory.
The NRC team inspection confirmed the ability to shutdown safely in
the event of a design basis fire. Management involvement in assuring
a safe shutdown capability was evident throughout the licensee's
effort involved in applying the NUREG 800 Guidelines. The applicant
formed a fire protection inspection team of hand picked specialists
from his staff and contractor personnel. This team addressed shutdown
concerns and capabilities, design changes, and compliance with guide-
lines. Management attention resulted in an efficient licensee team
which adequately addressed all NRC concerns. The applicant demon-
strated a clear understanding of safe shutdown issues and concerns.
Their analysis was comprehensive and well documented. Such thorough-
ness was also reflected in the supporting calculations reviewed by
the NRC. Throughout the NRC team inspection, applicant responses
were timely and technically sound.
In November 1984, a small fire in containment was caused by a short
in a temporary lighting cable, apparently due to crimping of the
cable by scaffoldin! planks. The damage was minor. No permanent
plant equipment was clamaged. The applicant's response was prompt and
well organized. A reflash watch was stationed for several hours.
Corrective action implemented after a September 1981 fire limited the
scope of this fire. This event demonstrated an effective fire re-
sponse capability.
One concern was the licensee's Hot Functional Testing approach which
waived fire protection for areas protected by carbon dioxide due to
problems with fire control panels. The licensee committed to addi-
tional patrols of the potential hazard areas to provide minimum pro-
tection. The carbon dioxide system has yet to be demonstrated. As
late as November, this system was not tested due to a problem
with the Heating, Ventilation and Air Conditioning System.
Staff responsibilities were evaluated as well defined and authorized
manning levels as ample to meet those responsibilities.
.. . .
.
. ..
_ - _ - _ _ _
-
.
. *
20
Conclusion
Category 1, consistent.
Board Recommendation
Licensee: None
NRC: Follow-up CO2
System testing and associated damper testing.
__- - - - - - - - - - _
.
. *
21
G. Emergency Preparedness (140 Hours, 2%)
This is the first SALP evaluation for Millstone 3 in this area. Unit
3 is an additional unit in the common site Emergency Plan and is in
part dependent on the program for Units 1 and 2. The site program
was rated as Category 2 (period 9/1/83 - 2/28/85) with the recommenda-
tion that the licensee evaluate measures for the timely completion of
action items. The major issue was the establishment of an integrated
emergency plan training / retraining program to ensure that lesson plans
were developed and training accomplished for each functional area of
4
emergency activity. At the end of the Unit 1/2 assessment period, the
" Emergency Preparedness Training Program" was only available in draft
form but contained the revised training lesson plan format and testing
requirements. This program, which was to be implemented by June 30,
1985, was late but acceptable in quality,
i
A Unit 3 Emergency Preparedness Implementation Appraisal was conducted
in July 1985. It covered facilities and equipment, organization,
procedures, and training. Afterwards, a meeting was held in Region I
to discuss deviations from current guidelines. During that meeting,
the applicant presented information which resolved the concerns or
4 proposed acceptable corrective action. In many cases, a more com-
plete description in the Emergency Plan or implementing procedures
would have allowed an earlier resolution.
On May 15, 1985, the NRC observed an emergency drill for Millstone 3.
!
Participation was limited to utility personnel. This drill imple-
mented selected response aspects including operator response, tech-
nical support activities, event classification and reporting, and
coordination of emergency response activities. Overall performance
was acceptable. Personnel $were appropriately trained and qualified
to perform the emergency functions observed. Areas noted as
needing improvement were coordination of emergency repair activities
between the Technical and Operational Support Centers and crowding of
some facilities in the OSC. The crowding was in part due to the
dispatching of repair crews from the OSC.
Management commitment and close involvement in assuring an adequate
level of emergency preparedness was shown during the emergency drill
and program reviews.
Conclus r3
Category 2, consistent.
Board Recommendation
4
Licensee: Increase management attention to assure corrective actions
are accomplished in a timely manner.
NRC: None.
_ - . - .
-_
- . - _ - - -- - -_ - - . - - . - - . --
_
-
.
.
22
,
H. Security (84 Hours, 1%)
- This was the first SALP evaluation of Unit 3 Security and reviewed
'
the development of a physical protection program for Unit 3 and
preparations for integration of the Unit 3 program into a site (Units
1, 2 and 3) security program. Also assessed was the licensee's
developing and implementing of a program for receipt and storage of
l new fuel. Three announced preoperational security program reviews,
including two inspections of new fuel were performed by a
region-based physical security inspector. Continued review of the
program was conducted by NRC resident inspectors.
The development of the physical security program and its integration
into the program for Units 1 and 2 included modification of the
security management organization; the procurement, installation and
acceptance testing of new equipment and the operational interface of
the Unit 3 equipment and systems with the existing system; and the
hiring and training of additional contract security personnel.
A major rewrite of the site physical protection plan was completed
and submitted to the NRC in May 1985. NRC review identified some
, minor issues which required rework by the licensee. All of these
issues have been resolved. In addition, the licensee submitted its
Plan for Receipt of New Fuel in March 1985. It required little
rework and was approved by NRC in April 1985. The licensee is
currently reviewing its Suitability, Training and Qualification, and
. Safeguards Contingency plans to provide for the integration of Unit
i
3. It appears that only minor administrative changes will be neces-
sary. All security program plans were observed to be professionally
prepared, well organized, responsive to regulatory requirements, and
submitted in a timely manner. Minor changes necessitated as a result
of NRC review were accomplished in a timely and professional manner.
The design engineering and layout of the Unit 3 security equipment
and systems are well conceived. Practical applications and utiliza-
tion of state-of-the-art equipment are evident. Quality assurance
4
oversight of program-related activities was evident throughout the '
assessment period. Project engineers and security supervisors were
l knowledgeable of program status, turnover dates and NRC performance
criteria. Procedures were in place to assure the proper acquisition ,
i
and retention of acceptance testing documentation. Documentation was '
found easily retrievable during NRC reviews. These reviews indicated
close coordination and oversight by licensee management for all
activities. The newly constructed site security facilities were well
planned with an adequate allocation of space. Human factors con-
sideration was evident.
4
e
,-- -
,>~m - - - - - - m ~-
. _ _ _ _ _ _ _ _ _
.
..
. *
23
.
The hiring of new contract guards and watchpersons is complete. The
security organization has increased by approximately one third, to
about 280 personnel, including both proprietary and contract
staffing. The training and. qualification of new security personnel
has been in progress since March 1985 and is scheduled for completion
in September 1985. Specialized training being administered to the
new personnel was observed during Region I program reviews and was
found consistent with the licensee's NRC approved Suitability,
Training and Qualification Program. Experienced Unit 1 and 2
personnel are in line for command and access control positions.
The last two Preoperational Security Program Reviews during the
assessment period included implementation inspections of the Plan for
Receipt of New Fuel and associated control procedures. No problems
were identified.
Corporate and site management involvement in planning, procurement,
installation, hiring of employees, budgetary support, quality
assurance and audit have been evident throughout the assessment '
period. Presentations on the status of projects were professional
and technically competent. Sufficient personnel are trained,
qualified and available to compensate for unplanned system or
equipment failures.
The licensee promptly informed the NRC of occurrences in the security
area during the construction of Unit 3.
Conclusion
Category 1, consistent.
Board Recommendation
Licensee: None.
NRC: None.
_
.
., .
.
24
I. Construction (4774 Hours, 59's)
The previous SALP assessment evaluated six areas of construction
separately. These were Containment and Other Safety-Related Struc-
tures; Piping Systems and Supports; Safety-Related Components;
Support Systems; Electrical Power, Instrumentation and Controls; and
Engineering-Construction Interfaces. All areas were rated Category 1
except Piping Systems and Supports which was re.ted Category 2. All
six areas have been combined under one functional area for this SALP.
Concerns addressed in the previous SALP included: (1) assumed pipe
and fitting sizes were used in stress calculations (2) lack of
aggressive action to correct deficiencies in the control of NDE qual-
ity, (3) minor delays in correcting deficiencies in safety-related
components and (4) choice of the proper Non-Destructive Examination
(NDE) method for inspecting of containment electrical penetration and
end plate welds.
Inspection of construction involved eighteen inspections in addition
to routine review by the resident inspcclors. There was a team in-
spection from NRC Headquarters and one from the Region. Three team
inspections involved the Enoineering Assessment In-Depth Technical
Audit. Ten construction violations wer~e identified. None of these
were considered serious or indicative of a breakdown in the quality
of construction.
Most electrical systems were energized during this SALP period to
support testing. Although there were problems with control of elec-
trical and I&C equipment due to dirt, aggressive management attention
was effective in correcting this. Overall, electrical construction
has been good. Design requirements'and specifications were generally
met. Deficiencies noted included not meeting electrical separation
criteria for some raceways and cables, some Class IE cable termina-
tions not in accord with design drawings, some main control board
redundant wires in contact with each other, and random use of color
tape to identify cable channels. The applicant quickly initiated
acceptable corfective actions. Vendor wire termination problems
were , uncovered'by the licensee and resulted in an aggressive 100%
reinspection program of four vendors. The associated rework has been
completed for the main control board and the Systems Control vendors
and was in progress for the other two.
Work observation, as-built verifications, and independent measure-
ments and calculations have found the instrumentation and controls to
be in compliance with drawings and commitments.
-
.
. *
25
Containment and other safety-related structures have been constructed
with only minor problems / weaknesses found. These have included
rattle spaces smaller than committed, concrete in the rattle space
between Containment and the Main Steam Valve Room, and some steel
connections not in accordance with design drawings. Repair of con-
tainment liner damage from a September 1981 fire were acceptably com-
pleted. Overall, structural construction <was in accordance with
applicable codes, commitments, and requirements.
Engineering-construction interfaces have generally been good and have
effectively functioned during operational turnovers. Although a
large number of open items may be present on turnover, there are
controls to determine how these items will be dispositioned. Manage-
ment has been very responsive. Improvements were noted in post-turn-
over control of wiring changes and preventive maintenance deficien-
cies. The applicant has knowledgeable personnel who are aware of re-
quirements involved with turnover documentation, but some files are
incomplete and it was very time consuming to assemble the data. No
major problems were experienced as a result.
Problems associated with the vendor radiographic program, identified
by the NRC Van inspection during the last SALP period, indicated that
management was not sufficiently involved in control of non-destructive
examination (NDE) quality and that technical evaluations were not
adequate. Additional problems were identified during this SALP
period. These include drawing control, missed radiographic indica-
tions in site and vendor welds, and failure of the licensee to have
the independent authorized nuclear inspector review final re-radio-
graphs of welds. These involved 600-700 vendor (Tubeco) weld radio-
graphs. The applicant initiated corrective action. Relief from code
requirements was requested from NRR for 30 welds imbedded in con-
crete. As of this writing, no substantive rework has been required
to assure the ability to meet functional design requirements. Never-
theless, continued management attention is warranted to NDE record
quality.
In August 1985, selected results of Preservice Inspection (PSI)
ultrasonic examinations of centrifugally cast stainless steel for the
reactor coolant piping were reviewed. The review identified dis-
crepancies involving documentation of examination limitations and the
disposition of indications attributed to geometric reflectors. These
indicate a need for additional licensee management attention to the
review of Westinghouse PSI data.
,
'
.
.
... *
'
26
4
' , During the CAT inspection discrepancies were identified in pipe sup-
port / restraints and mechanical equipment foundations, and between
'
as-built drawings and piping configurations. The team also identi-
fied a need for more thorough engineering review activities, and
additionaFreinspection and/or reanalysis. In' August 1985, an ex-
tensive inspection was performed on structbral steel bolting and
welding, pipe support welding, vendor tank welding, and stress recon-
ciliation. This inspection included independent measurements and
followup of licensee activities in response'to CAT findings. Over-
all, the results indicate good onsite welding quality and an adequate
program for response to the CAT findings.
Immediately after the SdLP period a multidisciplinary team inspection
,' assessed whether selected, as-built systems substantially agreed with
the'l descriptions contained in the FSAR and the SER. It was concluded
that overall workmanship was good and that the systems generally con-
form to the F5hk and SER. Capacity and seismic mounting discrepan-
cies were, however, identified in the control room air pressurization
system.
,'
.~ \
, .The senior resident inspector and Region I managers have found.that,
in general, submitted Construction Deficiency Reports were timely,
thorough, and of good quality. Technical solutions for Construction
s0eficiencies has been sound. Corrective action has been performed
- by properly trained personnel using approved procedures. However,
' '
resolution of a number of items has continued to proceed slowly
and needs, additional management attention,
s Nonconformance and Disposition reports are usually resolved in a
, timely manner, with positive corrective action being taken. Design
modifications-and modification requests were handled in accordance
, with procedures. ' Disposition of these requests were based on
engineering justification and review by members of the Joint Test
Group. Engineering and Design Coordination Reports have been
, generally effective. .
NNECo contracted Stone and Webster Engineering Corporai. ion (SWEC),
the AE for Millstone 3, to conduct an Engineering Assurance Program
Technical Audit. NRC review found the audit to be in accordance with
the approved program plan and of sufficient technical depth to
achieve the program objectives. There was a concern that reviewers
~) were not deviating from the review plan as necessary to thoroughly
p[ evaluate.both the adequacy of the design and the adequacy'of the
N desigrc process when potential problems were identif,ied. Also,
interfaces between the major disciplines of the AE audit team needed
improvement to ensure that potential discrepancies in one discipline
was reflected in others. As an outgrowth of the AE audit, NRC is
'/e reviewing the applicant's Seismic II/I program. This consideration
is included in the Licensing Functional Area.
.
- . .- .-_ . . .- . _. . .. _-.
-
.
.
27
QA/QC personnel were rountinely observed to be performing construc-
tion and preoperational testing functions. During construction,
,
" hold points" for inspection of completed work were readily apparent.
Subsequent reviews of the QA/QC involvement (quality examination,
'
procedure reviews, surveillance, and auditing) indicated logs and/or
i records were being maintained and the results reported. Nonconform-
., ing or unsatisfactory conditions were being followed for corrective
,
action,
,
Overall, the construction at Millstone 3 has been in accordance with
- the applicant's commitments and applicable codes and regulations.
- Conclusion
Category 1, consistent.
'
- Board Recommendation
. Licensee: Assure more timely closecut of CDRs and outstanding items.
!
l NRC: None.
1
1
i .
4
3
h'
r
d
--.._,.-_,....-..--._,-,,._,.-,..,_,--.m._.m_-_, ,.._.,-.c., , - - . . . .
,,,-,4 --
4._,,_ m.-,,_,,--- . - - ,,__, .,. , , _ . , _ . , ,-,_
. .
.
'
28
J. Licensing Activities
This area was rated Category 2 during the previous SALP, with
recommendations that the licensee continue to take the initiative to
resolve fuel load items and to provide appropriate management involve-
ment in significant review areas. During the current period, NRR
review supported issuance of Safety Evaluation Report Supplements 1
and 2 (March and September 1985) toward resolution of 19 SER open
items, 70 confirmatory items, and 7 license conditions. There were
several NRR on-site, in-depth technical audits in addition to meetings,
conference calls, and review of applicant inputs.
For those items identified as part of the staff's safety review, the
applicant demonstrated prior planning and assignment of priorities.
The applicant continues to take an aggressive approach to complete
unresoived items identified in the staff's SER. There were well-
stated and explicit applicant procedures for activity control. In
general, NNECO assigned technical people as needed to develop com-
plete high quality responses. The fire protection review effort was
a good example of this. Additionally, evidence of prior planning and
assignment of priorities was demonstrated during several on-site
technical audits. Audits were held on schedule and the appropriate
technical and management support was involved so that the NRC staff's
questions were answered with a minimum number of open items after the
audits.
Generally, the applicant exhibited conservatism in its decisions where
safety significance existed. An example of this is the Engineering
Assurance Program. The applicant, on its own initiative, took a sound
and thorough approach to the independent design review, using an
engineering assurance technical audit program performed by Stone &
Webster. Open items identified by S&W during this audit were
vigorously pursued by the utility.
In contrast to the approach taken by the applicant on many SER items,
there were a significant number of review matters for which the
applicant was unresponstve. The applicant did not come forward with
several potential review concerns early in the review process until
NRC forced the issue. In other cases, the applicant persisted in
supporting a position contrary to the staff's requirements. As a
result, several items of potentially high safety significance sur-
faced or remained unresolved late in the review process. High level
NRC management involvement was then necessary to accelerate the
review and assess potential impact on licensing. An example of this
is the Seismic Interaction Program. In this case, the applicant
failed to notify the staff of its planned approach to meet NRC
criteria until that approach was identified by the staff during the
Engineering Assurance Program Audit. It was not until after several
meetings with NRC staff to discuss and agree upon supplementary
. . - _ .- -. - . . - - _ - _ .. - _ _ . - ._-- --
.
.
.
.
29
<
information that progress was made toward resolution. Other examples
are the shift staffing / operating experience on shift issue and the
Technical Specification review. The position taken by the applicant
on both these matters was that the staff was aware of the applicant's
position early. The applicant did not pursue interaction with
1'
the staff to assure that NRC requirements were met. NRC repeatedly
attempted to work with the utility on shift staffing before the
utility began to be responsive. As a consequence, an inordinate
amount of staff involvement was necessary to complete this review.
The applicant was also unresponsive in regard to the Technical
Specification review. The applicant did not submit the justifi-
cations needed for non-Standard Technical Specifications in a timely
manner. An accelerated review schedule became necessary.
In summary, the applicant has provided satisfactory inputs to the
NRC, but too many items have not been timely.
Conclusion
Category 2, consistent
Recommendation
Licensee: Increase management involvement in the licensing review
process in order to assure more timely resolution of licensing issues.
I
NRC: None
!
t
I
. . _ _ . . _ . _ . _ _ _ - . , _ . . . - , , , _ . _ . . _ , _ . _ , _ . _ _ _ _ _ . _ . _ , _ _ _
_
.. _ _ _ _ . _ . . _ . _ _ _ _ . . . _ _ , _ _ . . - . , .
- . -. - ..- _ - - - - -- . - .. - . . __ - - . . .
-
.
'
.-
30
V. SUPPORTING DATA AND SUMMARIES
A. Construction Deficiency Reports (CORs)
4
The applicant identified 29 items of potentially significant
deficiencies during the assessment period. Subsequently, 3 were
evaluated as not to be reportable by the applicant. At the end of
- '
the assessment period, 15 remain open pending resolution of the
issue. The CDRs are listed in Table 1.
{ B. Investigation Activities
One investigation of a painter qualification incident was completed.
'
The report has not been released for public distribution. Another
investigation was in progress but not completed.
C. Escalated Enforcement Action
No escalated enforcement actions were taken this SALP period.
D. Management Meetings
On September 13 and 14, 1984, NRC staff met with Northeast Nuclear
Energy Company at Millstone 3 to discuss LOCA loads and load
combinations used in design of Millstone 3 pipe and component
supports.
On December 17, 1984 at Millstone 3, Waterford, Connecticut, a
management meeting was held to present the results of the Systematic
Assessment of Licensee Performance (SALP) for the assessment period
9/1/83 - 8/31/85.
A periodic management meeting requested by Millstone 3 and Northeast
, Utilities management to discuss the project status and progress was
held on February 8, 1985 at the Region I office.
4
'
A Seismic Qualification Review Team (SQRT) and Pump and Valve
- Operability (PVORT) audit was conducted during the week of March 4,
1985 by the NRC staff.
On May 21, 1985, a meeting was held at the Millstone 3 site with the
- NRC Radiological Assessment Branch to discuss and verify FSAR
- commitments relating to the radiation protection program.
!
- On June 21, 1985, a meeting was held at NRC Headquarters to discuss
Seismic II/I design considerations for Millstone 3.
On July 2, 1985, a meeting was conducted at NRC Headquarters to ,
, discuss the Millstone 3 environmental qualification report.
, ,
1
. - - - - ,----r -
y ,, ,,,,.._..,_.-.,,_,.,_,..,_,,,.~,.y ...,._,,ym-~, - - , , . _ , _ . _ _. - , _ , , _ ,
.-.__,...-..y_,,-.,.m., --___..-.....-..-,,,,.,.,,-.,,,m,. - -
. .
.
.-
31
On July 9, 1985, a meeting was. held at the NRC Region I Office to
discuss the status of licensed operator training and of the Millstone
3 project.
On July 11, 1985, a meeting was held with Northeast Utilities to
discuss the Millstone 3 fire protection at NRC Headquarters.
On July 29 and July 30, 1985, an audit of the Millstone 3 Safety
Parameters Display System (SPDS) to perform design verification and
design validation was conducted at the Northeast Utilities General
Offices in Berlin, Connecticut.
On August 1, 1985, a working meeting was held at the NRC Region I
office to resolve emergency planning pre-licensing issues for
Millstone 3.
'A meeting was held on August 6, 1985 at NRC Headquarters to discuss
the applicant's response to questions resulting from the staff's
review of the Millstone Nuclear Power Station Emergency Plan, Draft
2, to Revision No. O, dated January 1985.
. .
, .
TA9LE I
CONSTRUCTION DEFICIENCY rep 0RTS
(September 1, 1984 - August 31, 1985)
MILLSTONE NUCLEAR p0WER STATION, UNIT 3
CAUSE
CRD NO. OEFICIENCY STATUS CODE
84-00-10 Eleven Westinghouse process control cabinets had in- Closed A
ternal wiring which should have been removed at tha
factory
84-00-11 Unqualified motors on safety-related motor-operated Closed A
valves
84-00-12 Potential leakage path in seal of Rosemont Model 1153 Closed * B
Series B pressure transmitters
84-00-13 Problems with Flakt-Bahnson air conditioning units Open* B
84-00-14 Potential failure of auxiliary feedpump wear rings Open B
84-00-15 Oil leak and broken upper bearing housing in contain- Closed B
ment recirculation spray pump motors
84-00-16 GE relays potentially operating in less time than Closed B
the set time delay
84-00-17 Potential cracking of emergency diesel generator Closed A
engine driven lube oil pump discharge nozzle due to
over-torquing
84-00-18 Improper installation of conduit seal for Rosemount Closed F
Pressure Transmitter
85-00-01 Possible material problems with Parker-Hannifin Open B
stainless steel fittings
85-00-02 Jafety grade power supplies tied to control grade Closed B
cables without appropriate isolation devices in
Westinghouse Model 7300 Process Control Cabinets
85-00-03 Potentially inoperable non-motor-operated curtain Open B
type fire damper
- .. - . . - . . - - . - -.- --- .-- .. . . - - - - _ _ _ _ - - . .
d
a
j .
o t
i
E
CAUSE
, CRD NO. OEFICIENCY STATUS CODE
4
i
85-00-04 Improper operation of the emergency generator load Closed B
sequencers
,
85-00-05 No drain holes in Foxboro Transmitter junction boxes Closed F
! 85-00-06 Failure of emergency diesel generator 1 sad sequencer Closed B
to shed required loads
,
'
85-00-07 Non-seismically qualified auxiliary. feed pump lube Open B
oil pressure switches
85-00-08 Nonconforming terminations in CVI corporation equip- Open B
- ment
4
i
85-00-09 Cooper and Turner load indicating washers with preload Closed * B
out of compliance with design
.
85-00-10 Broken tack welds on feedwater check valves Open E
85-00-11 Emergency diesel generator fuel oil injection pump Open E
.
failures
85-00-12 Improper cable separation for Reactor Protection Closed B
System cables
j 85-00-13 Improper dimensioning of fillet welds on tube steel Closed F
4
connections where skewed angle is less than 45 degrees
t
85-00-14 Structural steel connections in the Main Steam Valve Closed F
Building installed to incorrect welding detail
- ,
! 85-00-15 Core exit thermocouple total system error exceeds Open B
. error assumed in Westinghouse Emergency Response
4
Guidelines
t
85-00-16 Improper installation of upper reactor internal core Open F
, thermocouple compretsing fitting
i
85-00-17 Seismic failure of Amphenol Triax Connector Open E !
85-00-18 Potential seismic interaction between the Flux Open B
Mapping System and Seal Table
.
J
' ,
1
- - _ _ _ _ . . _ _ _ . _ . _ _ _ _ _ _ _ _ , , _ , , _ _ _ _ _ _ _ . - _ _ . , _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ . - - _ - , _
.
.
.
3
CAUSE
CDR NO. DEFICIENCY STATUS CAUSE
85-00-19 Potential seismic failure of GE Type PVD21 Differ- Open E
ential Relays
85-00-20 Improper Emergency Diesel generator sequencing Open B
- Licensee subsequently classified item as not reportable
CAUSE CODES
A - Personnel Error
B - Design / Fabrication Error
C - External Cause
D - Defective Procedure
E - Component Failure
F - Site Construction Error
l
1
i
,_ _ . - _ _ - ,-_ .__
. .
.
!
4
TABLE 2
INSPECTION HOURS SUMMARY (9/1/84 - 8/31/85)
MILLSTONE NUCLEAR POWER STATION, UNIT 3
Functional Area Hours % of Time
A.: Operations Supports 552 7
B. Radiological Controls 181 2
C. Maintenance 169 2
!
D. Surveillance 195 2
'
E. Preoperational Testing 1865 23
F. Fire Protection 172 2 !
G. Emergency Preparedness 140 2
H. Security 84 1 .
I. Construction 4774 59
J. Licensing Activities -- -- l
3 TOTAL 8201 100
'
NOTE: The above values are approximate.
t
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!
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!
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1
'
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,
- + < mm u -m__,*.=>w~--,,+y-----w~~.--me-- ,w-e------n-w-+mv-wwm, % mvv - ~ . - %4we,--,-we-m, >----ev---+-r--- - - ,
- - _ _ . - _ _ __. - . - . -- - _ _ - - _ _ . . ~ .
.
.
_, .
5
i
TABLE 3
INSPECTION ACTIVITIES
MILLSTONE NUCLEAR POWER STATION, UNIT 3
'
INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
- 84-14 Resident Open items; preoperational testing; incore
- 8/19 - 9/29/84 114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br /> thermocouples; structural settlement monitoring
program; procedures; diesel fuel storage; lic-
ensee/ contractor self audits; significant deft-
ciencies; ACRS items.
84-15 Specialist Previous SALP period.
84-16 CANCELLED
84-17 Specialists Preoperational test program review including i
9/17 - 21/84 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> program requirements, control of documents, test
procedures, engineering drawings, manuals, de-
sign changes and modifications, jumpers and by-
passes; plant maintenance, preventive mainten-
ance, and maintenance records; test procedure
, reviews and test results evaluations.
84-18 Specialists Followup on previous inspection findings; work
- 9/17 - 21/84 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> observation; review of QC of pipe supports.
84-19- 1984 Millstone Unit 3 SALP.
84-20 Resident Follow-up on previous inspection findings; start-
9/30 - 11/10/84 266 hours0.00308 days <br />0.0739 hours <br />4.398148e-4 weeks <br />1.01213e-4 months <br /> up test program review and observation; event
follow-up; welding electrode control; training;
i
maintenance; construction; and housekeeping.
I
84-21 Specialists Facility tour; pipe and pipe support welding;
10/15-19/84 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> copper-nickel welding; repair welding; and
follow-up on open items.
'
84-22 Specialists Follow-up on open items; preoperational test
10/15-19/84 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> program requirements and implementation; test
procedure review and witnessing emergency diesel
generator set test verification; and facility
tour.
84-23 Specialists Installation of safety-related electrical and l
10/22-26/84 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> instrumentation system components.
l
I
'
. - - - . - - - _- - _ ----__ -_ - - - -.. . - -. --- - - -
_ _ - _ _ _ _ _ _ _ _ _ _ _ __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
!
. -
.
l
. ,
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(
6 ,
r
4
INSPECTION REPORT INSPECTION /
,
NUMBER AND DATES HOURS AREAS INSPECTED
. 84-24 Specialists Preoperational test program requirements and
l 11/5-9/84 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> implementation; test results evaluation and
witnessing; auxiliary boiler repair and testing;
.
preparations for' steam generator hydrostatic
.
I
testing; quality assurance and quality control;
facility tour.
84-25 Resident Preoperational testing; follow-up on open items;
11/11/84-1/7/85 192 hours0.00222 days <br />0.0533 hours <br />3.174603e-4 weeks <br />7.3056e-5 months <br /> control room practices; plant tours; control
. rod drive fabrication review; event follow-up; !
IE Notice review; implementation of security i
measures; audit activities; fire protection i
testing; hazards program review; changes to i
plant management; and Tubeco repairs,
i
84-26 Specialists Preoperational test program requirements and
. 11/26-12/5/84 134 hours0.00155 days <br />0.0372 hours <br />2.215608e-4 weeks <br />5.0987e-5 months <br /> implementation; test procedures and results
i
12/ 3- 5/84 results review; steam generator hydrostatic
I
12/10-12/84 testing; quality assurance and quality control;
,
and facility tours.
+ 85-01 Specialists Construction Deficiency Reports
j 1/8-10/85 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />
.85-02 Resident Preoperational testing; previous inspection ,
1/9-2/4-85 151 hours0.00175 days <br />0.0419 hours <br />2.496693e-4 weeks <br />5.74555e-5 months <br /> findings; control room practices; plant tours; '
potential significant deficiencies; flushing
'
program activities; IE Bulletins; allegations;
' valve positioning anomalies; fuel receipt pre-
parations; service water hydraulic testing;
safety injection plump test ar.o aly. '
85-03 Specialists Preoperational test program requirements and
, 1/21-?5/85 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> implementation; test procedure and results re-
i
views; test witnessing; auxiliary boiler status;
quality assurance and quality control; and
l facility tours.
} 85-04 Specialists Construction appraisal team: Electrical and in-
2/19-3/1/85 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> strumentation construction; mechanical con-
3/11-22/85 struction; welding and non-destructive examin-
' ation; civil and structural construction; mate- ,
rial traceability and control; design change !
control; corrective action systems. i
1
l
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!
,
- ..
-
.
. *
7
INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
85-05 Resident Review of activities including refueling cavity
2/5-3/18/85 183 hours0.00212 days <br />0.0508 hours <br />3.025794e-4 weeks <br />6.96315e-5 months <br /> seal ring leak test, emergency diesel generator
EDG-A gage repair, EDG-A lubrication system
performance, system flushes, hydraulic expansion
of steam generator tubes, emergency plan train-
ing, and FSAR/ design verification maintenance
training; open items; NRC Bulletins, steam
generator field service report; construction
deficiencies; and allegation followup.
85-06 Specialists Preoperational test program requirements and
2/12-15/ 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> implementation; test procedures and results re-
2/25-3/1/85 view; test witnessing; open items; and plant
tour.
85-07 Specialists Combined report for Units 1, 2 and 3: Preopera-
2/11-15/85 31/10 hours ** tional program for operational environmental
monitoring program including management controls,
quality control of analytical measurements,
meteorological monitoring, radiological environ-
mental monitoring program.
85-08 Specialists Installation of safety-related instrumentation.
2/4-7/85 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />
85-09 . Specialists Physical security plan and implementing proce-
2/11-15/85 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> dures for security and audits program, records
and reports, testing and maintenance, locks,
keys, physical barriers, security system power
supply, lighting, assessment aids, access con-
trol, detection aids, alarm stations, communi-
cations, training and qualifications, security
contingency plans and proposed 10 CFR 73.55 and
73.67 plan commitments.
85-10 Specialists Preoperational test program requirements and
, 3/18-22/85 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> implementation; test procedure reviews; test
'
witnessing; open items; reactor coolant systen
hydrostatic test; new fuel receipt and storage;
l quality assurance and quality control; facility
tours.
85-11 Specialists Procedure review, test witnessing, and evalu-
3/25-28/85 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> ation of the preoperational Integrated Leak Rate
Test, Structural Integrity Test, and Local Leak
Rate Test; facility tour.
l
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i
I.
. _ _._ _._ _ _ __ _ _ _ __ _ _ . . _ _ . _ . _ . __ _ _ _ __ __._
.
.
'
.
8 I
i
i
INSPECTION REPORT INSPECTION / '
l NUMBER AND DATES HOURS AREAS INSPECTED L
85-12 Resident Primary cold hydrostatic test and Chemical Ad-
3/18-4/22/85 222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br /> dition Tank Drawdown test witnessing; event I
followup; open items; potential significant :
deficiencies; IE Bulletins; IE Information No-
tices; steam generator "J" tube inspection; and
preparations for initial fuel receipt.
85-13 Specialists Installation of safety-related electrical and
4/8-12/85 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> instrumentation equipment; quality control
documentation; training of personnel; status ,
of audits and findings. C
85-14 Specialists Preoperational test program review; test proce-
4/8-27/85 121 hours0.0014 days <br />0.0336 hours <br />2.000661e-4 weeks <br />4.60405e-5 months <br /> dural review, witnessing, and evaluation; open !
items; emergency diesel generator status; reac- !
tor coolant system cold hydrostatic test wit- i
ness; new fuel receipt inspection and storage;
l quality assurance and quality control inter- }
j faces; facility tour.
[ 85-15 Examiner Oral, written and simulator examinations for ,
i
5/14-17/85 sixteen Senior R(actor Operators and five Reac- l
l tor Operators.
!
l 85-16 Resident Observation of limited emergency exercise; event !
l 4/23-5/27/85 268 hours0.0031 days <br />0.0744 hours <br />4.431217e-4 weeks <br />1.01974e-4 months <br /> followup; auxiliary feedwater pump flushing;
field welding; ultrasonic testing of low pres-
sure safety injection system; and eddy current '
testing of a steam generator.
l 85-17 Examiner Use of Millstone 3 simulator for NRC operator I
3/25/85 licensing examinations, i
(
'
85-18 Specialists Preoperational test program implementation;
5/6-10/85 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> engineered safety feature test status; emergency i
diesel generator status; pre-core hot functional l
test status; test procedure review and verifi- !
cation; new fuel receipt, inspection and stor-
age; turbine building hot functional test status;
quality assurance and quality control; facility i
tours.
85-19 Specialists Preoperational status pertaining to radiation
t 5/7-10/85 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> protection and radioactive waste management, l
l
including organization, personnel training and
qualifications, facilities and equipment, and
procodure development.
I
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_ _ _ _ _ _ - - __
,
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, .
1
INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
85-20 Specialists Safety-related pipe welding; Post Weld Heat
5/13-17/85 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> Treatment of containment shell penetrations;
reactor vessel clevis hard surfacing; review
- of in progress work including welding; allega-
tion followup; and review of service water clad
l elbow leakage.
85-21 Specialists Maintenance program; I&C program; and quality
5/13-17/85 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> assurance and quality control interfaces.
85-22 Specialists NRC independent measurements inspection using
5/20-6/14/85 575 hours0.00666 days <br />0.16 hours <br />9.507275e-4 weeks <br />2.187875e-4 months <br /> the Mobile Nondestructive Examination Laboratory
on selected safety-related piping fabricated
to ASME Code Section III, Classes 1, 2, and 3.
l 85-23 Resident Open items; facility events; Type C leak rate
! 5/20-6/14/85 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> testing; and vital batteries.
!
85-24 Specialists Preoperational test program implementations;
5/20-24/85 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> emergency diesel generator status; pre-core hot
functional test status; test procedure review
and verification; new fuel receipt, inspection
i
'
and storage; quality assurance and quality con-
trol interfaces; facility tours.
85-25 Specialists Preoperational test program; test procedure re-
6/24-27/85 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> views and witnessing. Emergency diesel genera-
i 8/8-11/85 tor status; quality assurance and quality con-
trol; end identification of new EDG components.
l
85-26 Resident Steam generator "J" tube modifications; eddy
5/28-8/8/85 (31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> current testing and tube plugging; preparations
for Containment Structural Integrety Test; IE
Bulletins; Preoperational testing.
85-27 Specialists Prooperational test program; EDG status; pro-
6/3-7/85 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> posed technical specifications status and re-
view; test procedure review and verification;
! engineered safety features tests; pre-core hot
l functional tests; valve problems; turbine
l building hot functional tests; containment HVAC;
l new fuel receipt, inspection and storage; qual-
I
ity control and quality assurance interfaces;
facility tours.
85-28 Specialists Installation of safety-related instrumentation
6/3-7/85 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> and associated control circuits.
1
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10
INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
85-29 Specialists Engineering Assurance In-Depth Technical Audit:
5/28-29/85 inspection of the program preparation.
85-30 Specialists Continuation of Preoperation Security Reviews;
6/17-21/85 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> review of receipt, storage, and protection of
new fuel.
85-31 Specialists Engineering Assurance Program Technical Audit
6/24-28/85 Implementation: inspection of program
85-32 Specialists Followup of violations, unresolved and construc-
8/8-12/85 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> tion deficiency reports; verification of FSAR
commitment to Reg. Guide 1.94 for exemptions
from concrete testing.
85-33 Specialists Containment leakage testing program: review,
7/5-15/85 106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> witnessing and evaluation of integrated leak
rate test, structural integrity test, and local
leak rate test, and online primary containment
leakage monitoring; facility tour.
85-34 Specialists Installation of safety-related electrical /in-
7/8-12/85 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> strumentation components and associated cir-
cuits; quality control documentation and open
items.
85-35 Resident Preoperational inspections; repairs to condenser
7/9-8/12/85 201 hours0.00233 days <br />0.0558 hours <br />3.323413e-4 weeks <br />7.64805e-5 months <br /> air piping; auxiliary feed pump endurance runs;
allegations; electrical termination for diesel
generators; event follow up; steam generator
wet layup; status of reactor water level moni-
toring; and status of Safety Paramater Display
System.
85-36 Specialists QA/QC administration; audit program; procurement
7/22-26/85 111 hours0.00128 days <br />0.0308 hours <br />1.835317e-4 weeks <br />4.22355e-5 months <br /> program; receipt, storage and handling program;
record storage program and document control
program.
85-37 Contractor inspection / evaluation of specific aspects of
l 7/8-19/85 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> licensee's Probabilistic Safety Study to assess
l
whether significant discrepancies exist between
l Technical Specifications, the Final Safety An-
l alysis Report, the Safety Evaluatien Report,
'
and the as-built configuration.
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INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
85-38 Specialists Preoperational test program procedure review,
7/15-19/85 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> test witnessing and evaluation; ESF test status;
l
Emergency Diesel Generator status; Quality As-
surance and Quality Control; ESF valve testing.
85-39 Specialists Emergency Planning Implementation Appraisal;
1 7/22-26/85 organization, training, emergency facilities,
! equipment and emergency implementing procedures.
85-40 Examiner NRC licensee meeting to discuss operator lic-
7/8/85 ensing examinations for Millstone 3. '
85-41 Specialists Quality records and work activities related to
8/5-9/85 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> the inspection and testing of safety-related
electrical equipment and open items.
85-42 Specialists Chemistry and radioactive effluent control pro-
8/5-9/85 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> grams organization, and staffing, training and
qualification facilities, equipment, plans, and
procedures.
85-43 Specialists Preoperational test program procedure review,
8/5-9/84 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br /> test witnessing, and evaluation; review status
emergency diesel generators; engineered safe-
guards test status; quality assurance and
quality control.
85-44 Examiners Oral, written, and simulator examinations for
Senior Reactor Operators and Reactor Operators.
! 85-45 Examiners October 1985 examinations, outside the SALP
assessment period.
85-46 Specialists Open item followup; ASME Code N-5 certification
l 8/12-16/85 226 hours0.00262 days <br />0.0628 hours <br />3.736772e-4 weeks <br />8.5993e-5 months <br /> program; stress reconciliation program, struc-
tural steel bolting; welding (structural steel,
pipe support, tack weld); preservice inspection
data for RCS piping; applicants response to IE
85-47 Specialist Dosimetry program: open items, organization
8/5-9/85 75/25 hours ** personnel selection, facilities and equipment,
calibrations, dose assessment, quality assur-
ance, documentation and recordkeeping, indepen-
dent performance.
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INSPECTION REPORT INSPECTION /
NUMBER AND DATES HOURS AREAS INSPECTED
85-48 Specialists Continuation of preoperational security reviews;
8/5-9/85 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> review of receipt, storage and protection of
new fuel, review of proposed consolidated site
'
security.
85-49 Specialists Operational Quality Assurance Program for design
8/19-23/85 107 hours0.00124 days <br />0.0297 hours <br />1.76918e-4 weeks <br />4.07135e-5 months <br /> changes and modifications, tests and experiments,
measuring and test equipment, and Safety Com-
mittee activities.
85-50 Specialists Allegation and open item followup in electrical
8/12-16/85 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> area.
85-51 Specialists Preoperational test program OIL witnessing of
8/19-9/13/85 184 hours0.00213 days <br />0.0511 hours <br />3.042328e-4 weeks <br />7.0012e-5 months <br /> Engineered Safeguards Features (ESF) tests,
reactor plant component cooling water pump per-
formance test, normal service station transfor-
mer test, and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing of Emergency
Diesel Generator EDG-3; test result evaluation;
and assessment of EDG status.
85-52 Resident Review of Main Condenser Structural
8/13-9/23/85 238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br /> Reports, diesel generator reliability, Three
Mile Island items, main steam indication
and cable repair, Safety Evaluation Report
Items, prevention of cable damage,
potentially significant deficiencies and
open items.
85-53 Specialists Capability to shutdown plant in event of design
8/19-9/23/85 172 hours0.00199 days <br />0.0478 hours <br />2.843915e-4 weeks <br />6.5446e-5 months <br /> basis fire; emergency lighting; reactor coolant
pump oil collection system.
- - Site inspection; Millstone 3 one-third of total hours.
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TABLE 4
ENFORCEMENT DATA
(September 1, 1984 - August 31, 1985)
MILLSTONE NUCLEAR POWER STATION, UNIT 3
A. Number and Severity level of Violations and Deviations
1. Severity Level
Severity Level I 0
Severity Level II 0
Severity Level III 0
Severity Level IV 11
Deviations _1
14
B. Violations and Deviations vs. Functional Area
Severity Level
Functional Area IV V Deviations
A. Operations 0 0 0
B. Radiological Controls 0 0 0
C. Maintenance 0 0 0
D. Surveillance 0 0 0
E. Preoperational Testing 3 0 0
F. Fire Protection 0 0 1
G. Emergency Preparedness 0 0 0
H. Security 0 0 0
I. Construction 8 2 0
J. Licensing Activities 0 0 0
TOTAL 11 2 1
. .
, .,
14
C. Listing of Violations and Deviations
SEVERITY FUNCTIONAL
REPORTS DATES SUBJECT REFERENCE LEVEL AREA
84-20 9/30-11/10/85 Failure to maintain Appendix B IV I
control of low hydrogen Crit. IX
welding electrodes
84-23 10/22-26/85 Failure to follow elec- Appendix B V I
trical installation Crit. V
procedures
85-04 2/19-3/1/85 Failure to translate Appendix B IV I
3/11-22/85 class IE wiring design Crit. III
requirements into docu-
ments
Failure to follow in- Appendix B IV I
tructions for post- Crit. V
wiring changes and
document control
Failure to establish Appendix B IV I
measures to assure pur- Crit. VII
chased equipment con-
forms to procurement
documents
Failure to establish con- Appendix B IV I
trols to prevent use of Crit. VIII
incorrect / defective
items
Inspection program did Appendix B IV I
not verify conformance Crit. X
with design documents
Failure to assure con- Appendix B IV I
ditions adverse to Crit. XVI
quality promptly identi-
fled
85-12 3/18-4/22/85 Failure to provide ade- Appendix B IV E
quate procedure for Crit. V
testing and flushing
85-16 4/23-5/27/85 Failure to provide ade- Appendix B. IV E
quate procedure for Crit. V
flushing
. _ _ . _ ._. . _ . . - - - _ _ _ _ _ _ . - - . . _ _ - . _ _ . _ _ - - _ _ _ . _ _ _ _ _ _ _ _ _ . - ~
! -
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4
1
l 15
i-
SEVERITY FUNCTIONAL
- REPORTS DATES SUBJECT REFERENCE LEVEL AREA
l
85-22 5/20-6/14/85 Failure to properly con- Appendix B. IV I
4
!
trol nondestructive ex- Crit. IX
aminations
%
Failure to properly Appendix B V I
identify welds on con- Crit. V
- trol drawings *
i
j 85-23 5/20-6/14 Failure to provide ade- Appendix B IV E ,
quate procedure for Crit. V 4
- flushing
85-33 8/19-8/23 Failure to provide hy- Fire Protec- DEV F !
, drogen recombiner area tion Evalu-
i
'
and several floor levels ation Report
of main steam valve en-
closure with fire detec-
, tion and steel members
- of ESF building walls
- not fire proofed.
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4
4
2
4
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NORTHEAST UTILITIES o.n. ome...s.e.nsu..,e.mn conn.ci,cui
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P O BOX 270
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(203) C6s s000
September 17,1985
Docket No. 50-423
B11640
Mr. R. W. S tarostecki, Director
SALP Board Chairman
Division of Project and Resident Programs
U. S. Nuclear Regulatory Comrnission
631 Park Avenue
King of Prussia, PA 19406
Gentlemen:
Millstone Nuclear Power Station, Unit No. 3
Svstematic Appraisal of Licensee Performance (SALP)
As we have stressed in previous meetings with you regarding the SALP program,
Northeast
of Utilities (NU) places high priority on achieving excellence in all areas
performance.
performance in those The SALP ratings provide NU with one assessment of our
areas of activity evaluated by that program and
achievement of superior ratings provides an indication that our management
controls are functioning properly and that our primary corporate goal of striving
for excellence in the maintenance of nuclear safety is being realized.
In the past, we have met to discuss the SALP ratings and NRC's evaluation of our
strengths and potential areas for improvement subsequent to publication of the
initial NRC SALP report. As a result, the initial reports have at times not
considered important information that otherwise could have been strengthened
by an exchange between ourselves and NRC. To maximize the potential for full
consideration of relevant views, we are taking this opportunity to provide some
of
theour
pastperspectives
year. on our level of performance on Millstone Unit No. 3 during
We believe it necessary for us to interact positively with the Staff whenever it is
given the finite resources at the disposal of both NU and the
the interest of further improving the regulatory process and assuring that
through discussion, all aspects of a proposed action are understood and
considered by NRC and NU. A significant f actor which should be considered in
assessing licensee performance is NU's consistent atternpts to further the depth
and quality of the exchange with the regulators, both in terms of interacting
with the NRC and participating actively in efforts to disseminate needed
information to the industry. Northeast Utilities executive management is active
in numerous industry initiatives, having made presentations at public meetings
before the Commission as well as meeting with individual Commissioners where
appropriate. The NU management team is active in, and in some instances chair,
various industry groups addressing a broad range of nuclear issues. We also
.;Q +4. J dl Y
- ... .- .- . . . - . _ . - . -- ._. .- . _ _ . _ _ _ _ .
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2
consistently attempt to further improve the quality of the regulatory proce
taking the opportunity to provide comments on proposed rulemakings and g
letters as evidenced in the examples provided in Attachment I.
During this SALP assessment period all major construction and test milestone
have been met to support the November,1985 fuel 16ad date.
As of the end of
the management target. August, the Millstone Unit No. 3 project is 98
that have occurred during this SALP period are as follows:Some of the
o
Completed Steam Generator Hydrostatic Test
o
o Completed Reactor Coolant System Hydrostatic Test
o Completed Millstone Unit No. 3 Emergency Drill
o Completed Structural Integrity Test and integrated Leak Rate Test
o
Completed Engineering Safety Features Test
Conducting Turbine Building Hot Functional Test
In June,1985 a!! system turnovers were completed and any building turnove
thatload
fuel remain date.will be completed on a schedule that supports the November ,1985
Licensing activities during this SALP period have been at a high Thelevel.
Mllistone Unit No. 3 Safety Evaluation Report (SER) was issued in July,1934
The SER
conditions. identified 19 open items, 70 confirmatory items and 7 licensin
Most of these items have been resolved and have been or wi
documented in SER supplements. The remaining issuer, have resolution sched
which sup
meetlngs, port the November,1985 fuel load date. During this period numerous
site audits and reviews and conference calls have been held
licensing activities. to suppor
, Also, during thh period several amendments to the FSAR
and to the ER have been submitted to the NRC. NU's responses to SER iss
well as NRC questions resulting from site audits or reviews, show high-leve
and responsiveness to NRC initiatives. management involvement, clea
demonstrating this are provided in Attachment I to this letter. Examples of indivi
Regarding day-to-day licensing activities, our licensing staff is consiste
responsive to the NRC Licensing Project Manager.
As a result of a
been made to improve the interface with NRC by estab ;
contact within the NU !! censing staff. This has centralized and helped prioritize
the many day-to-day licensing activities occurring between the NRC Lice
routinely Manager and our licensing staff. The NRC Licensing Project Mana
Project
>
j NU's licensing activity status and schedule for response to
!
remaining SER ltems and identified licensing actions to OL issuance.
!
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In general, we believe that this information may prove useful in your
deliberations
you when the
have any questions, SALP
please contactBoard
us. convenes for Millstone Unit No. 3.
Should
Very truly yours,
-
LE ('uk) c
J. F. Opeka 'l
_ _ .
Senior Vice President
I
_ _ _ 'e -
t)
By: E.M roczka N
Vice Pre ent
cc E. L. Doolittle, Licensing Project Manager, NRR
E. B. McCabe, Chief, Reactor Projects Section 3B, DPRP
T. E. Murley, Regional Administrator
T. Rebelowski, Senior Resident inspector, Millstone Unit No. 3
l
1
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ATTACHMENTI
Inputs to SALP Evaluation Process
The following items provide summary examples of some of the meetings, letters
and other
process activities
for Millstone Unit which
No. 3. we believe are relevant to the SALP evalu
The list is not a complete compilation of
pertinent issues and documents and is not intended to suggest that other items
not discussed herein are less important.
-
The NRC staff performed Seismic Qualification Review Team (SQRT)
and Pump
March and Valve Operability (PVORT) Audits during the week of
4,1985.
At the audit exit meeting, the Staff praised the
responsiveness and diligence of NNECO personnel in
questions
audit. raised by the Staff during the document review phase of theanswering
The Staff indicated that all questions raised during the audit
were successfully resolved. The Staff observed that NNECO has a good
qualification program and a thorough understanding of what is required
to maintain seismic qualification throughout the life of the plant.
During the Construction A n sal Team (CAT) Inspection, conducted
between February 19 and
a 22,1985, four Construction Weaknesses
were noted and nubsequeo .. ' ihntified in the Inspection Report (50-
423/85-04).
Although no specific response was required by the
inspection Report, NU provided the NRC our planned course of action
for each of these items in a letter dated July 11, 1985.
We
subsequently received a request from NRC to provide a response to
these weaknesses and to six violations that were identified separately.
Our advanced response to the Identified weaknesses is an example of
Millstone 3 management's commitment to take an aggressive attitude in
responding to NRC concerns and proposing timely corrective actions.
We subsequently responded to the
docketed iollow-up letter. violations in an appropriately
On May 21,1985, a site visit was conducted by the NRC Radiological
Assessment Branch (RAB). The purpose of the visit was to verify FSAR
staffing, radiation monitoring and plant design feature
maintain radiation exposures ALARA. Various aspects of the Radiation
Protection Program and the Health Physics Organization were discussed
with the Health Physics Supervisor and a tour of tne plant was
conducted. The NRC reviewer was very satisfied with the Radiation
Protection Program and the facilities.
The reviewer hdicated that
NNECO had qualified personnel and was well prepared to implement its
Radiation Protection Program.
On June 5,1985 NNECO was granted a schedular exemption to General
Design Criterion (GDC) 4 allowing us to forego the installation of pipe
whip restraints for primary loop piping. This exemption was granted
! based on information provided by NU, Westinghouse and other industry
and agency studies which allowed the NRC Staff to conclude that "the
placement of pipe whip restralnts and jet impingement shields degrades
plant safety, reduces the accessibility for and effectiveness of in-
!
!
<
T
, 4 0
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!
service inspection, increases in-service inspection radiation dosages,
and adversely affects construction and maintenance economics." The
NRC
Federal published the proposed modification to GDC 4 in a July 1,1985
Register notice.
-
At NU's option, since this is not a licensinj; requirement, a simulator
training and examination program was developed and implemented for
Millstone Unit No. 3. The Millstone Unit No. 3 simulator was deli
to the site in December 1984. Following installation, the simulator
l
entered
1985. a verification test phase which was completed on January 15,
From January 15, to February 11, 1985, the simulator was used
to test the training program curriculum and to validate the simulator
against this curriculum. On February 11,1985 training on the simulator
commenced. Each cold license candidate receives 5 weeks of simulato
training which includes 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of actual simulator experience, along
with 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> of classroom training. The accelerated program
cuirainated in the administering of the NRC operator licensing exams
on
on Maythe simulator
13,1985. for our first class of cold license candidates, beginning
examination program is an example of NU's proactive stan
responsiveness to NRC initiatives.
-
An a!!egations
the program was developed and implemented. It consists of
following elements:
-
A full-time administrator has been appointed for providing
overall coordination for allegation reviews. He will report
directly to our Vice President-Generation Engineering and
Construction and is located on site.
-
A visible, on-site facility designated the Quality Concern
Office (QCO) has been established where allegations
regarding project safety can be expressed with an individual
independent of Project Management with a guarantee of
anonymity.
stationed at A full-time consultant has been hired and is
the site to work with us in establishing our
allegations program. This consultant has been involved with
worker allegations in the past and is familiar with the
processes being used at other sites.
-
An Allegation Review Team (Review Team) has been
established to review safety concerns raised and to determine
whether or not there is any basis for the allegation. The
Review Team responsibilities are delineated in a specific
project procedure as well as in a specific charter which has
been established.
The Review Team is comprised of key
management personnel who have a wide range of backgrounds
and extensive experience in the nuclear industry.
-
An Independent Review Board is being assembled to conduct
an independent and detailed investigation of any a!!egation
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which has been deterrnined by the Resiew Team to
potentially have substance. This Board will be comprised of
one or more individuals who have expertise an the areas of
labor relations, law, nuclear construction, and quality
assurance / quality control.
.
NRC regulations do not require that an emergency preparedness
exercise be performed for Millstone Unit No. 3 prior to receipt of a
full-power operating license since the operating license for Millstone
Unit No. 3 will not be the first operating license for the Millstone site.
Nonetheless, an onsite emergency preparedness drill for Millstone Unit
No. 3 was conducted on May 15, 1985 to validate the Millstone Unit
No.3 specific aspects of the Millstone Nuclear Power S tation
Emergency Plan. This drill is illust ative of our efforts (beyond those
necessary to obtain an operating license) to assure ourselves that we
are ready to operate Millstone Unit No. 3 in a manner that will
adequately protect the public health and safety. The Millstene Unit
No. 3 drill was quite successful and demonstrated the readiness of our
organization to respond to an emergency at Millstone Unit No. 3.
.
The NRC 5%ff conducted an audit of the Safety Parameter Display
System (SPDS) for Millstone Unit No. 3 on July 29-30,1985. Although a
formal audit report has not yet been received, the NRC Staff indicated
at the ex t meeting that our overall program was quite good and that
they were impressed with the type of program which we ' had
implemented. On a related matter, unsolicited responses to several
NRC concerns were formally provided to the NRC two (2) menths
before the SPDS audit in an attempt to expedite resolution of; these
items during the audit.
-
In the resolution of fire protection issues we believe we have exhibited
a clear understanding of the issues and conservative, sound technical-
approaches are routinely employed. For example, the informatich
provided in support of the suppression systems in the cable spreacing
area and other areas was judged by the NRC staff to be a valid and
acceptable justification for the existing design. Other examples of our
pro-active approach to addressing issues are the ' docketed submittals
and meetings with the NRC fire protection reYiewer Well in advance of
the Fire Protection Audit. We identified potential deviations to the
NRC along with thorough technical justifications in advance to resolve
them without waiting for the audit to be conducted. The NRC Firs
.
Protection Audit for Millstone Unit No. 3 was conducted at the site
from August 19 through 23,1985. The audit was successful in that NRC
questions were promptly addressed and there were very few significant
items requiring followup af ter the audit.
The staff observed that the
engineering analysis for safe shutdown of the plant was one of the best
observed, to date.
There has been a high level of NU management involvement noted by
the auditors for all of the NRR audits conducted at the site. A high
level of management review and approval of all correspondence to the
.<>>
.s..
-4-
NRC is procedurally required at NU, this ensures a consistently clear
licensee understanding and reponsiveness to NRC initiatives.
-
In letters dated October 26, 1984 and February 19, 1985, NU provided
documentation of our assurance that Millstone Unit No. 3 had been
designed and constructed in accordance with applicable requirements
based on Stone & Webster Engineering Corporation (SWEC) Engineering
Assurance (EA) Program, our strong Quality Assurance Program and
other verification programs. The NRC concurred on April 17,1985 that
a separate Independent Design Verification Program (IDVP) or an
Integrated Design Inspection (IDI) conducted by the Staff was not
necessary to achieve design assurance for Millstone Unit No. 3 and
approved SWEC's EA audit as an acceptable alternative to a third party
review performed at the end of design and construction efforts.
We feel the above examples serve to provide evidence of some of NU's efforts
and accomplishments in the construction, licensing, and testing of Millstone Unit
No. 3 during this SALP period.
.