IR 05000336/1999004

Insp Rept 50-336/99-04 on 990315-31.Violation Noted.Major Areas Inspected:Monitored Licensee Activities During Plant Transition Between Operational Modes,Both During Normal & off-normal Working Hours

ML20206F460
Person / Time
Site:	Millstone
Issue date:	04/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206F457	List: ML20206F455 ML20206F460
References
50-336-99-04, 50-336-99-4, NUDOCS 9905060132
Download: ML20206F460 (77)

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U.S. NUCLEAR REGULATORY COMMISSION

~ REGION I

' Docket No: 50-336 License No: DPR-65 Report Nos: 50-336/99-04 Licensee: Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Facility: ~ Millstone Nuclear Pov ar Station, Unit 2

Location: .Waterford, CT j Dates: ' March 15-31,1999  !

l Inspectors: F. Arner, Reactor Engineer, Region I DRS J. Blake, Region ll DRS ])

P. C. Cataldo, Resident inspector, Millstone l S. Chaudhary, Sr. Reactor Engineer, Region I DRS :

'J. Cummins, Contractor S. Dembek, Millstone 2 Project Manager, NRR P. Habighorst, Resident inspector, Indian Point K. Kolaczyk, Reactor Engineer, Region i DRS D. Lanyi, Resident Inspector, St. Lucie J. Laughlin, Resident inspector, Salem L. James, Reactor Engineer, Region i DRS L. Scholl, Reactor Engineer, Region i DRS J. Zach, Contractor

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. Team Leader: J. Trapp, Senior Reactor Analyst, Region i DRS Approved by: James C. Linville, Chief $

Millstone Branch, Region l l

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. 9905060132 990430 l PDR ' ADOCK 05000336 C PDR

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TABLE OF CONTENTS PAGE EXEC UTIVE S U M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

' I. Management Programs & Oversight . . . . . . . . . . . . . . . . . . . . . .....................1 S1 M a nagement Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 S2 Corrective Action Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 S3 Independent Oversight . . . . . . . . . . . . . . . . . . . . . . . . .... ............ 7 S4 Quality Review Committees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 SS Sta rtu p Pla n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l l . Ope ratio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . ................13 03 . Operations Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 05 Operator Training and Qualifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 06 Operations Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 lil. Maintenance and Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 M1.1 Observations of Maintenance and Surveillance Activities . . . . . . . . . . . . . . . 24 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . . . . . . . 27 M3 Maintenance Procedures and Documentation .............................30 M6 Maintenance Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 M6.1 Maintenance Planning and Scheduling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 IV. E ngineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 E1 Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 il

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TABLE OF CONTENTS (CONT'D)

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PAGE l E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 35 l - E Permanent Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . 35 I

E2.2 Temporary Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 E2.3 Deferred issues Revievi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... . 38 l E2.4 Engineering Support to Plant Operations . . . . . . . . . . . . . . . . ..... . 38 E3' Engineering Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 E3.1 - Operability Determinations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 E3.2 Vendor Manual Cont 71 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 E3.3 Setpoint Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 l

E3.4 Equipment Qualification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

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E3.5 Operating Experience Program . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . 43 1 E3.6 Drawing Control . . .......... ... ....... ........ ............ 44 E8 Miscellaneous Engineering Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 E Emergency Core Cooling Systems Single Failure Vulnerability . . . . . . . . . . . 45 E8.2 (Closed) LER 97-034-00; Containment Sump Isolation Valves are Susceptible to Pressure Locking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 M anagement Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 X1 Exit M eeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

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EXECUTIVE SUMMARY The OSTI findings are one input, of many, used by the Nuclear Regulatory Commission (NRC)

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Restart Assessment Panel (RAP) to make a restart recommendation to the Commission. The I

OSTI concluded that plant hardware, staff and management programs are in place to support a

safe restart and continued operation of Millstone Unit 2. The OSTI conclusion is contingent l

upon the successful completion of the items identified by the licensee as required for restar MANAGEMENT PROGRAMS & OVERSIGHT S1 Manaaement Processes i

. Appropriate standards and expectations for cafety were estabn. ,Jd by senior management and were understood by subordinate managers and staff. The team concluded that management expectations for safe plant operations were communicated, understood and followed by the plant staff. Senior plant management used a variety of communication methods to reinforce expectations. Management expectations regarding employee concems were understood by the staf !

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. Planning and direction for the restart and recovery of Unit 2 were effective. The l application of probabilistic risk assessment (PRA) insights to design and operation of the plant were adequate. Effective ieadership was provided and management involvement in routine activities and emerging issues was appropriate. The Nuclear Oversight Verification Plan (NOVP) and " windows" assessment tools were effective mechanisms for management to assess restart readines . The team's findings, in addition to those of the NRC 40500 inspection team (NRC IR 50 336/99-01), provide the basis for the closure of Significant item List (SIL) item No.1, Management Oversight and Effectiveness; Licensee Staff Safety Culture, and the associated NRC Restart Assessment Plan item S2 Corrective Action Proaram ,

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. The overall corrective action program is adequate to support plant restart. Plant deficiencies are being included in the corrective action program and recent root cause ;

evaluations are thoroug . The team concluded that the licensee's backlog management plan was adequate. In addition, the team concluded that the licensee's process for deferral contained appropriate methodology for the identification of items acceptable for deferral and completion after the Unit 2 restart. Moreover, the team did not identify any items that if not completed prior to restart, would have an adverse impact on the safe restart of Unit 2.

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. The team's findings, in addition to those of the NRC 40500 inspection team (NRC IR 50-336/99-01), provide the basis for the closure of SIL items No.12, Licensee Restart Punch List - Review items Deferred Until After Restart, and the associated NRC Restart

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Assessment Plan item '

S3 Indeoendent Oversiaht

. The NOVP provides effective independent assessment of performance for resolution of

" key issues". The Nuclear Oversight Organization's involvement in operations, maintenance,Lsurveillance and engineering has been satisfactory. Line organization cooperation and support for oversight activities was apparent. The tearh concluded that the various reporting mechanisms employed by the nuclear oversight organization provided an effective means of capturing conditions adverse to quality and en! uing that those conditions were corrected. The reports were critical assessments and provided senior management with a useful " snapshot" of plant performance and areas requiring additional attention. Nuclear oversight audit findings with restart implications are being properly addresse S4 Quality Review Committees

• The plant operations review committee (PORC), station operations review committee (SORC) and nuclear safety assessment board (NSAB) all meet the technical specification (TS) requirements. At the time of this inspection, there were no outstanding oversight committee items that would adversely affect unit restart. The team concluded that the NSAB was providing effective independent oversigh SS Startuo Plans

. The team concluded that the licensee had developed detailed restart plans and established an augmented oversight organization for unit startu OPERATIONS O1 Conduct of Operations l

. The operations department had sufficient personnel to provide coverage throughout the restart period without excessive use of overtime. The shift turnovers observed were of high quality with active participation from groups supporting operations. Pre-job briefings were generally good with a few minor communications weaknesse * The team's findings provide the basis for the closure of SIL item No.13, Operator Performance, and the associated NRC Restart Assessment Plan item l v

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02 . Operational Status of Facilities and Eauioment

. The implementation of processes to establish and maintain configuration control were generally acceptable. However, various condition reports identified problems in the valve lineup and tagout process that indicate implementation was not always effectiv O3 poerations Procedures and Documentation

. Operator procedural quality wan generally good. Some minor validation deficiencies were noted in a few surveillance and emergency operating procedures; however, none had an impact on safe operation of the facility. Appropriate procedural adherence by operators was observe O4 Operator Knowledae and Performance

. Operator performance was generally good and control room demeanor was observed as appropriate. Both licensed and non-licensed operators were aware of plant conditions and maintenance activities in progress.

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. The operators conducted plant evolutions in a safe and controlled manner, and exhibited a conservative approach to equiptr.ent manipulation. Generally, control room operator expeditiously identified plant equipment malfunctions or changes in plant condition However, in one case a technical specification surveillance test requirement, to monitor steam generator temperatures, was not performed in a timely manner. There were no safety consequences as a result of not conducting this surveillance because the required plant parameters were always satisfied. The failure to conduct this technical specification required surveillance is a violation of NRC requirements. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appenoix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report M2-99-106 .

Generally, operator control board awareness and annunciator response were goo However, on several occasions, the team observed operators failed to appropriately communicate unexpected alarms to the Unit Superviso . Operator Trainina and Qualifications e

Alllicensed operators had satisfactorily completed requalification training. A review of the lesson plans, discussions with licensed operators, and observation of plant and simulator performance indicated that the training provided to the operators was sufficient

. to ensure that they could safely restart the unit. Modification training for the operators was appropriate to effectively communicate plant changes completed during the outag O6 Operations Oraanization and Administration

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. Operations department staffing levels were adequate to support the safe operation of the plant. Communications within the operations department and with other site vi i

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. organizations were good. Operators generally initiated operability determinations in response to degraded equipment conditions. The team observed good command and !

control of shift activitie l 07 Quality Assurance in Ooerations i

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Nuclear oversight observations provided accurate accounts of activities involving the conduct of operations. Self-assessments were critical and the licensee's corective action plans for improvement were appropriat MAINTENANCE AND SURVEILLANCE M1 Conduct of Maintenance

. The quality of maintenance activities observed was generally good. Maintenance i technicians conducted good pre-job briefings in the maintenance shops and briefed '

operators on job scope prior to beginning wor i e Procedure adherence by the maintenance staff was generally good. The team observed instances where work was stopped to clarify or revise maintenance procedure . The maintenance workers were knowledgeable of assigned maintenance tasks and had received appropriate training. The team concluded that the maintenance rework rate was at an acceptable level, and that the licensee had adequately resolved maintenance rework issues through the corrective action system. Appropriate maintenance supervisory oversight of field activities was observe M2 Maintenance and Material Condition of Facilities and Eauioment

. Necessary equipment repairs were either completed or scheduled for completion prior to plant restart. Maintenance backlogs were being appropriately managed and routinely -

assessed for impact on operations. The control of operator work-arounds and control room '.ieficiencies was also found to be adequate to support plant restart. The plant material condition and housekeeping were acceptable. The Backlog Reduction and

. WoA-It-Now (WIN) Teams had a positive impact on addressing emergent work and i reducing the automated work order (AWO) backlo * These findings, along with the review of temporary modifications (bypass jumpers)

documented in Section E2.2 of this report, provide the team's basis for closure of NRC

. Significant item List item 7, Bypass Jumpers, Operator Work-arounds & Control Board Deficiencies and the associated NRC Restart Assessment Plan item M3- Maintenance Procedures and Documentation

• The team concluded that procedures reviewed were generally adequate for the intended task ,

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M6 Maintenance Oraanization and Administration e Performance in the area of planning and scheduling was mixed. Planning was thorough, with detailed work packages prepared to support most AWO activities. Schedule adherence did not meet licensee's goals primarily due to emergent issues. The team did not observe any instances where schedule pressures or changes adversely affected plant safet . The licensee's performance in assessing the safety / risk of planned maintenance was acceptable. Safety assessments for maintenance activities were addressed by l appropriate procedures and the risk significance of planned activities was discussed at planning meeting * The licensee had identified and/or completed surveillance tests required for plant restar . The team's findings provide the basis for the closure of SIL item No. 6, Work Planning and Control, and the associated NRC Restart Assessment Plan item ENGINEERING AND TECHNICAL SUPPORT E1 Conduct of Enaineerina

• The engineering department managed the planned and emergent activities well. Daily planning of issues at the morning meeting set the priorities of both the system and design engineering departments. Communication with and support to other departments was good. The identification, documentation and control of issues within the condition report (CR) system was good. Corrective actions associated with CRs and other open items were properly tracked within the action item tracking and trending system (AITTS).

The team did not identify any CR issues that had not been properly screened and dispositioned for deferral until after the restar E2 Enaineerina Support of Facilities and Eauipment -

• The team found the design control process was being properly implemented. The technical quality of changes was good and modification package content, including the 10CFR50.59 screening and safety reviews, are comprehensive. Post-modification testing accomplished the verification of important design change attributes. The use of a Quality Review Board has contributed to improvements in the quality of the engineering product . Engineering has been effective in resolving issues. As a result, the use of temporary modifications was minimal. The number of installed temporary modifications (TMs) was low and below the plant goal. The team concluded that the evaluation and control of temporary modifications was good and that the installed TMs had no adverse impact on safe plant operatio viii

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evaluated. No deferred modifications were identified that would affect safe plant '

operatio I

. The licensee had substantially improved the design and licensing basis of the control room heating ventilation and air conditioning (HVAC) system. Inconsistencies between the system design criteria contained in the final safety analysis report (FSAR), TS and ;

the operating and surveillance procedures were eliminated. Single failure design errors were corrected. The system readinesa review was thorough. The control room HVAC surveillance testing program was a strength.'

E3 Enaineerina Procedures and Documentation

• The operability (OD) process was comprehensive. Operability determinations were technically sound and documented an adequate basis for establishing operability of the

degraded component or syste I

. The licensee program to maintain the accuracy of vendor manual information was being properly implemente . The licensee implemented an adequate setpoint process and the Millstone Unit 2 Instrumentation and Control (l&C) setpoint specification provided a clear definition of the program for the generation and documentation of safety-related, instrument and control setpoints. In general, the setpoints selected for review by the team were properly documented, reviewed, and supported by appropriate calculation . The licensee implemented effective commercial grade dedication and item equivalency evaluation programs and performed appropriate evaluations to support plant restar .- The team concluded that the operating experience program was functioning adequately to support restart. The backlog of reviews had been evaluated by the licensee to identify those issues requiring review before restart and appropriate priorities had been assigned to these issue . The majority of the drawing issues that have been identified over the past 12 months have had minor safety significance. Current procedures and processes for updating operational critical drawings in the control room had been followe E8 Miscellaneous Enaineerina issues

. The team concluded that the design changes resolved the emergency core cooling system (ECCS) single failure vulnerabilities. Additionally, the aspects of the design changes reviewed, with the exception of the emergency operating procedures (EOP)

changes, had been properly implemented. The licensee demonstrated that appropriate administrative controls were in place to ensure that the EOPs would be corrected prior to

- becoming effective. These findings provided the basis necessary for the closure of SIL 5 IX

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• ,.The licensee's corrective actions were considered appropriate to correct the issue identified in licensee event report (LER) 97-34. The licensee's April 1998 pressure locking tests indicated the valves would have remained operable and therefore the error was of minor significance. However, the failure to use appropriate assumptions when j initially analyzing the containment sump valves for susceptibility to pressure locking and I thermal binding (PLTB) was a weakness in design control. -These findings provided the I basis necessary for the closure of SIL ltem 20.7A and LER 50-336/97-03 I u

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! Reoort Details l

The objective of the Operational Safety Team inspection (OSTI) was to provide current information to the NRC Restart Assessment Panel by evaluating the readiness of plant hardware, staff, and management programs to support a safe restart and continued operation of Millstone Unit 2.~ The OST) observed operations at Unit 2 over a 17 day period; The OSTI l (team) monitored licensee activities during plant transition between operational modes, both during normal and off-normal working hours. The OSTI performed an independent, broad scope assessment in the areas of management programs and oversight, operations, maintenance and surveillance, and engineering and technical support. The OSTI used selected sections of NRC

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Inspection Manual Procedure 93802, " Operational Safety Team inspection," to conduct this inspection activit l. Manaaement Proarams & Oversiaht S1 Management Processes Inspection Scope The team reviewed records, procedures and performance measures and interviewed licensee management and staff to determine the adequacy of the management team to provide direction, standards, and expectations to the plant staf Observations and Findinas Standards and Expectations The team reviewed the licensee's policies and instructions (e.g. Millstone Focus 99, Northeast Utilities (NU) Nuclear Standards and Expectations, Operational Focus Enhancement Plan, Nuclear Oversight Verification Plan) to assess the licensee's success in establishing expected standards of performance. The team found that efforts to raise performance standards were evident. Written safety standards were revised and senior management conveyed expectations for meeting these standards by the statements they made and the examples they set at meetings and during interfaces with plant staff. Interviews with the plant staff indicated that established standards and expectations were well understood and were generally being me Communications Licensee management used a variety of methods to communicate and reinforce their expectations for safe plant operation. For example, daily newsletters were published on items of current interest, posters outlining management expectations for work activities were prominently displayed, and both formal pre-planned and impromptu meetings were conducted daily by individual line organizations and by line organization managers and supervisors. The information in the daily pre-planned management meetings was

presented by the Shift Managers with each key support department represented. Senior management presence at these meetings was evident with their focus on goal setting and ensuring expectations for safe plant operations was reiterated. The team observed several meetings and found them well run, with the necessary personnel available to

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make key decisions in a timely manner. The team observed that management  !

expectations were further reinforced by discussing condition reports (CRs) and human i performance errors during the management meetings. In addition to the management l meetings, each line organization had separate debriefs to discuss the issues raised at

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the management meetings. During the debriefs they also reviewed scheduled activities, ;

discussed events and operating experience reviews where appropriat l Probabilistic Risk Assessment l l

The probabilistic risk assessment (PRA) staff reviewed each proposed design change to j ensure that it did not adversely impact plant risk. The PRA staff also established i procedures for including risk insight into the schedule for on-line test and maintenance i evolution '

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Manaaement/Suoervisorv Oversiaht Operations and maintenance management interfaced frequently with subordinates through job-site tours and meetings. A Unit 2 Operations Department Work Observation Program assured that operations department managers performed regular observations of ongoing work. In addition, there was a structured management observation program ;

that required management and supervisory personnel to undertake plant tours and I report observations regarding staff working conditions and the material condition of the plant. The team reviewed a sample of these reports and found that the findings from l

these reports were properly entered into the corrective action program and discussed with the plant staf .

Employee Concerns The team conducted a random survey of plant staff to solicit their insights on the Employee Concems Program. The team contacted approximately twenty individuals from maintenance, operation, quality control (QC) staff, and engineering. All the individuals interviewed indicated that they were aware of the program and had confidence in the implementation of the process. This observation was consistent with the findings of the recent NRC corrective actions inspection (NRC Inspection Report (IR)

50-336/99-01).

Staffina The team verified that staff overtime was being controlled in accordance with Nuclear Generation Procedure (NGP) 1.09, " Overtime Controls for all Personnel at Millstone Station," and the NRC Policy Statement on working hours (NRC Generic Letter 82-12).

There were only three CRs written during the past 6-months regarding individuals exceeding the overtime guidelines at Unit 2. The three cases involved an engineer attempting to complete a task prior to vacation, a fire watch, and a technician. The corrective actions for each CR were appropriate. The licensee's Performance Evaluation group recently completed surveillance MP2-P-99-025, " Unit 2 Management and Staff Overtime." The surveillance reviewed the overtime for several plant i

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departments and used the security computer data to validate overtime hours. The conclusion of this surveillance was that no personnel were identified exceeding overtime

. limits that would potentially present a safety hazard and that the line organization has been proactive in the self identifying and correcting overtime limit violations. The team noted that overtime controls were frequently discussed during department meetings and plant staff interviewed were aware of the station overtime polic Restart Readiness Monitorina

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The licensee's process for ensuring restart readiness was centered around the implementation of the NOVP and the " windows" department readiness assessment These assessment techniques provided a useful measurement of plant restart i readiness. The NOVP is the principle tool used by management to ensure the key issues identified for restart are being satisfactorily accomplished. In addition to the NOVP, each line organization used the " windows" readiness assessment tool to evaluate

- key performance criteria within their organizations. The input from these readiness reviews was derived from the various self-assessment Nuclear Oversight reported on ten Unit 2-specific areas and six site-wide areas in the March 1999 report to senior management. The areas of health physics, chemistry, maintenance, work control / planning, corrective action, self-assessment, and fire protection were all rated as satisfactory. Security and training were rated satisfactory for ;

the site. Operations, engineering, and procedure quality / adherence were rated as l

- tracking to satisfactory for restart readiness. There was a plan for each area to make these areas satisfactory and ready for restart. Emergency planning, environmental monitoring, year 2000 computer issues (Y2K), and organizational realignment were not satisfactory from a site perspective. Management's attention was properly focused on the areas that need improvemen Self-Assessments The team evaluated the licensee's processes for performing self-assessments to ensure that they were effective in identifying and addressing safety significant issues which j could impact unit restart. The team reviewed a sample of line organization self- j assessments and recent line management observations, witnessed management observations, and conducted interviews with cognizant staff. The recent NRC 40500 )

team inspection (NRC IR 50-336/99-01) also reviewed this area. The OSTI team confirmed that the self-assessment process was functioning well. A wide variety of self-assessment tools were in place and assessments were performed on a regular basi i Self-assessments were generally timely, appropriately critical of personnel performance, and contained sufficient detail to be an effective tool for improving plant performanc !

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4 Conclusions' l l

Appropriate standards and expectations for safety were established by senior management and were understood by subordinate managers and staff. The team concluded that management expectations for safe plant operations were communicated, understood and followed by the plant staff. Senior plant management used a variety of communication methods to reinforce expectations. Management expectations regarding employee concerns were understood by the staf Planning and direction for the restart and recovery of Unit 2 were effective. The application of PRA insights to design and operation of the plant were appropriat Effective leadership was provided and management involvement in routine activities and emerging issues was adequate. The NOVP and " windows" assessment tools were effective mechanisms for management to assess restart readines i I

The team's findings, in addition to those of the NRC 40500 inspection team (NRC IR 50- l 336/99-01), provide the basis for the closure of SIL item No.1, Management Oversight ,

and Effectiveness: Licensee Staff Safety Culture, and the associated NRC Restart i Assessment Plan item S2 Corrective Action Program Inspection Scooe The team conducted interviews and reviewed documents to assess the adequacy of the ;

corrective actions program. Two inspectors spent one week reviewing the Unit 2 updated submittal regarding the NRC 10 CFR 50.54(f) Information Request, dated March 5,1999. The team reviewed the " Items to be Completed After Restart" section of the submittal to assess the licensee's process and basis in deferring items for completion until after Unit 2 restart. In addition, the Unit 2 Restart Management Backlog Plan was assessed for the integrated impact on the licensee's ability to both adequately prioritize closure of the large number of open items and maintain focus on safe operation of the !

unit post-restar l b. Observations and Findinas Problem Identification Processg3 The corrective actions program has a low threshold for condition report (CR)

identification and initiation. The average number of CR's submitted per month is approximately 300,- The team noted that the plant staff were generally diligent in writing CRs to document deficiencies identified during this inspection. The operators' threshold for identifying deficiencies was generally good. The plant equipment operators (PEOs),

in particular, were observed identifying and correcting deficiencies in the plant. Those problems that could not be immediately corrected were documented in either trouble reports or condition reports (CRs).

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Root Cause Evaluations The team reviewed a sample of root cause investigations conducted several years ago,

- six from late 1998cand three from the first quarter of 1999. -The reports demonstrated an improving trend in_ quality. Historically, there were examples of narrowly focused root causes, which led to marginally effective corrective actions. The root cause investigators used a variety of techniques that were appropriate. The more recent examples provided adequate detail, including figures and flow paths, so that the situation could be i understood. The corrective actions were well developed. A review of the status of the '

corrective actions associated with the CRs indicated that the corrective actions are being accomplished in a timely fashio l CR Feedback Process The corrective action process requires that the CR initiator be informed of the resolution of the CR. The team contacted ten CR initiators to verify that the CR initiators were informed of the corrective action for the issues they had identified. Of the ten individuals, nine were informed and indicated that the feedback process was working well. One individual could not recall being informed of the corrective actions implemented. One individual contacted implied that the corrective actions implemented were not fully satisfactory; however, in this case, the CR indicated that the disposition was accepted by the individual's superviso Deferred Items Review On March 5,1999, the licensee provided the latest update submittal to the 10 CFR 50.54(f)information request of April 16,1997. Specifically, the submittal contained the

" Items to be Completed After Restart" list, which consisted of items that the licensee had ;

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' determined to be def.errable until after Unit 2 restart. This latest submittal was comprised of items that had been.added by the licensee since the previous submittal of December 1998, which was also reviewed by the NRC as documented .in NRC Inspection Report 50-336/98-0 j The team reviewed approximately 1700 items on the deferred items list, and focused on items based on safety significance, operability, or other issues such as the impact on

- design or licensing basis. The team subsequently selected approximately 100 of the 1700 items for further review, such that an adequate assessment of the licensee's deferment could be made. The team also reviewed the methodology used by the licensee to defer items post-restart and determined that the process adequately identified items that were appropriate for deferral. The process was improved based on lessons leamed from Unit 3, as well as from effectiveness reviews from the licensee's corrective action program. The new process clarified operability questions relative to the appropriateness of deferral or completion prior to restart. The new process also established administrative requirements for addressing licensing or design basis issues,

. such as the need for specific license amendments, prior to restar ;

Based upon the review of the selected items, the team determined that the licensee's deferral of the items was appropriate. However, in several instances, the licensee had i provided weak documentation reg ? iing the basis for deferral. While the licensee's '

process required, in part, that the ">stification must be a stand alone explanation," such that the justification would be very clear and provide enough information for NRC review, the team found that the justification for deferral provided by the licensee was not always sufficient to afford an independent conclusion that supported deferral of the item. In all cases, the licensee provided the necessary information or documentation to support their i decision for deferral of the item I in addition to the specific deferred items inspection, OSTI team members supplemented this inspection effort with a review of approximately 15 EWRs that had been deferre I The EWRs deferraljustifications were all appropriat Backloa Manaaement On December 22,1998, the licensee submitted the Restart Backlog Management Plan

~ to the NRC. The licensee's plan provides for an integrated, structured approach to manage and disposition the backlog of identified items at the time of Unit 2 restart. In addition, the plan also attempts to balance the closure of the identified items with the need to focus on safe, event-free plant operations. Through December 18,1998, the licensee's identified backlog consisted of 2765 deferred items. The licensee has established specific dates for completion of these item The team noted that the licensee plans to develop guidance for the backlog management plan, which will reflect the following functional requirements:  ;

• The disposition of unresolved item reports (UIRs), independent Corrective Action Verification Program (ICAVP) discrepancy reports (DRs), and the remaining recovery ba :klog items (described previously as '* deferred items").

• Existing work control processes will be used to disposition the item * Performance monitoring will be established, tracked, and monitored 'or the backlog plan; key performance Indicators (KPis) will also be reported quarterl . Management will conduct performance reviews of the KPl goals. In addition, periodic assessments will be conducted to ensure management stcr.dards continue to be conservatively applie i On March 30,1999, the licensee submitted a change to the Backlog Management Plan commitments for both Units 2 & 3. Specifically, the licensee's timetable for completion of ICAVP DRs for Unit 2, was changed from prior to entry into Mode 2 following the ,

completion of the next refueling outage, to an expected completion date of December 31, l

2001. This commitment schedule change was made based on lessons learned from '

Unit 3. The basis for this change appears to be appropriate, given the licensee's efforts 1 in the assessment of both +he safety significance of the items that have been deferred, as well as the overall impact the backlog management plan would have on the continued safe, event-free operation after restar l

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7 Conclusions l

The overall corrective action program is adequate to support plant restart. Plant deficiencies are being included in the corrective action program and recent root cause l evaluations are thoroug The team concluded that the licensee's backlog management plan was adequate. In l addition, the NRC concluded that the licensee's process for deferral contained l appropriate methodology for the identification of items acceptable for deferral and completion after the Unit 2 restart. Moreover, the team did not identify any items that if i

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not completed prior to restart, would have an adverse impact on the safe restart of Unit 2.

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The team's findings, in addition to those of the NRC 40500 inspection team (NRC IR 50-336/99-01), provide the basis for the closure of SIL items No.12, Licensee Restart Punch List - Review Items Deferred Until After Restart, and the associated NRC Restart Assessment Plan item !

l S3 Independent Oversight l

! Inspection Scope  !

The team reviewed procedures goveming audits, surveillances and the Nuclear

- Oversight Verification Plan (NOVP) process, reviewed NRC inspection reports, observed a NOVP Panel meeting, and interviewed licensee representatives to assess the effectiveness of independent oversight provided by the Nuclear Oversight Organizatio Nuclear Oversight audit findings were reviewed to verify that significant audit findings, with potential unit restart implications, had been resolve Observations and Findinas Performance associated with each of several key issues was evaluated and documented in oversight evaluation reports using a method that provided for measurement consistency. Data from oversight evaluation reports were assessed using predetermined acceptance criteria and the results were provided to senior management in monthly reports. Evaluations were made objectively and the results were consistent

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with NRC inspection findings. Evaluation reports were communicated orally to the line organization to provido prompt feedback and then complemented with periodic written report .

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Throughout the NOVP process, the Nuclear Oversight Organization provided valuable independent feedback to station management on the status and quality of operations, maintenance, surveillance and engineering restart activities. The audit program is aggressive in breadth and scope and achieved its targeted number of audits in 199 Audits by Nuclear Oversight provided comprehensive assessments in selected i

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programmatic areas. They produced performance-based findings that were of value for improving program effectiveness. Surveillances were typically performance-based and identified opportunities for improvemen Line managers from operations, maintenance, and engineering respect the role of l

' Nuclear Oversight and value their input as opportunities for improvement. They actively participate in audit exit meetings and NOVP Panel meetings. Good interaction between Nuclear Oversight and line managers was apparen The team reviewed two stop work orders issued by Nuclear Oversight. While neither o j the issues had a significant adverse effect on plant safety, the fact Nuclear Oversight I was empowered to issue the orders, and was supported by senior management, indicates a healthy oversight functio The team reviewed findings from Nuclear Oversight audits and other reviews. The response to findings was timely and the team determined that findings with potential restart implications had been properly dispositione The licensee assesses the effectiveness of Nuclear Oversight by using a variety of independent groups such as the Joint Utility Management Assessment (JUMA), Institute of Nuclear Power Operators (INPO), and/or independent assessment teams. The OSTI team reviewed the JUMA report and that of the independent assessment team. The audit findings were clear, objective and appropriately included in the corrective action proces Conclusion The NOVP provides effective independent assessment of performance for resolution of

" key issues." The Nuclear Oversight Organization's involvement in operations, maintenance, surveillance and engineering has been satisfactory. Line organization cooperation and support for oversight activities was apparent. The team concluded that the various reporting mechanisms employed by the nuclear oversight organization provided an ef'ective means of capturing conditions adverse to quality and ensuring that those conditions were corrected. The reports were critical assessments and provided senior management with a useful" snapshot" of plant performance and areas requiring additional attention. Nuclear oversight audit findings with restart implications are being properly addresse i

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S4 Quality Review Committees I

a. Inspection Scooe l

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The effectiveness of oversight provided by the Plant Operations Review Committee (PORC), Station Operations Review Committee (SORC) and Nuclear Safety Assessment Board (NSAB) was reviewed. The team observed meetings, reviewed meeting minutes and interviewed cognizant personnel, b. Observations and Findinas

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Plant Operations Review Committee The team observed several PORC meetings and verified that the PORC meetings comply with TS and the members were capable of conducting TS required reviews. The PORC members were reasonably well prepared for the issues on the agenda and asked pertinent and challenging technical questions of the presenters and each other. The PORC meetings were conducted in a professional manne Meeting minutes are distributed in a timely manner and contain information from the presenters. However, the team noted that the meeting minutes did not always provide sufficient detail to determine how PORC member concerns were addressed. For example, in meeting minutes 2-99-051, the Chairperson requested that an individual making a presentation to PORC ask licensing to provide the reason for a note in the procedure being presented. The meeting minutes do not reflect the importance of this request or how licensing was expected to respond to POR Site Ooeration Review Committee The SORC members were well prepared for the items on the meeting agenda and asked technical questions of the presenters. ' Walk-in" items (i.e., items which are not pre-distributed to the members) were discouraged. One " walk-in" item at the observed i meeting was rejected because of a concem of a member which could not be addressed at the time by the presenter. The members adequately represent the site-wide perspective of the SORC. The SORC meets weekly rather that the TS minimum of once every six months. This maintains the agenda manageable, the meetings reasonably short, and issues current. The team reviewed the SORC backlog items and verified that there was no potential restart issues at the time of the inspectio Nuclear Safety Assessment Board The team evaluated the effectiveness of the NSAB to provide independent oversight to the organization. The team verified that the NSAB met the requirements of the T Procedures and processes are in place to ensure continued compliance with T Subcommittees are effectively used to relieve the full NSAB of detailed paper reviews and allows it to maintain a broader perspectiv ,

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' independent members, including the Chairman, provided in-depth and probing questions and observations. They also provide mentoring to the subcommittees. Members of the NSAB, who are employees of the licensee, are senior managers and effectively remove themselves from the line management role for their roles as independent oversight on the NSAB. The NSAB meeting minutes are reasonably timely and thoroug Conclusion The PORC, SORC and NSAB all meet the TS requirements. At the time of this inspection, there were no outstanding oversight committee items that would adversely affect unit restart. The team concluded that the NSAB was providing effective ,

independent oversigh l SS Startup Plans Inspection Scope The team reviewed the Operational Readiness Plan, special procedure (SPROC) OP98-2-08, " Unit 2 Restait Following 10CFR50.54(f) Outage," and supporting documents. The team also assessed the effectiveness of the startup and power ascension organization oversight during unit heatup activities. This review was accomplished through observations, interviews, and documentation revie Observations and Findinas

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The Operational Readiness Plan (ORP) addresses those aspects of unit operation that provided the basis for the unit shutdown in 1996. Appropriate restart goals were !

identified in the ORP as key issues. Each key issue had an assigned manager responsible for monitoring it's resolution. Interviews with the key issue managers indicated that the assigned individuals were aware of their responsibilities and issue status. The ORP considers the organization, system readiness, operational readiness, regulatory readiness, and communications. The team verified that appropriate aspects i of the plan had been completed. The Nuclear Oversight Verification Plan (NOVP) was i independently assessing performance in each key area on a biweekly basi ~ Management effectively used this process to focus attention in areas needing improvement for restar SPROC OP98-2-08 provides adequate hold-points for operations and unit management to control unit restart. The procedure appropriately required input from line organizations, oversight, and PORC. _ Appropriate independent oversight of restart activities was included in this procedur .

c. Conclusign The team concluded that the licensee had developed detailed resta i plans and ;

established an augmented oversight organization for unit startu j ll. Operatiorg Backaround & Plant Status ,

At the start of the OSTI, Unit 2 was in cold shutdown (Mode 5). On March 25,1999, the plant entered hot shutdown (Mode 4) and on March 31,1999, the plant entered hot standby (Mode 3). The team observed operations activities during both mode change The team's observations were performed over a 17 day period that included over 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> of shift observation including backshift and weekends. The team's findings '

documented in this report provide the basis for the closure of SIL item No.13, Operator !

Performance, and the associated NRC Restart Assessment Plan item I l

01 Conduct of Operations '

a. Inspection Scope The team assessed the adequacy of overtime controls, shift turnovers, and pre-job brief b. Observations and Findinas Overtime Controls The team reviewed operator time and attendance records from January 1 through March 22,1999. The team noted that working overtime was routine but operators rarely worked overtime beyond established administrative limits. The limits for overtime were defined '

in Nuclear Group Procedure (NGP) 1.09, " Overtime Controls for All Personnel at Millstone Station."In a few instances where overtime limits were exceeded, prior management approval was properly obtained and documente Operating crews worked on average about 12 to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of overtime each work wee During interviews shift managers and their crews described many of their crew members as being tired; however, the team did not identify any operator fatigue related issues during the inspection. The licensee planned to transition back to a five-crew shift rotation, that provides operators more time off than the current four-crew shift rotation, prior to the plant startu .

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Shift Turnoven The team observed fifteen (15) shift relief and turnovers. The turnovers were of good quality, in that necessary information concerning plant systems status was discussed and understood by the oncoming shift. It was noted that each member of the control room staff walked the main control room boards with their relief and discussed plant status. A shift turnover briefing for the oncoming shift was held after the individual operators had completed their station turnovers. During the briefing, each individual gave an update on activities related to their station. Active participation in the shift turnover by support groups to operations (work control, maintenance, chemistry, health physics, security, etc.) was evident. The Shift Technical Advisor routinely provided adequate risk insights during shift turnover. The shift relief and turnovers observed were conducted in accordance with the instructions delineated in procedure U2 OP 200.1,

" Unit 2 Conduct of Operations."

A recent self-assessment report identified that the shift turnover report did not evaluate alternative plant configurations relative to 10 CFR 50.59 safety evaluation screen Team review of various shift turnover reports did not identify alternative plant configurations for which a safety evaluation screen was necessar Pre-Job Briefs The team observed several pre-job briefings and found that they were generally detailed and thorough. There were detailed discussions en responsibilities, precautions, expected plant conditions, contingencies, and a strong emphasis on plant safety and taking the time to do the evolutions correctly. The plant briefings for the transition from Mode 5 and Mode 4 and for SPROC EN98-2-23, " Operational Testing of 2-SI-651 (DCR M2-98055), IPTE," that temporarily removed shutdown cooling from operation, were performed well with good participation by the system engineers. During the plant heat-up briefing, good insights were provided on reactor coolant pump performance and expected motor vibration value The team also observed the shift brief in preparation for the Mode 3 transition, and considered this brief adequate. The control room briefincluded appropriate guidance regarding termination of the heatup based on increased leakage from the 2-SI-652 valve

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(inboard shutdown cooling isolation valve), and the safety injection tank valve leakage; however, the team noted that no specific valve leakage limits were established (i.e., if the leakage from the reactor coolant system gets worse). Notwithstanding this lack of specificity on termination of the heatup, operators were sensitive to the known leakag Precautions and limitations from OP-2201, " Plant Heatup," were adequately discusse During observations of a pre-evolution briefing for procedure SP 2610A, " Auxiliary Feedwater Test," misinformation was provided to the plant equipment operator (PEO) on the position of the atmospheric dump valve to be operated. The PEO appropriately notified and corrected the communication error prior to manipulation of the atmospheric dump valv .

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-c. - Conclusion The operations department had sufficient personnel to provide coverage throughout the restart period without excessive use of overtime. The shift tumovers observed were of high quality with active participation from groups supporting operations. Pre-job briefings were generally good with a few minor communications weaknesse l 02 Operational Status of Facilities and Equipment Inspection Scooe The team assessed plant configuration controls by reviewing system equipment alignments, conducting system walkdowns, and reviewing the equipment tagging process and the locked valve progra Observations and Findinas i Review of Valve and Breaker Lineuos The team reviewed completed valve and breaker lineups that the licensee had performed to support plant heatup, observed operations personnel retuming selected portions of systems to service (i.e., reactor coolant, auxiliary feedwater, and emergency diesel genemtor starting air), and observed operations personnel perform independent verifications of these activities. The team also reviewed the PEO training guides and determined that the operators had been adequately trained and were qualified to perform valve lineups and independent verification . The team did not identify any problems with the valve and breaker lineups, the process for retuming systems to service, independent verifications, or qualification of valve alignment personnel. However, during the OSTI and the month prior to the OSTI, the licensee issued several condition reports which documented problems with the i implementation of activities related to the valve and breaker lineup processes (See the documents reviewed section of this report for examples).

These CRs documented instances of inadequate valve lineup restoration and inadequate valve lineups. The inadequate valve lineups were either valves added by modifications that did not get incorporated in all required lineups and documents, or discrepancies between valve lineups and drawings, and/or procedure changes that did not get incorporated into the valve lineup. The licensee was evaluating the problems documented in these condition rep 3rts to determine their causes and corrective action These valve lineup deficiencies were either licensee identified or self identifying. There were no safety consequences as a result of these deficiencies. Therefore, the failure to follow procedures as related to these events was of minor safety significance and is not subject to formal enforcement actio r

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System Walkdowns The team performed reviews of system valve lineup sheets and piping and instrumert drawing (P&lDs), and also performed walkdowns of selected portions of the auxiliary feedwater, service water, reactor building closed cooling water, and the 4.16 kilovolt systems. During the reviews and walkdowns, the team verified that: system lineup procedure requirements matched plant drawings and as-built configuration; valves in the flow path were in the correct positions; electrical breakers were properly aligned; and the condition of the components and equipment observed was acceptable. The team did not identify deficiencies with plant drawings, valve alignments, or condition of component Eauioment Taaaina Proaram The team randomly selected equipment isolation and control tags hung in the plant and verified that the information on each of the tags agreed with information on the clearance sheet, the tag was installed on the correct component, and the component was aligned correctly. The team also selected and walked down active equipment clearances and verified that the information on the clearance and tags agreed, tags required by each of the clearances was on the correct component, and the component was in the correct position. Additionally, the team observed an operator implement tagout 2-0650-99 to isolate the "A" high pressure safety injection pump seal cooier. The tagout was appropriately applied. The clearance /tagout process appeared to provide adequate controls to ensure personnel safety and plant configuration. However, several CRs

. documented recent tagging and maintenance problems indicating that implementation of the tagging program has not been fully effective. The licensee was evaluating these problems to determine their causes and corrective actions at the end of the inspectio Locked Valve Proaram The team randomly selected locked valves in various safety systems and vent and drain valves associated with containment integrity. The team verified that the valves were locked in the position required by the locked valve lineup list. One minor instance existed where two integrated leak rate test valves (2-AC-113 and 2-AC-115) outside the

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containment boundary were locked and not reflected within 2-OPS-1.32, " Locked Valve Checklist." The licensee processed a locked valve evaluation form to add these two valves to the locked valve checklis Conclusion i

The implementation of processes to establish and maintain configuration control were i generally acceptable. However, various condition reports identified problems in the l

- valve lineup and tagout process that indicate implementation was not always effectiv {

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03 Operations Procedures and Documentation Inspections Scope The team reviewed selected plant and system operating procedures; observed operators' implementation of procedures; assessed temporary procedure changes; and assessed whether risk significant operator actions had been adequately proceduralize Observations and Findinas Procedure Quality The quality of operating and administrative procedures were generally good. The

. procedures reviewed were technically accurate and provided an appropriate level of detai Most operations procedures had been recently revised as part of a procedure upgrade program (PUP). Since April 1998, approximately 60 technical procedures had been upgraded by the PUP that included verification and validation of the procedures,. The team noted that the revised procedures appropriately followed the procedure writer's guide. There were only three operations procedures which had not been upgrade These were scheduled to be completed in May 199 On March 31,1999, the team observed that e.a Unit Supervisor (US) had marked up copies of SP 2606B, " Containment Spray Operability /IST Facility 2" after completion of the surveillance. The surveillance procedure had incorrect information on the position of the recirculation valve for the "B" containment spray pump. The team confirmed that a procedure change was being processed and that actions to complete the surveillance were consistent with the guidance in DC-4, " Procedural Compliance."

The quality of plant heatup procedure OP-2201 was good. This conclusion was based

- upon the team's observation of operators using the procedure during plant heatup. The procedural actions and implementation were conducted well during the transition between shutdown cooling and using the steam generators as the heat sink. The transition resulted in very little variation in both reactor coolant system temperature and pressur .

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The team noted that a surveillance test procedure deficiency resulted in declaring the "C" service water pump inoperable A recent procedure revision had added a second pump ,

performance curve from the f@afety analysis report (FSAR). However, the FSAR  !

_ pump curve did not account for instrument inaccuracies and suction pressure variations due to sea level elevation changes. This omission resulted in the surveillance test failure. Short-term corrective actions were to perform a safety screen, remove the FSAR

. figure from the procedure and provide clarification on performance curve differences in the procedure. Team review of the pump performance data concluded that the pump did not degrade into an unacceptable rang The licensee identified ten significant operator actions that had a measurable impact on core damage frequency, The team verified that the licensee had appropriately proceduralized these operator actions in the appropriate emergency and abnormal operating procedure The team reviewed various emergency operating procedures (EOPs) and abnormal operating procedures (AOPs) to confirm proper labeling and equipment staging for operator actions outside and within the control room. The review consisted of in-plant validations, simulator validations, and reviews within the control room. The evolutions involved local control of the auxiliary feedwater turbir!e, energizing the 4.16 KV bus 24E from unit 1 bus 14H, loss of all feedwater, local operation of the atmospheric dump valve, cross connection of unit 1 station air, and supplying fire water to the auxiliary feedwater i pump Generally, proper equipment was staged and appropriately identified on SP 2657,

" Emergency Operating Procedure Equipment Inventory." Components were generally l labeled appropriately and lighting in the area was appropriate. In one case, EOP 2537, i

" Loss of All Feedwater," two control room panel designations for operator actions were incorrect, and contingency step 2.20.c contained a human factor deficiency between the expected action and labeling on control panel COS. On March 23,1999, the licensee generated a CR to document these deficiencie The team verified that local operation of plant equipment had been tested and operator actions were validated. The team confirmed periodic testing to locally cycle the atmospheric dump valves (2-MS-190A and B) and the fire water supply valves to the auxiliary feedwater pumps existed in surveillance procedures. Several, minor validation issues were identified by the team that included: no area temperature indications for the auxiliary feedwater room, no validation of local operation of the atmospheric dump valves

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with operators using self-contained breathing apparatus, and no performance testing to '

confirm acceptable reactor building component cooling water flow to the instrument air compressor. These minor validation issues were resolved by either the licensee validating actions or providing additional information to substantiate that the existing procedures were technically acceptabl .

i 17 l Procedure Adherence i

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The team observed implementation of numerous operating procedures and surveillance activities that included procedures for starting reactor coolant pumps, securing the residual heat removal (RHR) system, controlling plant heatup from Mode 4 to Mode 3, filling the safety injection tanks, and control element assembly testing. The team noted appropriate procedure implementation as required in DC 4, " Procedural Compliance."

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c. Conclusions Operator procedural quality was generally good. Some minor validation deficiencies were noted in a few surveillance and emergency operating procedures; however, none

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had an impact on safe operation of the facility. Appropriate procedural adherence by operators was observe :

04 Operator Knowledge and Performance a. Insoection Scope The inspection scope consisted of observations of operators both inside and outside the control room. The observations included changes in plant conditions, surveillance testing, or other activities that demonstrate the abilities and knowledge of operators. The team also verified that log-keeping practices were adequat b. Observations and Findinas Ooerator Performance Operator performance was generally good during the periods of team observation General control room demeanor was observed to be appropriate. Both licensed and non-licensed operators were aware of plant conditions and maintenance activities in progress. The observed evolutions were well controlled with appropriate supervisory {

oversight. The operators conducted plant evolutions in a safe and controlled manner, '

and exhibited a conservative approach to equipment manipulatio The team accompanied several plant equipment operators (PEOs) on their rounds. The team observed that the PEOs properly performed their rounds, properly filled out their log sheets and out-of-specification readings were documented and resolved. The team's observations of PEOs performing activities within the auxiliary building identified appropriate identification of issues such as leakage from a post-accident sample system (PASS) filter, waste gas compressor relief valve leakage, and leakage from the "B" high pressure safety injection (HPSI) inboard seal coole s:

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18 l Shift Technical Advisors were knowledgeable of plant risk evaluations. Plant evolutions that resulted in changes to the risk assessment were properly discussed during shift tumover The unit supervisor (US) appropriately consulted technical specifications during interactions with surveillance test personnel to confirm adherence to appropriate compensatory measures. Plant activities involving makeup of soluble boron to the volume control tank included multiple checks to ensure adherence to reactivity management practices. The team's review of past events indicates that several reactivity management issues had occurred between November 1998 and January 199 An adverse trend CR was appropriately initiated on March 1,1999 to evaluate common cause attributes of these past events. This issue is described in the NRC's Resident inspector inspection report (NRC IR 99-02).  !

Loa Keepina Operator log keeping was adequate and performed in accordance with procedure U2 OP

. 200.1, " Unit 2 Conduct of Operations." An electronic log (the shift manager's log) was maintained by the control room staff to document shift activities. This electronic log was readily available to the plant staff. Information logged in the shift manager's log included limiting condition for operation (LCO) entries and exits, the starting and stopping of major n plant equipment, unanticipated events (i.e., equipment failure) and the completion of surveillance test Self Checkina and Con' trol Board Awareness -

Generally, control board awareness and annunciator response were good. However, on several occasions, the team observed that operators failed to communicate unexpected -

alarms to the US. No adverse consequences were observed due to this lack of communication and the team noted improved communication regarding unexpected alarms during the duration of this inspection. When unexpected alarms annunciated, the control room operators reviewed the correct alarm response procedure and took appropriate actions. The practices of self checking and peer checking were frequently implemented by the operator j The team found that operations management was actively involved in operations activities. The team frequently observed operations management in the control room providing guidance to the shift. Operations management participated in shift tumover meetings to reinforce expectation Generally, control room operator's expeditiously identified plant equipment malfunctions or changes in plant conditions. Examples included timely awareness of reactor coolant systerp (RCS) inventory loss (0.3% indicated pressurizer level change) during an !

evolution to drain portions of the letdown system in support of local leak rate testin )

However, in one case, a unit supervisor failed to recognize the need to conduct a !

technical specification required surveillance test. Specifically, when RCS pressure was l raised above 200 pounds per square inch absolute (psia), in support of SP 21199, "LPSI

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System and Shutdown Cooling Heat Exchangers Leakage Test," no control existed to !

Implement technical specification surveillance requirement 4.7.2.1. The surveillance '

requires that every hour the steam generator primary and secondary temperatures be-verified to be greater than 70 degrees Fahrenheit (*F). The team confirmed that temperatures were always greater than 70 "F during the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the surveillance was not performed. The licensee prepared CR M2-99-1060 to document this missed j surveillance and was in the process of preparing a licensee event report at the end of the inspection. The team reviewed other condition-based surveillance requirements to verify that adequate procedures existed to conduct the surveillances and no deficiencies were ,

identified. The failure to conduct the required TS surveillance test is a severity level IV violation and le being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy (NCV 50-336/99-004-01)

l Conclusions Operator performance was generally good and control room demeanor was observed as appropriate. Both licensed and non-licensed operators were aware of plant conditions and maintenance activities in progres The operators conducted plant evolutions in a safe and controlled manner, and exhibited a conservative approach to equipment manipulation. Generally, control room operators expeditiously identified plant equipment malfunctions or changes in plant condition ,

However, in one case a technical specification surveillance test requirement, to monitor )

steam generator temperatures, was not performed in a timely manner. There were no safety consequences as a result of not conducting this surveillance because the required plant parameters were always satisfied. The failure to conduct this technical specification required surveillance is a violation of NRC requirements. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report M2-99-106 Generally, operator control board awareness and annunciator response were goo However, on several occasions, the team observed operators fail to appropriately communicate unexpected alarms to the Unit Superviso Operator Training and Qualifications Inspection Scope The team observed operator training and examined qualifications records to verify that required training was complete and training records were properly maintaine p l 5 l

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b. ' Observations and Findinas Reaualification Trainina The team observed a portion of licensed operator requalification training and reviewed licensed operator requalification training records to verify that all required training was performed. The team specifically verified that licensed operators attended and passed requalification training for the plant startup procedures. The team reviewed lesson plans and simuiator scenarios and found both to be satisfactory. Management involvement was evident from comments in simulator evaluation records. The team found that operators returning to shift from administrative or other assignments satisfactorily ,

regained licensed duty proficienc l Restart Trainina i

A review of the lesson plans for restart instruction indicated that the training was i

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adequate. Training for entering Mode 4, and the subsequent plant heatup, occurred early this yea One licensed operator candidate had not performed the required number of reactivity manipulations prior to the shutdown in early _1996. The qualification card for this individual clearly documented the need to perform the required manipulations in order to complete the requirements for his licens Modification and Simulator Trainina The team evaluated specialized classroom and simulator training to verify that the

. operators were adequately prepared for a safe plant restart. Additionally, the team discussed recently installed plant modifications with several operations personnel. The personnel interviewed were knowledgeable of the modifications completed during the extended outage, and the effects on the plant systems and procedure The team observed portions of operator training provided on plant modifications and 4 witnessed control room simulator training. Lesson plans for classroom instruction were adequate to ensure that the operators were cognizant of the plant modifications. Plant l operators stated that management was present for classroom instruction and participated by toenforcing goals and operating policies. During the conduct of simulator training scenarios, the SM and US appropriately monitored and directed crew activitie .Overall, the operators demonstrated good knowledge of plant systems and modifications, and effective use of the operating and emergency operating procedure P

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. Conclusions l All licent.e4 >perators had satisfactorily completed requalification training, A review of the lessc:, plans, discussions with licensed operators, and observation of plant and i simulator performance indicated that the training provided to the operators was sufficient 1 to ensure that they could safely restart the unit. Modification training for the operators l was appropriate to effectively communicate plant changes completed during the outag Operations Organization and Administration a.- Insoection Scope i

The team assessed operator communications within the control room, verified adequate

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shift staffing, and verified that plant management were providing adequate oversigh Qbap_ntations and Findinas Staffina Levels )

The team reviewed the operations department staffing levels. There were five operating crews. During the inspection, four crews were on shift rotation operating the plant and one crew was assigned to the work control center. Each operating shift had two licensed senior reactor operators, two licensed reactor operators (COs) and at least two plant .

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equipment operators (PEOs) and a STA. During complex evolutions or evolutions which .

had not been recently performed (i.e. plant heatup), additional operators supplemented l the control room staff to assist and to perform peer checks. The team found that operations department staffing levels were adequate to support the safe operation of the plant and minimum shift complements were always me Communications The team observed communications on all shifts among operators and between the 1 control room and other site organizations were generally good. Management expectations regarding three way oral communications were generally me Operability Determinations in general, the team observed that the SM and US were effective in identifying issues that required operability determinations (OD). However, the team noted one isolated case where an OD for the station batteries was not initiated in a timely manner. On March 17,1999, the assistant operations manager (AOM) briefed the operators on a station battery performance issue. An OD for the station batteries was not initiated until after the team discussed the need for an OD with shift management. In response, the licensee appropriate ( prepared operability determination MP2-022-99, on March 20,1999, and concluded that the station batteries were operable with compensatory measures. The team reviewed the operability determination and associated procedure changes and found them acceptabl g3 1

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The team found that the quality of command and control of shift activities was goo The US and SM were knowledgeable of and frequently involved in ongoing plant

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activitie Conclusions Operations department staffing levels were adequate to support the safe operation of the plant. Communications within the operations department and with other site organizations were good. Operators generally initiated operability determinations in response to degraded equipment conditions. The team observed good command and control of shift activitie Quality Assurance in Operations i

a. - Insoection Scope The inspection scope consisted of reviews of recent oversight and self-assessment reports, performance indicators, and corrective actions for issues identified in the assessments, Observations and Findinos l Oversiaht and Self-Assessment Functions During the team's assessment, the licensee had continuous nuclear oversight of operations activities and a peer evaluation during the week of March 15,199 The team reviewed nuclear oversight log entries for the two week inspection perio Nuclear oversight observations provided an accurate account of activities involving the conduct of operations. Some of the observations such as missing pages in surveillance procedures, inconsistent quality of three way communications, and difficulty in evaluating valve alignment completions were generally consistent with the OSTI finding The team observed one example where a nuclear oversight observer inadvertently changed a plant process computer display being used by operators to monitor reactor coolant pump net positive suction head. The STA immediately restored the display, verified that plant conditions did not change in the short time period the display was affected, and spoke with the nuclear oversight person regarding changing parameters on the computer. The licensee initiated CR M2-99-1246 to evaluate corrective actions for this event.

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The team observed a debriefing between the peer evaluator from Seabrook Station and the operations manager on March 20,1999. The peer evaluator observed the conduct of operations during the week of March 15,1999. The review was objective and-identified areas for improvement that included inconsistency in crew communications, opportunities for debrief of special evolutions to enhance lessons leamed, and improved knowledge of operability determinations by SMs. The operations manager was in the process of evaluating improvements at the end of the inspection perio The team reviewed the operations self-assessment program as described in OA-11,

"Self Assessment," and the results of the program between February 22,1999, through ;

March 5,1999. Twenty areas wers the focus of the self-assessments. Areas identified j as needing improvement were worker practices, awareness of plant status, tagging, and :

operator burdens. The one area that did not meet management's expectations involved l several valve mis-positioning events. The five areas either needing improvement or not I meeting management's expectations all had corrective action plan !

i The team reviewed self-assessment 2 OPS-SA-99-18, " Millstone Unit 3 OSTl Lessons Leamed." The assessment evaluated fifty-six areas to confirm unit 2 readiness for restart. The assessment was thorough and deficiencies were appropriately entered into J the corrective action program. _ The team reviewed condition reports written as a result of this assessment and concluded appropriate corrective actions had been establishe Some of the outstanding condition reports included increasing the resources to approve and schedule maintenance activities, improvements in post-evolution debriefs, and increase in awareness of operating experience information. The teams' assessment indicated actions were being taken to resolve the issue The team reviewed follow-up actions associated with self-assessment report 2 OPS-SA-99-18A, conceming three configuration control events documented in NRC Inspection :

- Report 50-336/99-02. The causal factors for the events involved lack of management ,

control of on-shift work load, less than adequate resources, and insufficient on-shift personnel to control plant status. The teams observations indicated improvements in the areas needing corrective action i Conclusions Nuclear oversight observations provided accurate accounts of activities involving the conduct of operations. Self-assessments were critical and the licensee's corrective action plans for improvement were appropriate.

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l Ill. Maintenance and Surveillance M1 Conduct of Maintenance M1.1 Observations of Maintenance and Surveillance Activities

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a.- Insoection Scope The team observed maintenance and testing activities to assess the overall quality of the maintenance and surveillance testing programs. The team verified that pre-job briefings were thorough, mechanics and test personnel followed procedures, and management I oversight of field activities was appropriate. The team also reviewed the post maintenance test failure rate and the maintenance rework rate to assess the quality of maintenanc l Observations and Findinas l Reactor Buildina Closed Coolina Water (RBCCW) Heat Exchanaer Flow Test l The purpose of this test was to verify adequate service water flow through the RBCCW l heat exchangers during an accident. The pre-job briefing was thorough, coordination with the control room operators was good and engineering involvement was appropriat ;

All equipment manipulations were directed by the control room and procedural adherence was good. The test was postponed one day to implement necessary procedure change Enaineered Safeauards Actuation System Diode Replacement The licensee identified that a non safety-grade diode had been inappropriately installed in the engineered safeguards actuation system (ESAS). The diode replacement work was coded as a Mode 4 hold, but due to difficulty identifying the correct part number, this job was not included in the work schedule. The outage manager noted this discrepancy i and scheduled this task as emergent work to be performed one day before Mode 4 work was planned to be completed. Poor planning resulted in this task becoming emergent

, work. Plant conditions and questions regarding plant impact of this task by the US resulted in this task being delayed one day. This activity'was an example of how emergent work adversely impacted schedule adherenc The instrument and controls technician performing the work was very experienced and knowledgeable of the task being performed. The team verified that the technician was qualified to perform work on this system. The pre-job briefing was thoroug Coordination with the control room operators and the system engineer was excellen ~O

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Turbine-Driven Auxiliary Feedwater (TDAFW) Pumo Throttle Valve Linkaae The team observed maintenance activities associated with the adjustment of the throttle

- linkage for the TDAFW Pump. During earlier maintenance activities involving replacement of portions of the throttle valve and linkage, a maintenance mechanic had questioned the acceptability of observed tolerances in the linkage connections. The maintenance observed by the team involved consultation with the pump vendor's representative to ensure that the throttle valve linkage was properly installed and )

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aligned. The maintenance staff appropriately conducted this activity; however, purchasing delays in contracting the pump vendor support resulted in this activity not being performed as originally schedule I Control Room Ventilation Preventive Maintenance The team observed the performance of several preventive maintenance (PMs) activitie Generally, PM activities observed were completed in accordance with procedures, i However, in one isolated case, during the performance of a semiannual PM to inspect

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the control room air conditioning coils, procedures were not appropriately followed. The mechanic performing this activity inadvertently opened the duct port on the wrong train of control room air conditioning (CRAC) system. The mechanic failed to properly complete and sign the component identification procedure step, requiring the worker to verify the

~ proper component prior to conducting the maintenance. This was contrary to the conduct of maintenance administrative procedure that requires the verification sign-offs

- and self-checking be complete to ensure that the task was completed correctly. Upon discovery that the PM had been initiated on the wrong train, work was immediately stopped, the wrong train sealed, and work continued on the proper train. However, maintenance supervision was not informed of the incident in a timely manner. The conduct of maintenance administrative procedure also requires that, if unexpected conditions develop, work shall be stopped, equipment or systems be placed in a safe condition, and supervision be informed. The licensee appropriately determined that opening the duct on the wrong CRAC train had no affect on the operability of the protected train. This deficiency was entered in the licensee's corrective action system as CR M2-99-0986. The failure to follow the PM procedure is of minor safety significance and is not subject to formal enforcement actio Steam Generator Level and Automatic - Auxiliary Feedwater Initiation Loaic Functional T_q The team observed the performance of surveillance procedure SP 2402M, " Functional Test of Steam Generator Level and Auto - Auxiliary. Feedwater initiation Logic." The instrument and controls (l&C) technicians performing this procedure stopped prior to completion of the tests because certain relays could not be located. These relays had been insta!!ed by a design change and were labeled differently in the field than the nomenclature used in the procedure. While the technicians researched the location of the relays, they left a jumper installed in the circuitry which provided an active auxiliary

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feedwater (AFW) pump initiation signal. This fact was unknown to the technicians, who

, incorrectly communicated to control room operators that the AFW pump start signal was l defeated by the jumper. There was no consequence as a result of this error since the f

pump start was blocked by the pump handswitch being in the pull-to-lock positio Engineering personnel determined that the relays had dual identification on the drawings. The procedure used one form of identification, while the labeling in the field

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used the other. The procedure revision, which was done to incorporate a design change, was verified and validated by tabletop exercise instead of a field validation. The l immediate corrective actions included a procedure revision to correct the relay identification issue and describe the purpose of the installed jumper. The event was discussed with the instrument and control (l&C) department technicians to sensitize them to the importance of understanding the effect that procedure steps have on plant statu Additionally, five other recently revised l&C procedures received field validation before use. The condition was self-revealing during the surveillance performance, had no i safety impact, and corrective actions were appropriate. This inadequate procedure step i is a minor violation that is not subject to formal enforcement actio Volt Direct Current (dcl Station Batterv and Turbine Batterv Surveillance The team observed the weekly surveillance on the 125 volt de station and turbine batteries. The technicians complied with the procedure, established appropriate safety precautions, and correctly recorded the appropriate test dat Chilled Water System Leak Surveillance The team observed conduct of a leak test for one train of the chilled water system. The periodic surveillance test was also being conducted as a post maintenance test for valves replaced during the current outage. The personnel conducting the surveillance were thorough in the examination of the system. They also identified material deficiencies such as damaged insulation, a corroded support, and a leak in the bellows of the air handling unit serviced by the chilled water system. The test personnel appropriately failed the surveillance test when the acceptance criteria was not satisfied due to leakage identified from a threaded connectio Charaina Pumo Discharae Check Valve Test The team observed a PEO manipulate the system to test the valves. The test procedure referenced another procedure (the charging pump start-up procedure) in lieu of including the required valve manipulation steps. The referenced procedure was not discussed during the pre-job briefing, nor was the need to have the procedure available listed as a l

prerequisite in the test procedure. The lack of availability of the procedure locally did not i

i adversely affect test performance since the equipment operator was able to contact the l control room and have the required manipulation steps read to him. This procedure problem was appropriately discussed during post-Job discussions.

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Maintenance Rework Rate The team reviewed an analysis of rework conducted by the licensee's maintenance

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~ engineering group which included a list of maintenance AWOs completed during the last 15 months that were considered to be rework items. The rework rate for that period was about 1% of the total number of maintenance AWOs. The team also reviewed a list of condition reports for rework items during the same period and selected several of these for a detailed review. These items were well documented, with thorough analyses and reasonable corrective action Conclusions The quality of maintenance activities observed was generally good. Maintenance technicians conducted good pre-job briefings in the maintenance shops and briefed operators on job scope prior to beginning work, i

Procedure adherence by the maintenance staff was generally good. The team observed instances where work was stopped to clarify or revise maintenance procedure The maintenance workers were knowledgeable of assigned maintenance tasks and had  ;

received appropriate training. The team concluded that the maintenance rework rate

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was at an acceptable level, and that the licensee had adequately resolved maintenance rework issues through the corrective action system. Appropriate maintenance supervisory oversight of field activities was observe M2 Maintenance and Material Condition of Facilities and Equipment Insoection Scope

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. The team assessed the adequacy of the material condition of the plant, including a review of identified maintenance deficiencies, to verify that plant equipment condition is acceptable to support a safe plant restart. The team reviewed deficiencies to ensure i they were prioritized and corrected commensurate with their safety significance. An assessment of the Work-it-Now (WIN) and Backlog Reduction Teams was performe Observations and Findinas Plant Eauipment Condition The team observed the condition of equipment located in the primary containment, auxiliary, and turbine buildings. The appearance of plant equipment and facilities were acceptable with no obvious indications of fluid leakage or other deficiencies not already included in the licensee's corrective action program. Several significant plant equipment improvements were installed during this outage (e.g., containment sump, replacement of pressurizer spray piping, etc).

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Operator Burdens and Control Room Deficiencies The team reviewed the licensee's operator burden and control room deficiency programs. At the time of the inspection, the licensee had identified approximately 15 operator burdens. The team did not identify any additional operator burdens that were i not already included in the program. Where appropriate, the licensee proceduralized the ,

burdens in plant procedures. The team determined that the individual and cumulative safety impact of the identified burdens was minima The licensee had an adequate program to highlight important control room deficiencie j

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The licensee had 29 deficiencies in the program at the time of this inspection. Fourteen of these deficiencies had been corrected and were waiting for retests. The team did not identify any additional control room deficiencies. The safety impact of the control room deficiencies was minima l Maintenance Rule Systems i

The team reviewed the maintenance rule action plans for six of thirteen (a)(1) system The action plans were well documented and contained appropriate corrective action They were prepared by the system engineer, and approved by the expert panel l chairperson and the unit 2 plant director. For (a)(1) systems, the system engineers were required to write monthly status reports to the maintenance rule coordinator until the systems achieved (a)(2) status. The team verified that corrective actions had been completed or were documented in the corrective action system, and that monthly status reports were being writte '

The team noted that corrective actions identified in the latest (Revision 5) maintenance rule action plan for the chilled water system were scheduled to be completed prior to Mode 4 operation. In contrast, the " Plan of the Day Schedule" had these actions identified as Mode 2 items. A CR (M2-99-0984) was written to resolve this discrepanc Maintenance Backloa 1

.The maintenance backlog impact on operations had been assessed by the license The team independently assessed the impact of the maintenance backlog and determined that the backlog did not include any items that would adversely impact safe plant operations. The backlog of work required to be completed prior to restart was tracked by work control personnel with periodic status reports provided to plant management. Daily meetings were conducted to assess the impact of emergent work on plant operation The number of " Task Completions" required for restart had been reduced from 2825 tasks in April 1998 to 270 tasks in March 1999. The tasks included assignments associated with NRC Open items, Significant item List issues, and CR corrective actions as tracked in the licensee's Action item Tracking and Trending System (AITTS) but did not include opened AWO .

2 . The AWO backlog was reported on a daily basis, with primary emphasis on the backlog ,

of items required for restart. The licensee trending reports showed a continual decline in the number of AWOs working or in close-out/ retest status, with a slight increase in the-number of AWOs deferred until after startup. On March 25,1999, at the end of the inspection, the AWO breakdown included 370 items in the outage scope and 663 items in the deferred work category. A review of the 370 outage scope items showed that the majority of the AWOs involved minor issues, such as hot torque of bonnet fasteners, !

' insulation replacement, and post heat-up inspections. A review of a sample of the deferred items showed them to be issues that would not affect start-up, and can be done on-line or during the next refueling outag The team also reviewed the licensee's listing of automated work orders (AWOs) required

- to be completed prior to restart. The review of open significant hardware AWOs showed that the majority involved work steps which were to be completed as the plant startup progressed. There appeared to be no significant hardware issues that would not be corrected prior to operation of the plan .

Work-it Now OMN) and Backloa Reduction Teams The WIN tearn consisted of a maintenance supervisor, two plant operators, two maintenance technicians, and a planner / parts person. The WIN team worked primarily on emergent maintenance issues. They used the same procedures and processes that are in place for " normal" work. The WIN team was successful in the timely resolution of emergent plant issue i The Backlog Reduction Team consisted of a Unit 3 supervisor; a mixed crew of Unit 3 mechanical, electrical and l&C mechanics and technicians; and a Unit 2 planner. The i Backlog Reduction Team spent two weeks resolving Unit 2 equipment deficiencies. For example, the backlog team replaced teflon tape with approved joint sealants for environmentally qualified electrical equipment. During the two-week assignment, the ,

backlog team reduced the Unit 2 AWO backlog by almost 100 item l tig.usekeepina and Eauioment Storaae The team observed that housekeeping was acceptable with most areas clean and well maintained. A facilities betterment program was ongoing to improve the appearance of various locations throughout the auxiliary building. The team noted a few unsecured ladders, staging and scaffolding that, when brought to the licensee's attention, were expeditiously restrained or remove *

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30 i l Conclusions Necessary equipment repairs were either completed or scheduled for completion prior to plant restart. Maintenance backlogs were being appropriately managed and routinely assessed for impact on operations. The control of operator work-arounds and control room deficiencies was also found to be adequate to support plant restart. The plant l material condition and housekeeping were acceptable. The Backlog Reduction and WIN Teams had a positive impact on addressing emergent work and reducing the AWO backlo These findings, along with the review of temporary modifications (bypass jumpers)

documented in Section E2.2 of this report, provide the team's basis for closure of NRC Significant item List item 7, Bypass Jumpers, Operator Work-arounds & Control Board Deficiencies and the associated NRC Restart Assessment Plan item M3 Maintenance Procedures and Documentation  ;

M3.1 Maintenance Procedure Quality Insoection Scope The team verified that the quality of maintenance and surveillance procedures were adequate to safely perform the intended task Findinas and Observations The team reviewed selected maintenance procedures during work observations. The team observ31 that generally the procedures were appropriate for the tasks being performed es work packages and procedures were revised when appropriat The quality of the PM procedures reviewed were generally acceptable with one minor exception. Preventive Maintenance Form 2701J-37 was not component or system specific and could not be performed on the 'B' control room air conditioning system evaporator fans during the semi-annual PM. The generic nature of the PM form required the maintenance technicians to stop work and consult with supervision, resulting in being in the control room air condition limiting condition for operation (LCO) for an additional period of time (not exceeding the LCO). The licensee appropriately documented this procedure deficiency in the corrective action program (CR M2-99-0988). The inadequate procedure step is of minor safety significance and is not subject to formal enforcement actio The quality of surveillance test procedures reviewed were generally acceptable. One exception was an l&C procedure where the " tabletop" validation and verification program had not identified discrepancies between the procedure and control room labeling (See section M1.1 for details). During this outage, the licensee verified that all required testing had been included in the inservice testing (IST) procedure ,_

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31 Conclusions The team concluded that procedures reviewed were generally adequate for the intended task M6 Maintenance Organization and Administration M6.1 Maintenance Plannina and Schedulina Insoection Scope The team assessed the maintenance work planning and scheduling processes to assure adequate tracking, prioritizing and resolving of safety significant plant equipment deficiencies. A sample of work packages was reviewed to evaluate their quality. The

. team also reviewed the licensee's process for evaluating risk when taking equipmr.it out-of-service for maintenance. The team also verified that surveillance tests P.;id preventive maintenance scheduling were appropriately cuntrolle Observations and Findinas Work Plannina The team reviewed approximately 30 work packages. The work packages were found to-be satisfactory and the work instructions were sufficient for the scope of work. Changes to work packages and procedural steps had been performed in accordance with the appropriate administrative control The team noted that the planning department had a large backlog of completed AWOs for final closure. This backlog had no noticeable effect on the completion of work in the '

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Schedule Adherence The adherence to plant schedules had been poor. On average, only 46% of work orders on the 3-day look ahead schedule were started and 42% were completed on schedul The difficulty in meeting schedules was attributed to several factors including emerging issues, focus on outage critical path items and supporting mode changes. During the inspection, the team noted several instances where maintenance tasks were delayed in

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starting, or interrupted in progress, due to unforseen difficulties or changes in prioritie Maintenance manager.was observed to emphasize doing the job right, rather than being '

overly concemed with schedule adherence.

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Risk Assessments

The team reviewed licensee activities relative to the assessment of safety during

' maintenance activities.-The team noted that the risk sensitivity of planned activities was communicated to alllevels of the maintenance organization. Plan-of-the-day meetings

' discussed the risk status of the plant, including which facility was protected, as a standard topic of discussio The team noted good communication of plant risk and safety status within the maintenance department. The risk status of the plant and the potential effect of plann maintenance activities were discussed during daily supervisors meetings and daily crew meetings. Biweekly department meetings held by the maintenance manager were also prefaced by a discussion of the safety status of the plant and the risk significance of ongoing activitie At the time of this inspection, the licensee was in the final stages of initiating a 12-week i rolling schedule for Unit 2 on-line maintenance and surveillance activities. The process was scheduled for implementation on April 4,1999, using new station procedures applicable to both Units 2 and 3. As a part of the " lessons-leamed" from Unit 3, phased .

implementation was planned for Unit 2. The first phase included integration of surveillance and preventive maintenance activities (scheduled using the 12-week scheduling process) with corrective and emerging maintenance activities (scheduled using the outage scheduling process). The first phase of the 12-week scheduling process was performed by a Unit 3 scheduler to mentor the Unit 2 schedulers and to incorporate lessons leamed from Unit PM Proaram Schedulina The PM program included a set of regenerating work orders that were entered into the production maintenance management system (PMMS). The team noted that the system may be prone to human errors because it required the planner to manually regenerate a PM during AWO closure or the PM would not be rescheduled. In addition, a missed or -

deferred PM would not adjust the next quarterly PM, but the corresponding next year's PM would be adjusted. The licensee's staff were aware of these scheduling limitation The team did not identify any cases where the potential process weakness resulted into inadequate scheduling of PM The team noted that the Condition-Based Maintenance (CBM) Department has developed, but not implemented, a monitoring, testing and maintenance program to improve component reliability. The CBM Department had recently issued a procedure to improve the PM program through periodic review of corrective maintenance activitie Prior to the issue of this procedure, trending of trouble reports and corrective maintenance on individual components had been an informal pre-outage function of the maintenance planner .

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The team found that the PM deferrals were adequately documented and readily recoverable. - During the outage, the licensee had reduced the number of overdue PMs

' from approximately 200 to 7. The team noted that the deferral documentation was not always timely. Five of the seven overdue PMs had deferral requests still pendin Surveillance Testina Procram Schedulina The team reviewed the licensee's restart surveillance scheduling program. The licensee i demonstrated that the planned and/or completed surveillance testing would adequately support the restart of the unit. As a part of the surveillance schedu'ing, refueling cycle surveillance tests had been put on an 18-month schedule during the maintenance outage, with the start of the current 18-month cycle being November 199 Conclusions Performance in the area of planning and scheduling was mixed. Planning was thorough, with detailed work packages prepared to support most AWO activities. Schedule adherence did not meet licensee's goals primarily due to emergent issues. The team did ,

not observe any instances where schedule pressures or changes adversely affected plant safety.-

The licensee's performance in assessing the safety / risk of planned maintenance was ,

acceptable. Safety assessments for maintenance activities were addressed by appropriate procedures and the risk significance of planned activities was discussed at planning meeting The licensee had identified and/or completed surveillance tests required for plant restar The team's findings provide the basis for the closure of SIL item No. 6, Work Planning and Control, and the associated NRC Restart Assessment Plan item IV. Enaineerina E1 Conduct of Engineering Insoection Scope The team evaluated the effectiveness of the technical staff, including design and technical support (system) engineers, in supporting the safe operation of the plant. The team also assessed system and design engineering response to emergent (day-to-day)

plant technical problems including an assessment of communications and interfaces, timeliness, and technical adequacy of the support. The team also verified that issues were being properly prioritized and effectively resolved in a timely manne e

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34 Observations and Findinos The engineering departments provided good support for day-to-day activities and were properly represented at various meetings observed by the team. A key member in this respect was the engineering duty manager who served as the primary point of contact for engineering in their interface with other plant departments. The engineering staff members were knowledgeable of issues and provided good support to other department l The daily engineering moming meeting provided good discussion of emergent issues, I new CRs and the status of ongoing activities. The responsibility for issues was clear and individual accountability for completing tasks was eviden l The team screened the list of open CRs that required engineering actions to close. From this list the team selected several for additional review, including CRs generated during :

the two-week inspection period. The team found that the licensee properly evaluated ;

and prioritized the issues for resolutio The team also reviewed the corrective action plans and implementation of corrective actions for a number of CRs listed at the end of this inspection report. The team found the corrective actions were generally appropriate and effectively implamented. However, in one case, when a problem was identified with the bend radius of a cable within a conduit fitting, the initial investigation did not fully investigate the potential scope of the

- - " problem. Subsequent actions were taken to inspect aoditional cables in similar conduit fittings and the overall issue was evaluated and documented by the licensee in M2-EV- l 99-0015, " Technical Evaluation for Cable Bend Radius in Conduit Fittings - Millstone Unit 2." The inspectors reviewed the document and determined that the additional actions and technical evaluations appropriately addressed this issu System Readiness Reviews The system readiness reviews required the System Engineers (SEs) to conduct a broad i review of several aspects that contribute to system readiness. The team reviewed - I approximately ten system readiness review reports and found them to be comprehensive. The system deficiency backlogs had been appropriately reviewed and dispositioned._The team determined that the SEs were knowledgeable of the system readiness reviews and were cognizant of plans to address those issues needing q

- corrective action prior to plant startu Syjtem Walkdowns The team walked down a number of safety systems and interviewed the responsible '

system engineers regarding system status. The SEs were knowledgeable of the open

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The engineering departments were fully staffed and were functioning effectivel Engineering personnel, including supervisors and managers, provided around-the-clock, on-site support of activities including items such as post-modification testing, Conclusions The engineering department managed the planned and emergent activities well. Daily planning of issues at the moming meeting set the priorities of both the system and ;

design engineering departments. Communication with and support to other departments '

was good. The identification, documentation and control of issues within the CR system was good. Corrective actions associated with CRs and other open items were properly tracked within the action item tracking and trending system (AITTS). The team did not

, identify any CR issues that had not been properly screened and dispositioned for deferral until after the restart. These findings provide the team's basis for the closure of NRC SIL 7, items C.3.2.e, Effectiveness of corporate engineering support, and item C.4.f., Significant hardware issues resolve E2 Engineering Support of Facilities and Equipment E Permanent Plant Modifications Insoection Scope

.The team reviewed several modifications that were installed during the current outage to verify that the modifications were installed in accordance with program requirements and that the modifications did not reduce plant safety margins. The team also verified that the engineering resolutions of the issues being addressed by the modifications were technically sound and that the safety evaluations provided an adequate basis for determining if the changes involved an unreviewed safety question. The team also riviewed the modification closeouts to ensure that drawings were revised, post-niodification testing was performed, and that plant procedures and vendor manuals were i.pdate Observations and Findinas The team reviewed several plant modifications and minor modifications (MMODs) that were completed during the outage. The engineering of the design changes was technically sound and thoroughly documented in accordance with the Design Change Manual (DCM) requirements. The team found that the safety evaluations included good bases to support the conclusions relative to determining if the change constituted an unreviewed safety question. The modification closeouts were complete, drawings and procedures were properly revised, appropriate post-modification testing was performed, and vendor information was update __-_--

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.The team also reviewed several maintenance support engineering evaluations (MSEEs).

MSEEs were used to provide engineering support to maintenance or operations to implement enhancements that did not constitute design changes. The use of an MSEE must be approved by the design engineering manager, must be documented on a design change notice (DCN) and evaluated in accordance with 10CFR50.59 to ensure it does not constitute an unreviewed safety question. The team found that the MSEEs were implemented in accordance with the DCM and were of a good technical qualit Drawings and other documents affected by the MSEE were appropriately update The team reviewed the function and results of the engineering Quality Review Board (QRB). The purpose of this board is to review all primary engineering documents (DCRs, MMODs, MSEEs, TMs) for technical and administrative quality before they are sent to the PORC committee for approval. The team attended a QRB meeting held to review a MSEE and found the review by the board to be very thoroug The engineering design manager has tracked the engineering rework rate since the inception of the QRB and the statistics indicated a marked improvement in the products '

being presented. The increase in quality was also reflected in a reduced rejection rate (to near zero) of engineering documents by the PORC committe Conclusions The team found the design control process was being properly implemented. The technical quality of changes was good and modification package content, including the 10CFR50.59 screening and safety reviews, are comprehensive. Post-modification testing accomplished the verification ofimportant design change attributes. The use of a Quality Review Board has contributed to improvements in the quality of the engineering product E2.2 Temoorary Modifications Insoection Scope The team reviewed the existing temporary modifications (TMs) to verify that they were installed in accordance with the procedural requirements and to assess the operational impact of the TMs intended to be installed at the time of plant restart. During plant walkdowns, the team examined systems to identify if any potential modifications existed to station equipment that were not being properly controlled by the TM process. The existing TMs were discussed with the responsible system engineers (SEs) and design engineers to assess their knowledge of the TM process, the effect on system operation and the proposed resolution that will allow removal of the TMs.

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37 Observations and Findinas

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There were a limited number of TMs in place at the time of the inspection and they were

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- - installed and controlled in accordance with the administrative proceduresc The TMs were properly documented and the documentation included appropriate safety analyses and technical evaluations. Affected procedures were properly revised where necessar The SEs, design engineers and engineering supervisors were knowledgeable of the installed TMs and with the planned actions to resolve the condition requiring the TM Of the eight temporary modifications installed at the time of the inspection only two had the potential to directly affect safety related systems. Temporary modification 2-96-083 documented a problem with the emergency diesel generator (EDG) room drain header check valve. The valve had been temporarily repaired and local backwater flapper valves were installed in each of the individual drains. The flapper valves were leak tested prior to installation to ensure there would be minimal inleakage in the event of an external flood. A calculation was also performed to ensure that any minor back leakage would be detected by the operators before any safety-related equipment could be impacte Temporary modification 2-99-06 was installed during the inspection to jumper the low air flow alarm contact for vitalinverter 4. The air flow instruments were designed to detect a reduction in cooling air flow through the inverter. Due to an apparent malfunction of a circuit card, the instruments were causing spurious alarms in the control room. The low flow alarm contact was jumpered to prevent the nuisance alarms until the cause could be ;

identified and corrected. The temporary modification contained a thorough technical and safety evaluation. Additional alarms remained active following the installation of the jumper and included a high temperature alar During plant walkdowns, the team questioned if temporary cameras installed in various areas of the containment were controlled by a temporary modification. This question had also been raised by a member of the oversight department. The cameras had previously been controlled by a procedure but the licensee now concluded that it would be more appropriate to control them with a temporary modification. The licensee was preparing a temporary modification that was to be implemented prior to plant restar Conclusion Engineering has been effective in resolving issues. As a result, the use of temporary modifications was minimal. The number of installed TMs was low and below the plant goal. The team concluded that the evaluation and control of temporary modifications was good and that the installed TMs had no adverse impact on safe plant operatio ,

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38-E2.3 Deferred lasues Reyigg Insoection Scooe The team reviewed the deferred engineering work request (EWR) backlog and selected several issues for detailed review to assess plant impact of not completing these items -

~ before restart. Additional inspection of items to be completed after restart was also performed as documented in section S2.2 of this repor Observations and Findinas The team selected a sample of the deferred EWRs for review based on their potential -

safety significance in review of these EWRs, the team did not identify any restart issues and the EWRs reviewed had adequate bases for deferra Conclusions The licensee had adequate controls in place to ensure deferred work was properly evaluated. No deferred modifications were identified that would affect safe plant operatio E2.4 Enaineerina Support to Plant Operations

- Inspection Scope -

The team compared the surveillance procedures for the control room heating and ventilation (HVAC) system, to the design criteria and testing requirements contained in the Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS). The team also examined the HVAC system readiness review document, and conducted a walkdown of the system with the cognizant system enginee The team examined HVAC surveillance procedures to determine if surveillance testing was conducted in accordance with the testing requirements outlined in the plant TS, and 1 to verify the design assumptions used in the surveillance procedures accurately reflected

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i system performance criteria contained in the FSAR. A system walkdown was performed to examine the physical condition of the system, and verify the system engineer was familiar with the operations of his syste ;

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39 Observations and Findinos During the current outage, the licensee conducted an extensive review of the HVAC j system design analysis, surveillance and operating procedures and maintenance practices. The review was thorough and numerous deficiencies were detected. The issues included the discovery of single failure vulnerabilities, inadequate surveillance procedures, and inconsistencies between the system design analysis specified in the FSAR, and TS. To resolve these issues, the control room HVAC system was modified, surveillance and operating procedures were rewritten and the system design analysis was revise Modifications to the control room system included locking certain backdraft dampers in place to eliminate single failure vulnerabilities and sealing holes in the ventilation system ductwork to reduce control room air in leakage. The licensee also established additional administrative controls to minimize system unavailability by ensuring work that could disturb the control room boundary was completed in a timely manne The control room surveillance testing program was robust. Not only #d the testing verify the system would meet the performance criteria established in the FSAR and plant TS, but certain aspects of the testing utilized state-of- the-art performance monitoring equipment not generally used by the industry. Specifically to measure control room air in leakage, the licensee used a tracer gas. Industry testing has revealed that a tracer gas is more likely to find degradation in the control room pressure boundary than other less sensitive, but acceptable, methods such as air pressure drop testin l l

Recent revisions to the sections of the plant TS and FSAR, which discussed the control room HVAC system, removed inconsistencies that existed between the two document For example, prior to one change, the dose assessment for the control room operators described in chapter 14 of the FSAR, assumed the minimum air flow through the control room charcoal filters was 2500 cubic feet per minute (cfm). This assumption was not conservative, since the minimum filter air flow allowed by the plant TS was 2250 ci ;

The revised chapter 14 duse assessment for control room operators, properly assumed a charcoal flow rate of 2250 cf The readiness review conducted on the system was thorough and appeared to capture, i assess, and resolve remaining design, maintenance and procedure deficiencie l The system engineer demonstrated familiarity with the operation of the control room HVAC system, its maintenance history, and recent modifications it had receive c. Conclusions The licensee had substantially improved the design and licensing basis of the control room HVAC system. Inconsistencies between the system design criteria contained in the FSAR, TS and the operating and surveillance procedures were eliminated. Single failure design errors were corrected. The system readiness review was thorough. The i control room HVAC surveillance testing program was a strengt !

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E'3 Engineering Procedures and Documentation j

E3.1 ' Ooerability Determinations Insoection Scope The team reviewed the open operability determinations (ODs) at the time of this j

- inspection to assess the technical adequacy of the evaluations and the potential impact '

on safe operatio Observations and Findinas )

~ The OD process was consistent with the guidance provided in NRC Generic Letter 91-18, Revision 1, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions."'

There were approximately 26 open operability determinations at the time of the inspection. The ODs were readily accessible via computer and a hard copy was maintained in the shift manager's office in the control room. The ODs were thorough and provided sufficient detail to establish operability. The team reviewed all the open ODs and determined that they were acceptable to support plant restart or that the licensee had assigned an appropriate mode restraint for the resolution of the issue which required the evaluation. The team discussed many of the ODs with engineering department managers, supervisors and engineers. The engineering personnel at all levels had a good understanding of the issues, and for each of the conditions described in the ODs, there was an appropriate plan for resolving the degraded or non-conforming conditio Conclusions The OD process was comprehensive. Operability determinations were technically sound and documented an adequate basis for establishing operability of the degraded ;

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E3.2 Vendor Manual Control Insoection Scooe -

The team reviewed the engineering products to ensure that control of vendor equipment technical manual information was included in engineering documents. The licensee program for control of vendor information was previously reviewed by the NRC in SIL ltem 50, Observations and Findinas The team found that engineering documents, such as design changes and maintenance support engineering evaluations, included updates to vendor manual m

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41 i t Conclyginns i

.The licensee program to maintain the accuracy of vendor manual information was being properly implemente E3.3 . Setooint Controls Inspection Scope The team assessed the setpoint control process for safety-related plant equipment. The team reviewed selected setpoints for safety-related functions and emergency operating procedure (EOP) operator actions to assess their adequacy and safety basi Observations and Findinas The team reviewed Specification SP-ST-EE-329, " Standard Specification for Use and Control of Master Setpoint index," Rev. 2, and Specification SP-M2-lC-019, " Millstone Unit 2 l&C Setpoints," Rev.1. These specifications clearly delineated the bases for incorporating instrument uncertainty into safety related setpoints. Additionally, the current bounding values of the reactor protection system (RPS) and engineered safety 1 features actuation system (ESFAS) setpoints along with emergency operating procedure action points were incorporated into SP-M2-IC-019. The team found that an adequate process was in place to control setpoint Revision 4 to CEN-152, " Combustion Engineering Emergency Procedure Guidelines",

. was issued, in part, to incorporate information gained through the Combustion Engineering Owners Group (CEOG) instrument uncertainties study. Specific CEOG guidance on instrument uncertainties was provided in study CE-NPSD-1009 Rev. O, "l&C Engineering Limits and Bases EOPs." In a letter dated May 7,1997, the licensee stated that any safety significant items identified as part of the Millstone Unit 2 instrument uncertainties study would be incorporated into the EOPs prior to restart from the current outage. The team sampled several parameters, which had been identified as having a 1 high degree of safety significance, in the CEOG guidanc Calculation, S-01228-S2, Rev. 2, " Millstone 2 Emergency Operating Procedure Setpoint Documentation", provided the bases for setpoints used in the EOP's. Fifteen setpoint bases were reviewed along with appropriate supporting documentation. The team found the decision to include or not to include instrument inaccuracies to be sound for the given parameters. Significant EOP changes had been made which incorporated potential instrument errors for harsh environments. For example, revised pressurizer pressure instrument inaccuracies were incorporated into new pressure-temperature curves and shutdown cooling temperature and pressure entrance criteria in the EOP The team found the bases for the setpoints reviewed to be adequately justified. With one exception, the team found that supporting setpoint calculations were generally comprehensive and utilized appropriate design inputs and assumptions. The exception involved the refueling water storage tank (RWST) level setpoin ..

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During a review of calculations 92-030-1259E2, Rev. 2, "RWST Level Setpoint Analysis,"

and 98-ENG-02558M2 Revision 0, " Determination of Minimum Submergence Criteria for RWST Suction Piping," the team noted that the minimum submergence value for the

. suction pipe had been calculated assuming a post-sump recirculation actuation signal (SRAS) operating condition. At that point the low pressure safety injection pumps (LPSI)

are automatically secured, resulting in a reduced fluid velocity. The team determined that using the lower fluid velocity in the calculation could result in a calculated submergence value which would be non-conservative for the tank level that would exist just prior to the SRAS signal inadequate suction pipe submergence could result in flow vortexing and subsequent air entrainment in the flow path to the safety related pump The licensee initiated condition report M2-99-1107 to evaluate this conditio On March 25,1999, a calculation change notice was approved which concluded that the present setpoint was acceptable. The new calculation now credited anti-swirl vanes on the intake pipe and determined that the minimum submergence level to avoid air ingestion was 25 inches above the bottom of the tank in the pre-SRAS condition. This value was bounded by the existing minimum analytical setpoint of 26 inches above the bottom of the tank in the post-SRAS condition. The team determined that this new calculation supported the basis for the reasonable expectation of continued operability documented in the condition repor During a review of the bases for the EOP action setpoints associated with HPSI pump discharge pressure transmitters, the team questioned the use of these instruments during the recirculation phase following a loss of coolant accident (LOCA). Specifically, during the recirculation phase following a LOCA, the transmitters would be subjected to a potentially harsh radiation field. However, they were not environmentally qualifie The pressure transmitters were used in EOP 2532, " Loss Of Primary Coolant", to verify that HPSI pump run-out conditions did not exist following post SRAS alignment to the containment sump. Following SRAS, it could be postulated that the operator may throttle HPSI injection flow when not warranted based on erroneous readings on the unqualified ,

pump discharge pressure instrument. Additionally, FSAR Table 7.5-3, " Regulatory i Guide 1.97 - Accident Monitoring Instrumentation," did not reference the pressure transmitters or credit their use in post accident condition The team noted that calculation 97-122 Rev. 2, " Millstone Unit 2 ECCS System Analysis," had concluded that based on the HPSI throttle valve position settings, runout would not be a concern. The team also noted that in the event the operators had inadvertently throttled HPSI flow, there was additional instrumentation, such as core exit thermocouples and reactor vessel water level, which would have provided for determining the adequacy of core cooling. The licensee initiated condition report

. M2-99-1122 and stated that the use of the pressure transmitter would be removed from ,

the emergency operating procedure during the next revision which was scheduled to be performed prior to plant restart. The failure to adequately translate the design basis into procedures constituted a violation of minor significance and is not subject to formal enforcement actio :,

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43 Conclusion The licensee implemented an adequate setpoint process and the Millstone Unit 2

Instrumentation and Control (l&C) setpoint specification provided a clear definition of the

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program for the generation and documentation of safety-related, instrument and control setpoints. In general, the setpoints selected for review by the team were properly documented, reviewed, and supported by appropriate calculation E3.4 Eauipment Qualification Insoection Scope The team reviewed a sample of item equivalency evaluations (IEEs) and commercial grade deoications to ensure equipment was appropriate for use in safety systems. The team reviewed the packages for several commercial grade items which included individual parts as well as dedication of components such as air conditioning units, transfer switches and transmitter Observations and Findinas The. team found that the procedures and processes for the equipment reviews were technically sound and provided adequate controls. This procedure provided reasonable assurance that a commercial grade item selected for use would perform its safety-related functio The evaluations reviewed were thorough and applicable data bases and documents were properly updated. The program effectively involved the appropriate departments, such as design engineering, in the evaluation review process and in the implementation of evaluation results such as updating of procedures or specification Conclusion

The licensee implemented effective commercial grade dedication and item equivalency evaluation programs and performed appropriate evaluations to support plant restar E3.5 Ooeratina Experience Proaram insoection Scope The team reviewed the licensee operating experience procedures to assess the adequacy of the program. The team reviewed a sample of completed operating experience evaluations which had been designated as operational mode holds to assess the adequacy of issue resolution. The team also reviewed a sample of open operating experience (OE) items to assess whether appropriate priorities had been assigned for issue resolution.

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b. Observations and Findinas The team found that the Nuclear Safety Engineering (NSE) Group had been administering the operating experience assessment program in accordance with NSE 1, Rev,0, " Implementation of Operating Experience." The reports were thorough and provided, when required, appropriate recommendations to address the related issue Recommendations made were tracked through resolution by the NSE grou The team reviewed five OE issues which had previously been designated as start up restraints. The team found that proposed and completed corrective actions justified removing them from operational mode holds. OE documents currently under evaluation were reviewed and found to be properly prioritize c. Conclusions The team concluded that the operating experience program was functioning adequately to support restart. The backlog of reviews had been evaluated by the licensee to identify those issues requiring review before restart and appropriate priorities had been assigned to these issue E3.6 Drawina Control Inspection Scope The team reviewed the adequacy.of drawing controls and the status of operations critical drawings to ensure they were acceptable to support plant restar . Observations and Findinas Over the last 12 months there were 225 condition reports that docuniented drawing / configuration deficiencies. Of the 225, only five issues necessitated preparation of operability determinations, of which none of the issues resulted in operability issue ;

The five items of concern documented the discovery of longstanding design / configuration issues that did not appear to be indicative of current plant performance. The team found that recently completed plant modifications had been accurately reflected in control room operational critical drawings within the time requirement specified in the DC Conclusions The majority of the drawing issues that have been identified over the past 12 months have had minor safety significance. Current procedures and processes for updating operational critical drawings in the control room had been followe r

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E8' Miscellaneous Engineering issues E Emeroency Core Coolina Systems Sinale Failure Vulnerability Insoection Scooe The team reviewed the corrective actions taken by the licensee to address the single failure vulnerabilities for post loss of coolant accident boron precipitation strategy and the isolation of the safety injection tanks. The team reviewed selected design change documentation, inspected the installation of the design changes, and reviewed the operating procedure changes. The team verified that key aspects of installation were !

consistent with the design change documentatio Findinas and Observatio On January 9,1998, the licensee identified single failure vulnerabilities in the strategies used for controlling boron precipitation in the reactor vessel and isolation of the safety injection tanks (SITS) following a loss of coolant accident (LER 98-002). Both system alignments used to mitigate the affects of boron precipitation in the reactor vessel would be compromised if a failure of either an altemating current (ac) or direct current (de)

electrical facility were to occur. The licensee addressed this concern by installing a design change that allows either electrical facility to power key valves in the boron precipitation flow path. The licensee also identified that the failure of either train of electrical power could also prevent the isolation or venting of nitrogen gas from the safety injection tanks. . Introduction of nitrogen from the SITS into the reactor coolant

. system following an accident could have an adverse affect on core cooling. A design change was installed that allowed either SIT isolation or venting of the SIT nitrogen cover gas concurrent with a single failure of either electrical facility. The design change electrically powered the SIT vent valves and isolation valves from opposite electrical facilit The team noted that the emergency operating procedure changes made to implement i the boron precipitation design change were incorrect. The licensee stated that these procedures had only been conditionally approved by the PORC and further validation, verification and procedure revisions were known to be required. The licensee demonstrated that the procedure deficiencies noted by the team had ueu oreviously identified by the design engineering organization. - A condition report (CR) was icsued to review the circumstances surrounding the conditional PORC approval of the emergency operating procedures (EOPs) and the conditional PORC approval for the EOPs was temporarily withdraw Conclusions l l

' The team concluded that the design changes resolved the ECCS single failure  ;

vulnerabilities. Additionally, the aspects of the design changes reviewed, with the

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exception of the EOP changes, had been properly implemented. The licensee j demonstrated that appropriate administrative controls were in place to ensure that the j EOPs would be corrected prior to becoming effective. These findings provided the basis necessary for the closure of SIL 5 E8.2 - (Closed) LER 97-034-00: Containment Sumo isolation Valves are Susceptible to Pressure Lockina l t Insoection Scope t

Licensee Event Report (LER) 97-034-00 was submitted to document the discovery that valves 2-CS-16.1 A&B could be susceptible to pressure locking due to variations in containment pressure. The team reviewed the licensee's actions to resolve the l documented discrepanc j i Observations and Findinas l

i The licensee identified the apparent design weakness while performing a review of a j previous modification to these valves that had been made to prevent the possibility of j thermally induced pressure locking. The review found that the valves could be l pressurized to 54 pounds per square inch gage (psig) during an accident where previous I analysis had only postulated an initial bonnet pressure of 37 psig. Because preliminary calculations indicated the motor operators may not be adequately sized to open if the bonnet was pressurized to 54 psig during an accident the valves were declared l

inoperable. Subsequent testing in April 1998 indicated that the valves would have j functioned properly and were operable. Nonetheless, the licensee chose to modify these !

valves to prevent bonnet pressurizatio To resolve this concern, the licensee installed a pressure relief system on the valves that would prevent bonnet pressure from reaching a point at which the potential for pressure locking could be a concern. At the time of the inspection, the modification had just been declared operable. The team reviewed the control room design drawings and valve lineup sheets and verified they had been updated to reflect the addition of the modificatio !

Additional corrective actions included examining all remaining safety-related valves to l

determine if they were susceptible to pressure locking or thermal binding (PLTB). No !

new issues were identified. To ensure the full range of accident conditions are j considered during future pressure locking / thermal binding reviews, the "MOV System !

and Design Basis Review instruction" was changed to require Nuclear Engineering (NE)

to perform the MOV analysis. The licensee believes that the NE department, which develops the plant safety analysis, will be better suited to identify similar analysis error The team verified that the instruction was revise i

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l PLTB of gate valves was the subject of Generic Letter 95-07, " Pressure Locking and Thermal Binding of Safety-Related Power Operated Valves." This letter required, licensees in part, to examine all safety related valves for susceptibility to PLTB, modify them as appropriate, and inform the NRC of the results. The team noted subsequent to I the identification of this issue, the office of Nuclear Reactor Regulation had reviewed l NNECo's revised PLTB program and determined it was adequate. This conclusion was i outlined in a November 24,1998 safety evaluation repor ' Conclusions

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The licensee's corrective actions were considered appropriate to correct the issue identified in LER 97-34. The licensee's April 1998 pressure locking tests indicated the valves would have remained operable and therefore the error was of minor significanc However, the failure to use appropriate assumptions when initially analyzing the containment sump valves for susceptibility to PLTB was a weakness in design contro These findings provided the basis necessary for the closure of SIL ltem 20.7A and LER 50-336/97-03 V. Manaaement Meetinas X1 Exit Meeting The team held an exit meeting that was open for public observation, on April 7,199 The slides used by the NRC to conduct presentations during the exit meeting are provided as Attachment 1 to this inspection report. The licensee acknowledged the findings presented. The data base used to track inspector's requests / questions and licensee responses will be placed in the Public Document Roo INSPECTION PROCEDURES USED IP 93802: Operational Safety Team inspection (OSTI) >

ITEMS OPENED, CLOSED, AND DISCUSSED Opened NCV 99-04 Missed Technical Specification Survaillance to monitor steam generator temperature

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Closed LER 97-034 SIGNIFICANT ITEMS LIST Closed SIL 1 . Management Oversight and Effectiveness; Licensee Staff Safety Culture ,

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Work Planning and Control

. SIL 7 Bypass Jumpers, Operator Work-Arounds and Control Room Deficiencies SIL 12 Licensee Restart Punch List - Review Items Deferred Until After Restart SIL 13 Operation Performance LSIL 20.7 Pressure Locking of Valves 3 SIL 53.1, Single Failure of ECCS  ;

LIST OF ACRONYMS USED AFW auxiliary feedwater AITTS action item trending and tracking system AOM Assistant Operations Manager AWO- automated work order AOP_ abnormal operating procedures l

.CBM condition based maintenance CFR code of federal regulations CFM- cubic feet per minute CM corrective maintenance

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' CO control operator COEG Combustion Engineering Owners Group ,

CR condition report CRAC control room air conditioning CST condensate' storage tank DC direct current DCM design change manual

.DCR - design change request

DR - discrepancy reports ECCS emergency core cooling system ED emergency diesel generator EOP emergency operating procedure ESAS . engineered safeguard actuation system ESFA engineered safety feature actuation system EWR engineering work request FSAR final safety analysis report . t

. HPS high pressure safety injection I HVAC heating ventilation and air conditioning l

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l lCAV independent corrective action verification program i INPO institute of nuclear power operations j l&C instrumentation and control lEEs

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item equivalency evaluations IR NRC inspection report 1 IS Inservice test JUMA joint utilities management assessment j

KPI key performance indicator '

LCO- ' limiting condition for operation l LER licensee event report I LLRT localleak rate testing LOCA loss of coolant accident LPSI low pressure safety injection MMOD minor modification MOV motor-operated valve MSEE maintenance support engineering evaluations NE nuclear engineering NGP nuclear group procedures NNECO northeast nuclear energy company NSE nuclear safety engineering NORP nuclear oversight verification plan NRC- nuclear regulatory commission NSAB nuclear safety assessment board NU northeast utilities OE operating experience ,

OD operability determinations l OP operating procedure

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OPS operations ORP operational readiness plan NU OSTI operational safety team inspection PASS post accident sampling system PEO plant equipment operator i PDR public document room P&lD _ piping and instrument drawing PLTB pressure locking and thermal binding PRA~ probabilistic risk assessment PORC plant operations review committee FM preventive maintenance PMMS production maintenance management system PSIA pounds per s'uare inch absolute

' PSIG pounds per square inch gage

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PU procedures upgrade program QC quality control QRB _ quality review board RAP NRC Restart Asaussment Penel RBCCW reactor building closed cooling water

.RCS_ reactor coolant system

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RHR residual heat removal RPS reactor protection system RWST - refueling water' storage tank SE system engineers Sll significant issues list SIT safety. injection tank SM: shift manager

'SORC site operations review committee i SP surveillance procedure SPRO special procedure STA shift technical advisor TDAFW turbine driven auxiliary feedwater TM temporary modification

TS technical specification UlR ' unresolved item report '

-. US unit supervisor- )

UT . ultrasonic test-VCT volume control tank -

.V&V validation and verification

- WIN work-it-now

.Y2K- year 2000

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- PARTIAL LIST OF DOCUMENTS REVIEWED MANAGEMENT PROGRAMS AND OVERSIGHT:

Progress Toward Readiness Restart at Millstone 2, January 8,1999 Unit 2 Restart Following 10CFR50.54(f) Outage, SPROC OP 98-2-08 I Post-Maintenance Testing, CWPC 3, Revision 2

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' Millstone Self-Assessment of the Retest (for AWOs)

. CRs related to Retests' 4 R. P. Necci to U. S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit 2, i Response to April 16,199710 CFR 50.54(f) Information Request," February 5,1999 R. P. Necci to U. S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit 2, Response to April 16,199710 CFR 50.54(f) Information Request," March 5,1999 R. P. Necci to U. S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit 2,

. Independent Corrective Action Verification Program, Final Report - Volumes 1 and 2 Additional Comments," March 5,1999 NOQP 1.08, Nuclear Oversight Verification Plan (NOVP) ,

NOQP 2.01, Nuclear Oversight Audits NOQP 2.04, Nuclear Oversight Assessments NOQP 3.04, Nuclear Safety Engineering Functions & Responsibilities - ISEG and Operating

- Experience Assessment -

Oversight evaluation by Key issue Leads / Nuclear Oversight Leads Northeast Utilities Nuclear Group, Nuclear Oversight Assessment, independent Assessment Team, July 1997 -

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1998 Joint Utility Management Assessment (JUMA) Report for the Millstone Station Necci to Kenyon, RPN 99-015, Nuclear Oversight Monthly Report, February 11-March 9,1999, March 25,1999 Necci to Kenyon, RPN 99-011, Nuclear Oversight Monthly Report, January 7-February 10, 1 1999, February 26,1999 Necci to Kenyon, RPN 99-006, Nuclear Oversight Monthly Report, December 9-January 6, 1999, January 26,1999 Necci to Kenyon, RPN 98-013, Nuclear Oversight Monthly Report, November 8-December 9, 1998, December 24,1998 Necci to Kenyon, RPN 98-009, Nuclear Oversight Monthly Report, October 9-November 7, 1998, November 23,1998 QA open item list Quality Assurance Audit Report No. A23073, "MP3 Technical Specification implementation Verification" Quality Assurance Audit Report No. A22073,"MP2 Technical Specification implementation Verification" Nuclear Oversight Audit Report MP-98-A04, " Environmental Protection - Air Quality" Millstone Station Nuclear Oversight Audit Report MP-97-A10-07, Millstone Station " Operating Experience Assessment Program" Nuclear Oversight Audit MP-98-A01, " Conduct of Operations" Millstone Units 2 & 2 (sic)

Nuclear Oversight Audit MP-98-A03, " Design Control Implementation" Nuclear Oversight Audit Report MP-98-A06, " Severe Accident Management & Emergency '

Operating Procedures Unit 2" Nuclear Oversight Audit Report MP-98-A15, " Measuring and Test Equipment Millstone Station" Northeast Utilities Nuclear Oversight Audit MP-98-A20, "MEPUPMMS Program"- Units 1,2, & 3 Nuclear Oversight Audit Report MP-98-A23, " Technical Specifications" Millstone Station Nuclear Oversight Audit Report M2-98-A24, " Millstone Unit 2 Core Reload" Millstone Station .

- Nuclear Oversight Audit Report M1-98-A21, " Conduct of Operations" Millstone Unit i Nuclear Oversight Audit Report M1-98-A28, " Maintenance / Test Control" Millstone Unit 1

> Nuclear Oversight Audit Report MP-98-A08, " Station Blackout Program" Millstone Unit 2 Nuclear Oversight Audit Report M3-98-A10, " Configuration Management" Millstone Unit 3 i Northeast Utilities Nuclear Oversight Audit Report ('7 Day") MP-99-A05, "Special Processes" Surveillance MP2-P-99-025, " Unit 2 Management and Staff Overtime Controls" Surveillance MP2-99-006, " Conduct of Operations for the period January 9,1999 through February 3,1999," W. E. Strong and W. D. Bartron to D. A. Hagan, February 10,1999 Surveillance MP2-P-98-064, " Conduct of Operations for the period December 8,1998 through January 5,1999," W. D. Bartron to M. J. Wilson, January 7,1999 Surveillance MP2-P-98-058, " Conduct of Operations for the period November 6,1998 through December 4,1998," William E. Strong and W. D. Bartron to M. J. Wilson, December 11,1998 Non-conformance Reports, NGP 3.05 Corrective Program, RP 4 Nuclear Assessment Program, NGP 2.38 Procedure to Stop Work, NGP 3.19 Open Oversight CRs/All Units /All Significance Levels List CR-01935, Dual Role Valves CR-7147, QAS Surveillance: Discrepancies Between PMMS and EEQ Master List

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CR-8655, QAS Audit: Conflict Between Electrical Load List and As-Built

.CR-8837, FSARs Require RCS Samples Not Required by Technical Specifications

- CR-8981, TSfor Boron Dilution & Addition is More Restnctive than Other Tech Spec Sections CR-10107, Electrical Separation M2-99-0499, MP2 Project engineer exceeded the o'rertime limits, worked 17.5 hrs, person felt compelled to finish job before leaving for vacation the next day M2-99-1079, Overtime Policy Violated by Technician i M2-99-1181, ." Overtime Control" policy NGP 1.09 was exceeded by vendor personnel on 3/27-29/99 performing fire watch M2-99-1360, Supervisor prepared authorization for overtime form without including himself in j the list of affected personnel '

M2-99-1365, CRS involving involving overtime controls issues should address the potential ,

safety implications ID'd in NGP 1.09 M2-97-1102, Auxiliary Feedwater Regulating Valves Not Tested Using Back-up Air M2-97-1106, AFW Room Heat Load Calculations Have Errors i M2-97-1173, Potential CST Inventory Loss Due to Single Active Failure Not Reported in LER in I

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1991 M2-97-2688, Containment Liner Has Severe Coating Failures M2-98-1085, Containment Liner Paint Not Qualified per ANSI N10 .

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M2-98-2894, Containment Air Recirculation Fans Not Tested in Accordance with Technical Specifications M2-98-3101, Assessment of Reactor Protection System Id'd Several Safety Evaluation Screens Not in Compliance with NGP 3.12 or RAC 12 M2-98-3456, Failure to implement the Requirements of 10CFR50 Appendix B and NU QA Program (NUQAP QAPs 3 & 5)

M2-98-3559, Action item Assignment was inappropriately Closed Prior to the Actions Being Completed Safety Review Committees Plant Operations Review Committee, OA 3, Revision 4, change 3

- Plant Operations Review Committee meeting minutes, 2-99-020,2-99-021,2-99-022,2-99-050, 2-99-050R, 2-99-051 (Draft), 2-99-052, 2-99-053, 2-99-054, 2-99-056 (Draft) i PORC open items Site Operations Review Committee, OA 4, Revision 2, Change 3 Site Operations Review Committee Meeting Minutes 98-68,98-69,98-71,99-06 Site Operations Review Committee Open items List - Action Request 99001769 Nuclear Safety Assessment Board, NGP 2.02, Revision 16, Change 2 Nuclear Safety Assessment Board Meeting Minutes,' 98-19,98-21,99-01 Nuclear Safety Assessment Board Open items Meeting Minutes - NSAB-O&M Subcommittee Meeting #98-14, December 4,1998 Meeting Minutes - NSAB-SE Subcommittee Special Meeting #99-06, February 11,1999 Technical Specifications Section Student Qualification / Training Status (for Technical Staff), February 15,1999

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ROOT CAUSE INVESTIGATIONS REVIEWED l l

M2-98-3067, Valve Mispositioning Resulting in Nctice of Violation for inadequate Procedure, l Root Cause investigation M2-98-3176, Instrument Air Valve was Found Open Versus Tagged Closed as Expected, Root Cause Investigation M2-98-3318, LER Root Cause for Negative Pressure Requirements for Enclosure Building May Not Have Been Conservative, Root Cause Investigation M2-98-3435, Non-Conservative Assumption in LONF, Root Cause Investigation M2-98-3839, Pressurizer Spray Thermal Fatigue, Root Cause Investigation M2-98-3544, Adverse Trend in CRs in Operational Configuration, Control Area Deficiencies, Common Cause Investigation j M2-99-0268, Reactor Coolant System Level increased When Water inadvertently Transferred '

From SITS, Root Cause Investigation l M2-99-0442, Charging Pump Event During Surveillance Restoration, Root Cause Investigation M2-99-0304, SFP Water inadvertently Transferred to Clean Waste, Root Cause investigation M2-97-1171, Unit 2 Floodgate Inspection, Root Cause Investigation Following is a list of documents in addition to the one enclosed with the previous j feeder:

CR Nos, :M2-99-0481, 0451, 0530, 0600, 0630, 0631, 0652, 0268, 0304, 0987, 0046, 0090, 0556,0035,0775,0370,0789,0542 M2-98-0295,1556,1527 ,

M2-97-1382 Restart Readiness Report, B17622, dated Jan. 8,1999 Station Procedure: Self-assessment, OA 11, rev 1 Self-assessment for OSTI, Assessment Nos. 2 OPS-SA-98-05, -06; U2-MSA-98-04, -005; MP21&C 98-3; 2 OPS-SA-97-08; U2-DE-98-017; 2 OPS-SA-98-24,-25,-2 Unit 2 Work Observation Reports,4* qtr 98, 3* qtr 98,2" qtr 98,1" qtr 98, Performance Indicators for CRs and AITTs for January and February 199 Northeast Utilities Nuclear Safety Standards and Expectations, rev 0; Operational Focus Enhancement Strategy; i Mid Cycle Corrective Action /Self-Assessment Review, March 24,1999; Organizational Transition Plan, dated January 14,1999;

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OPERATIONS Surveillance Procedurgtg

. EN 21203, Service Water Flow Through RBCCW Heat Exchangers, revision 5 SPROC EN98-2-23, Operational Testing of 2-SI-651 (DCR M2-98055), IPTE, revision 0 SP 2610E, MSIV Closure and Main Steam Valve Operational Readiness Testing, revision 7, l change 6

- SP 2612C, Service Water System Lineup and Operability Test, Facility 1, revision 6, change 1 SP 2612A, "A" Service Water Pump Tests, revision 8, change 3 SP 2612B, _"C" Service Water Pump Tests, revision 8, change 3 SP 26120, Service Water System Lineup and Operability Test, Facility 1: revision 6, change 1 SP 2612C-1, Service Water, Facility 1,~ revision 29, change 3 SP 2612D, Service Water System Lineup and Operability Test, Facility 2, revision 7 j SP 2612D-1, Service-Water, Facility 2, revision 27, change 9 SP 2612E, Service Water Valve Tests, revision 8 l SP 2612F, "B" Service Water Pump Tests, revision 0, change 3 SP 2669A, Unit 2 Aux Bui! ding Rounds, revision 26, change 4 ,

SP 2610C, Auxiliary Feedwater System Lineup Verification l SP 2611C, RBCCW System Alignment Checks, Facility 1 Administrative Procedures

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DC 4, Procedural Compliance, revision 4, change 6 SPROC OP98-2-08, Unit 2 Restart Following 10CFR50.54(f) Outage, revision 0 U2 OP 200.1, Unit 2 Conduct of Operations, revision 2 C OP 200.1, Conduct of Operations, revision 4, change 2 3 C OP 200.9, Operational Performance Status, revision 1 2-OPS-7.03, Computer Assisted Tagging System Audit, revision 3

' 2-OPS-1.25, Work Observations, revision 10

' 2-OPS-1,32, Locked Valves, revision 4 -

- 2-OPS-1.33, Operations Department Temporary Modification Tracking and Audit Requirements,

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Revision 7 NGP 1.09, Overtime Controls for All Personnel at Millstone Station, revision 8 )

DC2, Developing and Revising Procedures and Forms, revision 3 DC4, Procedural Compliance, revision 4, change 5 '

RP 5, Operability Determinations [4 Comm. 3.2], revision 2 RP 16, Trouble Reporting, revision 0 DBS-2326A, Service Water System, revision 1 ODI Form 1.25-36, Safety Tagging: Clearance Preparation and Review, revision 2 ODI Form 1.25-37, Safety Tagging: Hanging Tags, revision 3 ODI Form 1.25-38, Safety Tagging: Independent Verification of Tagging, revision 3 ;

ODI Form 1.25-39, Safety Tagging: Clearing a Tagout, revision 2  ;

ODI Form 1.25-40, Work Control: Pre-Authorization Review of Work Packages, revision 3 ODI Form 1.25-41, Work Control: Authorization and Release of Tagging and AWOs, revision 2 ODI Form 1.26-04, Briefs, revision 0 ODI Form 1.26-05, Communications of Annunciators and Annunciator Response Procedure l j

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(ARP) Usage, revision 0 ODI 1.26-06, Control Room Indication Monitoring, revision 0 ODI 1.26-07, Peer Checks, revision 0 -

' ODI 1.26-08, Operator Procedure Knowledge, revision 0 ODI 1.26-09, Announcing Major Equipment Starts or Shifts ODI 1.26-10, Tagging Clarifications, revision 2 ODI 1.26-14, Placekeeping, revision 1 ODI Form 1.26-44, Utilization of Three SROs, revision 1 OA 11, Self-Assessment, revision i U2 OF 5, Unit 2 Work Observation Program, revision 0, change 1 W.C. 2, Tagging, revision 3, change 2 W.C. 9, Station Surveillance Program, revision 3 W.C.-10, Jumper, Lifted Lead and Bypass Control C AC 3, Post-Maintenance Testing, revision 2 U2 W.C.1, Work Control Process, revision 1 U2 W.C.14, Work it Now (WIN) Program, revision 1 2-UP_-1.03, Unit 210-4-2 Process, revision 2 Operatina Procedures

- OP 2306, Safety injection Tanks, revision 16, change 5 OP-2201, Plant Heat up, revision 27, change 8 OP 2326A, Service Water System, revision 19, change 9 Plant Drawinas Drawing 25203-26008, P&lD Circulating Water, sheet 1 of 4 Drawing 2520-26008, P&lD Service Water, sheets 2 of 4 Drawing 2520-26008, P&lD Service Water to Vital AC Switchgear Cooling Coil and AC Chillers, sheet 3 of 4 Drawing 2520-26008, P&lD Screen Wash and Hypochlorite, sheet 4 of 4

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Drawing 25203-30001, Main Single Line Diagram Drawing 25203-26005, P&lD Condensate Storage & Aux Feed Drawing 25203, P&lD RBCCW System RBCCW Pumps & Heat EXC Drawing 25203, P&lD RBCCW System Spent Fuel Pool & Shut-Down Heat EXC Drawing 25203, P&lD RBCCW System CNTMT. Spray Pump & S.I. Pump Seal Coolers i

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. Self-Assessment ]

I 2 OPS-SA-99-18, Unit 2 Configuration Control items Self-Assessment - Based on Unit 3 OSTI J Lessons Learned Millstone Unit 2 Operational Readiness Report (dated November 17,1998)

OF-11, Self Assessment 2 OPS-SA-99-18A, Configuration Control Events Condition Reports CR M2-99-0515, Maintenance cut a half inch main steam line outside the tag-out boundar CR M2-99-1082, Safety injection tank vent valve was found open while it was red tagged closed under clearance 2-267-9 CR M2-99-1113, Maintenance personnel cut into an instrument air supply line

. Q_ondition Reports Documentina Valve Alianment Errors i Events that occurred during the OSTI inspection:

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.CR M2-99-0970, Water was unexpectedly drained to the east condenser sump because a two l inch drain line valve was left open instead of closed. The inadequate restoration followed a I

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modification to the turbine building fire sprinkler system. The apparent cause was personnel error in not recognizing a vent valve on the fire sprinkler valve should be confirmed close CR M2-99-0971, A valve lineup for the fire protection system was inadequate in that all of the required valves were not included in the lineup (Ops Form 2618K-1) after the system was modified. A contributing factor to the spill of fire water documented in CR M2-99-0970 (discussed above) was inadequate updating of drawing 25203-26011 after a modification was made to the turbine building fire sprinkler syste CR M2-99-1025, Tagging Clearance 2-0158-99 indicated that the restoration of certain post accident sampling system (PASS) valves would be performed under lineup CHEM Form 2804K-11. This lineup did not include all the valves which were required for restoration from the clearanc CR M2-99-1071, Valves added by a modification to containment sump valves (2-CS-16.1 A & B)

had not been added to the containment integrity lineup nor to the Technical Requirements Manual containment isolation valve list (section 5.0, page 11.5-8).

' CR M2-99-1078, Change 8 to the containment integrity lineup, SP 2605A was processed on March 21,1999. This change added new valves associated with DCN DM2-0300605-98, DCR j

' M2-97037. The revision of 2605A-1 performed in preparation'for Mode 4 on March 20,1999, )

did not contain the new valves, j

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in the month prior to the OSTI, the licensee issued the following condition reports which also I documented problems with the implementation of activities related to valve and breaker lineup

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processe I m

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CR M2-99-0424, throttle positions for some throttle valves on the chilled water valve lineup

. (OPS Form 2330C-1, Rev 15) did not match the positions listed in the more recent revision of

' chill water procedure OP-2330C, revision 11, change 4. Procedure change did not get incorporated into the valve lineu CR M2-99-0471, Valve lineup (Ops Form 2304A-1) showed the position for the volume control tank (VCT) outlet header to the sample system isolation valve (2-CH-116) to be closed. The ;

system.P&lD (25203-26017, sheet 1) showed the position of this valve to be open. Having the normal position for this valve as closed would require personnel to open it in a post-accident situation in order to route post accident sampling system (PASS) effluent back to the VC Condition Reports Documentina Eauioment Taaaina Issues CR M2-99-0515, Maintenance cut a half inch main steam line outside the tag-out boundary which had been established to support the modification work. Operations had to close four

. additional valves to stop the flow of water form the cut lin CR M2-99-1082, Number 4 safety injection tank vent valve nitrogen supply stop,2-SI-842, was found open while it was red tagged closed under clearance 2-267-99. The valve disc was so hard against the backseat that two people independently incorrectly determined it was shu CR M2-99-1113, Maintenance personnel cut into a instrument air supply line in the room between the condensate storage tank (CST) and the condensate surge tank without the line .

being tagged out. The air line was being cut to replace valve 2-CN-241, hotwell make-up from .

CS Maintenance and Surveillance Maintenance / Surveillance Procedures

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TQ-1, Personnel Qualification and Training, U2 OA 5, Unit 2 Work Observation Program,-

U2 WC 1, Unit 2 Work Control Process, i WP 28001, AWO Preparation and Work Scheduling,-

2-Ul-1.03, Unit 210-4-2 Process, RP 16, Trouble Reporting, U2 CBM 105, Preventiva Maintenance Program Changes and Deferrals for MP2, CBM 107, integrated Preventive Maintenance Program, MP 2701J, Preventive Maintenance, C MP 701, Conduct of Maintenance,

OA 10, Millstone Maintenance Rule Program, OP 2264, Conduct of Outages, COP 200.9, Operational Performance Status,

' ODI 1.39, Operations Review Board, MDI 2-1, Attachment 9, Departmental Expectations, Pre and Post Job Brief Guide, OA 11, Self Assessment, OA 5, Work Observation Program,

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OA 8, Ownership, Maintenance, and Housekeeping of Site Buildings and Facilities and i

. Equipmen :IC 2438, Preventive Maintenance Program,

. U2 WC 9.1, Surveillance Program implementation, WC 9 Station Surveillance Program, C WPC 3, Post-Maintenance Testing, C WPC 4, On-line Maintenance, NOQP 4.08,. Determination of Quality Controls for Quality Activities OM 1, Outage Management, OM 2, Shutdown Risk Management, WC 18, Foreign Material Exclusion and System Cleanliness, WC 2, Tagging, MP-20-WM-SAP 02, On-Line Maintenance, MP-20-WM-FAP02.1, Conduct of On-Line Maintenance, 2601J, Completion of "C" Charging Pump IST Testing, AWOs M2-99-03175, Hydrogen Purgs Air Accumulator for 2-EB-92 M2-97-01191, "B" DC Switchgear Room Chiller (Vital Chiller)

M2-98-06835, "B" Control Room Air Conditioning Compressor M2-98-11470, #4 Safety injection Tank Vent to Containment Valve Assembly M2-98-06629, "B" Turbine Building Closed Cooling Water Heat Exchanger M2-97-01163, Chilled Water System M2-96-03285, Replace Valve Stem IAW DM2-00-1690-98 M2-97-06220, "A" Condensate Motor Overhaul, M2-99-01562, X27 Station Air Compressor Aftercooler, Maintenance Rule Corrective Action Plans service water system chilled water system 480 volt ac load center system, 480 voit ac motor control center system control room air-conditioning system engineered safety features actuation system PARTIAL LIST OF ENGINEERING DOCUMENTS REVIEWED Surveillance Procedures SP 2609A, EBFS and Control Room Ventilation Operability Test, Facility 1 SP 26098, EBFS and Control Room Ventilation Operability Test, Facility 2 SP 2609C, Enclosure Building Operability

- SP 2609F, Control Room Ventilation System Filter Testing, Flow and D/P, Facility 1

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-59 Ooeratina Procedures OP2315A Control Room Air Conditioning System Plant Modifications /MMODs/MSEEs DCR M2-97-0-12 (EWR M2-96-191) Single Failure of CRACS Damper 2-HV-210 & Permanently

- Closing Crosstie Damper 2-HV-213 DCR M2-97-042 (EWR M2-96-133) Intake Structure Ventilation Modification DCR M2-98105 (EWR M2-98-174) Replacement of Pressurizer Spray Piping DCR M2-97050 Modification of ESAS Undervoltage Sequencer Module DCR M2-97011 EDG Pre-lube, Slow Start and " Ready to Load" alarm modificatio DCR M2-98095 Turbine Driven AFWP Redundant Power Supply DCR M2-98073 Cross Connect Piping Between CST and Condensate Surge Tank DCR M2-99004 Safety injection Tank Nitrogen System Modification -

MMOD M2-97531 Relocation of Differential Relays for 4160V Switchgear MMOD Fan 158 HELB Interlock Modification DCN DM2-00-0074-99 EBFS Charcoal Tray Bolting DCN DM2-00 2053-98 Overpressurization of SDC Line DCN DM2-00-1690-98 TDAFW Governor valve DCN DM2-00-185-99 Condenser Tube Shields DCN DM2-02-1411-98 Relay Replacement DCN DM2-00-1755-98 Service Water Pump Motor Replacement DCN DM2-00-0215-99 RPS Fuse Replacement DCN DM2-00-0356-99 Lighting Panel Wattage Reduction Condition Reoorts M2-97-0532 Loop 2B Flow Transmitter input Calibration Change M2-97-2810 DCNs issued Without Adequate Bend Radius Information

'M2-97-2946 Leak Tightness of LPSI Not Verified for Post-LOCA

- M2-98-0059 Post LOCA Boron Precipitation Control Subject to Single Failure

- M2-98-0437 Insufficient Cable Bend Radius M2-98-0451 Loss of Service Water During LOCA M2-98-0474 Insufficient Cable Bend Radius M2-98-1392 Operability of Motor Driven AFW Pump

- M2-98-1430 Operability of SIT Tanks When Filling, Draining, Adding, Venting M2-98-1431 IST Acceptance Criteria May Not Assure Equipment Performance M2-98-1526 Containment Spray Pumps could Be Adversely Affected M2-98-1527 EDG Load Sequencing With Simultaneous Start of Pumps M2-98-1605 Combined ECCS Pump Minimum Flows Could Result in Deadheading l M2-98-2736 Boroscope inspection of Check Valve i M2-98-3303 Design Cales TS Requirements Differ from Pump Performance i

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M2-98-3526 Post SBLOCA Nitrogen Intrusion to RCS M2-98-3774 SFP Siphon Breaker Hole Sizing and Location M2-98-3852 Discrepancies Between MEPL, PMMS and Electrical Schematic l M2-99-0643 Discrepancies Between Plant Drawings, Calculation and As-Built ~

M2-99-1122 Basis for use of HPSI pressure instruments in EOP 2532

. Calculations /Supportina Procedural Chanaes/ Modifications

- 92-030-1259E2 Rev. 2 RWST level-Setpoint Analysis L-3001,L-3002, L-3003, L-3004 S-01228-S2 Rev. 2 M2 EOP Setpoint Documentation CE NPSD-1009, Rev; O l&C Engineering Limits and Bases in EOPs Uncertainties 99-ABB-02825-E2 2 Tech Spec Action Value Basis Document- RWST Volume 98-ENG-02558M2 Rev 0 Determination of Minimum Submergence Criteria RWST I 97-ENG-1768E2 Rev.1 Pressurizer Pressure Loop Uncertainty 1 97-122 Rev. 2 ECCS Flow Analysis for Millstone Unit 2 )

PA XX-XXX-1007-GE Rev.1 LPSI Flow Loop Accuracy i PA XX-XXX-1006GE Rev.0 HPSI Flow Loop Accuracy S-01901-S2 Rev. O Development of RCS PT Curves for use in SPDS/EOPs I 97-DES-1739-M2 Confirmation of Availability of Fire Water as Backup to AFW (EWR 2-94-0262)

System Readiness Reviews Reactor Building Closed Cooling Water System Containment Spray System & Refueling Water Storage Tank Safety injection Tanks and High Pressure Safety injection System

' Auxiliary Feedwater System Emergency Diesel Generator 4.16 kV Electrical System q 125 Volt DC System '

Reactor Coolant System inadequate Core Cooling System Control Room Heating and Ventilation System Miscellaneous L

MEMO TS-97-256 Concurrent Operation of RCPs and LPSI Pump for SDC

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Q ATTACHMENT 1 Slides used at April 7,1999 Exit Meeting a

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y Inspection Objective c' OPERATIONAL SAFETY g^ d

" T pr vid urr at information to the

o TEAM INSPECTION (OSTI) o Restart Assessment Panel by evaluating

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5a NRC Exit Meeting g.j and management programs to support a

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April 7,1999 safe restart and continued operation of Inspection 50 336/99-04 Millstone Unit 2

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OSTITeam Assignments inspection Schedule j e Onsite preparation

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14:01 (merch 14,1ose)

l ,.:h ] g a In-office preparation g (werch s.12,1oes)

NNl l l 71.2 l l l g,j u Two week onsite inspection

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(March 1526,1999)

I- I'rhll =llsIBElT= IFi=1 _ n , ~~,n .

Assessment Areas sunmnum m cwure

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,1. Management ProCrameAndependere Oversight 3 ' "h efe C a SIL 8 Work Planrdng and Control 2. Operations @ u SIL 7. Operator Work .Arounds & Control Roorn De6ciencee

.y S. Engineering and Technical Support j e SIL 13. Operator Performance a SIL 20.7. Pressure Locking of Velves 4. Maintenance and Surveillance a SIL 53.1. Sir.gle Failure end ECCS-u s een s mwicen e

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Management Processes AppropetMe management proce-n twve been eeanbNen.d and are Amcdoning adequately to

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, ., -; support a eete plant roesert and consnued

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Management c% op.r. don o Programs / Independent Oversight g , ,,,,,eme, h,, e.,,,,,,hed ,_,, ,,,,,,, , ,o,, ,,,,

a g .ccano ,-Q - [ s Ttw operanonal Readiness Pian demonstrated resotusen or p, . poenn.nc. . .

. u r. gem.nio.mor md .trong =*.mont m em.,gog pm.e ..

-ui n . -= > n .

Management Processes (cont) Corrective Actions

' ' 8' '" '8 a unnagement has toen respoestre e employee concems 3

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3 accepenMe to supportplant teetert

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I e Adequete etsmno hee toen proved for recowry (oneme of '

panie stan we. touw contmand in accordance wm NRC e Plant manegement inn toen a%amly Warmd m the guidestwo) o conecke acton program

e oussay Asswance has twen enecoway meegreed una em une y a The aveshold for includbng usues inen the conectw actens orgenarason program a low e The eter-department communicahon nwchenome are e The quaMy o, recongy performed root came snelrus were

.ppmpnam m eupport op.raan or e. una gad hama== m oen * u.a.uu i can .

Corrective Actions (cont) Self-Assessment

'a r m ,'c,=,aT, ,,la^:::",at,=a.,m,.d . rn. e . ,,,.nt e,oor., e am -

.r,, v.se e- . ,.mo ,.ec.d ,o, c. n .sonmemy ,a.noa,.n.d .nd .r. .cc.p , , n r- ~

~.T re. - ..n - . ,

o e-r .m o . e.,,o,_ we,e ,..d me..e. ., , 0, e o a remad a resset reeduwee

~. ; e The setassessment processee appeared to to functoring

. ;3 p a The =taprown=re pingisms tan teen ee.cthe khases uns 3 05r1 ll hhanesUhs B En G

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Independent Oversight independent Oversight (Cont.)

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i The Nuclear Overnight Orperdzedon hee pnwided i

"' j f -- . _-..JJ performance mesesements and hee ' 3 m Nuchas Ovemgh.taudt

' Andinesweie restartimpacatens revowed have and Anengs tun pmpany

% offecdvelyidentf#ed erees forimprovement, I

• 8h P.C#'88

.ddre .ed Ph e The Nucleaf Overe6ght Orgaruzanon was effectwo in O e NuckerOve a o

,,tas, = ,';; y a go,,*"'n=*

a .nd w o, n. n .ni,er,.mance and

< , e ih

.

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-i a.e rsight mer., reports provated usehA ed d0$ e The Nuclear Overs'Oht Orgaruzabon's invokoment m em.r.non e. n v wine . mannsnanc.=urv.s.nc. .nd .nsiaeenno ha  ;

a mmeis.sacert u n eemsmaacan u i

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Quality Review Committees The Plent Operadone Review Committee, Sseden OpereGons Review Commelsee, and

• I the Nuclear Sellety Aseessment Board comply -

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a J with en Technicet specincecone }i OPerations  :

g- muswnence g  ;

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O O O

s Stabon and Platt Operacons Revew Commatoes conduced mquired samty reviews appropruimy

<g g a The Nuclear Safety Assesamord Boanf was eRecuve in paidmg phet samty overught u.snoen n nam manoen u ,

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n c Opadons (cont)

Conductof Operations

_ The conduct oroperecone was acceptende a

• Nr'au"n "**" '"* ***' "" * '"*

,;y a Control toard awareness and emurrete response were e stafang treet metTechnscal Speericabon Requirements

@ oenesar and O O O e ~ro,ne ,.. wore .,es .dh n.nsi,sm reghements e opwstors acoresy asentswd end conoced eenconc 't

-~ i oen n .en ,,

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Procedure Quality / Adherence Equipment Status Controls  !

opweene procedure queury wee genereny good l

operator's procedure adherence was approprinne _ Controle for esenbushing equipment status were 1 y '., ; 1 acceptable a genom ve ow.eng pr c ,e.revgodwe,.

chnuty sound  ;

g a The equMe4 chance pograin me genn8y 08ectm j a = e,-~=.--n

,

- - g . =m _ m,_. _e .e, ._p.te, ._ed  !

o . __ _ __. wm .e, . .. c !

. _ e...mp._.. ,_ :

documersed e. anew em. t can a n.aemm w. I oen se l

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i Training and Qualifications i

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Engineering and Technical

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punt operenons otoff had received approprum q;

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treening S Support g . nego ,ed 0, ,sou =.oon ,g -. co,. g

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e Tm mod =.t,..w...,,,o 8:

i . e,ec.n,.m. w ,e i h.d i.e.n -, ,md

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u oen n - .en m l

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l Plant Modifications Plant Technical Support l The punt modencecon program was The Eneineering and rechnker support

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approprutely contraned and implemented . . Deparanents providat emeiy and etInstive

. . k eupport to the une orgentzeeans. The becksoa of e Dateded pecess lor design changes O engineering work wee property priorlet2ed for 8 8 feeart

e The pennenent meagn change packages,inctA .e me.ty sevows and poet modecation t-sting, were enhJesar e Knowledgest. System Engewers  !

.. . sound 4 ;

• ^9 m Proposed phnt modecanon desotrae were appropnete

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'" e E#ectve s@ port for emergott plant asues a Tempm,y modmcanon program cortroh are enecthm o opmbety mormmations were techrecas, sound l

f u soon n w-=. a een m l

l G l l

, 1 Plant Technical Support (Cont.) Engineering Programs i, . The m. mon er conomon toporte we. e-ouon and e .

me enginewing progreme wm errecovery

- a The syvem Reedmess Revowe were compretenswo D e Pfard drawings reflected plant doesgn and design change, )

e The vendor equipmentlechntsiir*>rmation was properly

, updated

' d s Phrd @ m W cmbd end e catubscons were genersW appropnate num waeen a mmm maoen u Engineering Programs (Cont.)

a Maintenance and Surveillance

"<

9. rh. .mm.u nde .d n docu,nen. ,ev- were ,,

wchntasy s <

e opereano expeneace evaut=n= were v= rough 8

0 0

N.$

3 kikf imm wroen rr um uuseen w I

Conductof Naintenance Activities Planning and Scheduling unintenance ecovtsee asemed wm genuouy good Ment schedule goele were not met due to

, y; . ;b emergentleaves a Pmcochase cpeHty and adtwrence were generaW approprute ' Work planning peChego que#ty wee good a D U e Waregement overaght of sold actMtes was effectwo m Emergers inause wece provereng accurew schedunne end

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a Quality of maaleenance work was generany good ,.

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a work pisaning process knprwoments were penned

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a Work plannm0 Peckages and shp tets quemy were appeopriate wm uu s can a wm.m > oen m 5 /

M i Plant Material Condition Preventive Maintenance The plant meterial cor# don wee accepteNe PM program wee necepteNe

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s Backlog of momenarce activmee had been priortrod a

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~: a PMs required %r restartwere completed m impact en oporstone assessed g

@ a e Condition based mondormg procedure was recortly leeued to O

O e Housekeeping and equipment serage wre gewracy improve tw PM program appropnate

, j :. t m.{ e PM procedureswere generally ecceptatWe gy e Observed equipment condmoriwee accepenbee g w ii -w oon -

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Surveillance Testing OSTI Conclusion SurwMence teedng program wee accepenNe j j e The OSTI furjings are one input used by

.' S . swvenance wenng proceduree =re necepmo" ~! ' the NRC Restart Assessment.Tnel(RAP)

. surve4=nce um procedwe edherence was good g in making a restart recommendation to the g

' Commission . tecteucere perionung wenng were quan.d .nd f, kaa**o'** gj e The OSTI conclusion is contingent upon the licensee's successful completion of

. Pr wm nr.nnes a me coordin.imn wie operwmn. =s m

' those items identified as required prior to restart w w een ,,

OSTI Conclusion (Cont.)

P The OSTI has concluded that plant g

hardware, staff, and management a programs are ready to support a safe

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plant restart anti continued plant operation of Millstone Unit 2 6