ML20207B605
| ML20207B605 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/04/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20207B611 | List: |
| References | |
| NUDOCS 8612110002 | |
| Download: ML20207B605 (2) | |
See also: IR 05000245/1985098
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DEC 0 41986
Docket Nos. 50-245; 50-336
Northeast Nuclear Energy Company
ATTN: Mr. J. F.- Opeka
Senior Vice President - Nuclear
Engineering and Operations Group
P. O. Box 270
Hartford, Connecticut 06141-0270
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Reports 50-245/85-98
and 50-336/85-98, and Your Reply Letter Dated November 5, 1986
This refers to the Millstone Unit 1 and 2 SALPs for the period from March 1, 1985
through May 31, 1986. The SALP reports were initially forwarded to you by our
August 29, 1986 letter (Enclosure 1). On October 2, 1986, at a management meeting
on the Millstone site, we discussed the SALPs with you and your staff (see Enclo-
sure 2 for attendees). We have reviewed your written comments (Enclosure 3) and
herewith transmit the final SALP reports (Enclosure 4).
After the October 2, 1986 management meeting, we concluded that your comments about
assigning a grade to'the Unit 1 Refueling and Outage Management area were valid
and re-examined that area. After supplementing the observations with relevant
observations from other SALP areas, the SALP board assigned this area a Category
1 rating.
We noted your extensive comments on the Unit 1 Maintenance and Modifications area.
While we acknowledge the points you make, we still have an overall concern about
the scram solenoid valves, the main turbine mechanical pressure regulator, the
emergency gas turbine (EGTG), and the three scrams related to this area. We modi-
fied the SALP evaluation to reflect the role of faulty replacement parts on EGTG
performance, but our review also affirmed the Category 2 rating assigned to this
area.
For the Unit 2 SALP of the Plant Operations area, you commented that Licensee Event
Reports (LERs) need address failed components only when such failures occur. We
agree. As a matter of clarification, the NRC concern developed from the LERs re-
viewed is about identifying the manufacturer and model of failed components so that
information recipients can take more timely actions.
We have also made minor corrections to the SALPs. These did not result in any
changes in the associated SALP ratings.
We appreciate your responses to the SALP comments and your discussion of plans to
improve performance. Thank you for your cooperation.
Sincerely,
T
8612110002 861204 Drigi'nal signed by
PDR ADOCK 05000245 Ito as E. Murley,
O PDR Thomas E. Murley
_ Regional Administrator
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Northeast Nuclear Energy Company 2
DEC 0 41986
Enclosures:
1. NRC Letter, T. E. Murley to J. F. Opeka, Dated August 29, 1986
2. SALP Management Meeting Attendees, October 2, 1986
3. NNEco Letter, J. F. Opeka to T. E. Murley, Dated November 5,1986
4. Region I Systematic Assessment of Licensee Performance (SALP)
Report 50-245/85-98; 50-336/85-98
cc w/encis:
E. J. Mroczka, Vice President, Nuclear Operations
W. D. Romberg, Station Superintendent
D. O. Nordquist, Manager of Quality Assurance
R. T. Laudenat, Manager, Generation Facilities Licensing
Gerald Garfield, Esquire
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC) -
NRC Resident Inspector
State of Connecticut
Chairman Zech
Commissioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Carr -
Vandana Mathur, McGraw-Hill Publications (2 copies)
bec w/encls:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief
J. Shea, LPM, NRR
T. Murley, RI
T. Martin, RI
W. Kane, RI
S. Ebneter, RI
R. J. Bores, DRSS
J. Shediosky, SRI, Millstone 3
P. Swetland, SRI, Haddam Neck
! M. McBride, RI, Pilgrim
K. Abraham, RI (2 copies)
NRC Management Meeting Attendees
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ENCLOSURE 1
gf asc%'c, UNITED STATES
E " . ,., ^g NUCLEAR REGULATORY COMMISSION
- j REGION I
0,, 531 PARK AVENUE
KING oF PRUSsl A, PENNSVLVANIA 194M
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Docket Nos. 50-245 MG29 N
50-336
Northeast Nuclear Energy Company
ATTN: Mr. J. F. Opeka
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Senior Vice President - Nuclear
Engineering and Operations Group
P. O. Box 270
Hartford, Connecticut 06141-0270
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report Numbers
50-245/85-98 and 50-336/85-98
On July 28, 1986, the NRC Region I SALP Board reviewed and evaluated the perform-
ance of activities associated with the Millstone Nuclear Power Station, Units 1
and 2. These assessments are documented in the enclosed SALP Board Reports. You
will note that much of the performance analyses are the same for both units in the
arees of Radiation Controls, Emergency Preparedness, Security and Safeguards, As-
surance of Quality, and Training and Qualification Effectiveness. Common assess-
ments are included in both reports to make each unit's SALP Report complete.
A meeting at the site to discuss these assessments will be scheduled. That meeting
is intended to provide a forum for candid discussions relating to the performance
evaluation.
At the meeting, you should be prepared to discuss our assessment and your plans
to improve performance, particularly in the radiation protection area. Any com-
ments you may have regarding our report may be discussued at the meeting. Addi-
tionally, you may provide written comments within 30 days after the meeting.
Following our meeting and receipt of your response, the enclosed reports, your re-
sponse, and a summary of our findings and planned actions will be placed in the
NRC Public Document Room.
Your cooperation is appreciated.
Sincerely,
-.
Thomas E. Murley
Regional Administrator
Enclosures:
1. NRC Region I SALP Report 50-245/85-98
2. NRC Region I SALP Report 50-336/85-98
3. Northeast Utilities Letter B11979 dated March 13, 1986.
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Northeast Nuclear Energy Company 2
G291995
cc w/encls:
E. J. Mroczka, Vice President, Nuclear Operations
W. D. Romberg, Station Superintendent
D. O. Nordquist, Manager of Quality Assurance
R. T. Laudenat, Manager, Generation Facilities Licensing
Gerald Garfield, Esquire
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut
bec w/encls:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief .
J. Taylor, IE
T. Murley, RI
S. Ebneter, DRS
T. Martin, DRSS
E. McCabe, DRP
E. Conner, DRP
D. Holody, RI
P. Lohaus, RI
J. Shea, NRR
D. Jaffe, NRR
SALP Board Members
DRS Branch Chiefs
DRSS Branch Chiefs
DRP Branch Chiefs
K. Abraham, RI (2 copies)
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ENCLOSURE 2
MILLSTONE UNITS 1 AND 2 SALP MANAGEMENT MEETING
WATERFORD, CONNECTICUT
OCTOBER 2, 1986
Northeast Nuclear Energy Company
W. Ellis, Chairman and Chief Executive Officer
W. Fee, Executive Vice President - Nuclear Engineering and Operations
J. Opeka, Senior Vice President - Nuclear Engineering and Operations
E. Mroczka, Vice President - Nuclear Operations
C. Sears, Vice President - Nuclear and Environmental Engineering
W. Romberg, Station Superintendent
J. Stetz, Unit 1 Superintendent
S. Scace, Unit 2 Superintendent
J. Kelley, Station Services Superintendent
M. Black, Simulator
K. Burton, Unit 3 Operations Supervisor
E. Foster, Unit 2 Engineering
R. Kacich, Licensing Supervisor
R. Laudenat, Licensing Manager
D. Nordquist, Nuclear and Environmental Engineering
R. Palmieri, Unit 1 Operations Supervisor
R. Place, NUSCo Nuclear Safety Engineer ..
P. Prezekop, Unit 1 Engineering
J. Shea, Unit 1 Project Manager
J. Kangley, Radiation Services Supervisor
B. Granados, Health Physics Supervisor
R. Graves, Haddam Neck Superintendent
R. Asafaylo, Quality Services Supervisor
J. Smith, Unit 2 Engineering Supervisor
G. Baston, Nuclear and Environmental Engineering
W. Renfro, Nuclear and Environmental Engineering
R. Harris, Nuclear and Environmental Engineering
J. Sullivan, Health Physics
G. Closius, Quality Assurance / Quality Control
E. Debarba, Generator Engineering
F. Dacimo, Unit 2 Maintenance
U.S. Nuclear Regulatory Commission
T. Murley, Regional Administrator
T. Martin, Director, Division of Radiation Safety and Safeguards
E. McCabe, Chief, Reactor Projects Section 38, Division of Reactor Projects
A. Thadani, Director, PWR Project Directorate #8, Office of Nuclear Reactor
Regulation (NRR)
D. Jaffe, Licensing Project Manager, Millstone 2, NRR
T. Rebelowski, Senior Resident Inspector, Millstone 1 and 2
G. Grant, Resident Inspector, Millstone 1 and 2
F. Casella, Resident Inspector, Millstone 3
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ENCLOSURE 3
NORTHEAST UTILITIES o.n.r.i Ome.. . s.io.n sir..i. e.rnn. Conn.ciicui
l En EcN'*Y*$ P.O. BOX 270
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HARTFORD. CONNECTICUT 06141-0270
L L J 7.'.~. '7d".U,"," ~, (203) 665-5000
November 5,1986
Docket Nos. 50-245
50-336
B12312
.
Dr. Thomas E. Murley, Regional Administrator
Region i
U. S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Gentlemen:
Millstone Nuclear Power Station, Unit Nos. I and 2
Systematic Assessment of Licensee Performance
The Staff recently forwarded the SALP Board Reports (I) for the 15-month period
ending May 31, 1986, for Millstone Unit Nos. I and 2. Subsequent to receipt of
the SALP Board Reports, a meeting was held on October 2,1986 between
members of the Staff and members of Northeast Nuclear Energy Company
(NNECO).
.
The purpose of this letter is to respond to and comment on the findings of the
SALP Board with particular emphasis on the Board recommendations for the
individual evaluation categories. The responses to the Board's recommendations
for Millstone Unit No. I and Millstone Unit No. 2 are contained in Attachments
A and B, respectively, to this letter. This response was due to be submitted on
November 3,1986. In a telephone conversation with a member of your staff on
November 3,1986, NNECO was granted an extension to November 5,1986, for
the submittal of this letter.
NNECO takes very seriously the ratings and recommendations given by the Board
as an input into the continuing process of evaluating and improving our overall
performance. As reflected by our comments and observations during the October
2, 1986 meeting, we generally concur with the Board's observations and
previously have taken or are taking steps to address the concerns identified, it
remains our objective to achieve Category I ratings in all functional areas for
subsequent SALP evaluations, and the attachments to this letter describe some
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of the steps we will be taking to fulfill that objective.
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T.E. Murley letter to 3.F. Opeka, "SALP Report Nos. 50-245/85-98 and
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L 50-336/85-98," dated August 29,1986.
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We trust that the actions presented in the attachments addressing the concerns
of the Board and our general comments will be considered in subsequent SALP
evaluations. We will be updating you regarding the status of implementing the
corrective actions discussed herein prior to the next SALP evaluation.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
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J.F. Opeka '
Senior Vice President
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By: C.F. Sears
Vice President
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Docket No. 50-245
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. Attachment A.
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Northeast Nuclear Energy Company
Millstone Unit No.1
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Response to SALP Report -
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Functional Area: PLANT OPERATIONS
Board Recommendation: None.
Response:
The report states that weaknesses were noted in the " correction of Isolation
Condenser valve motor-operator problems." We suggest that the term " motor-
operator" be deleted since the problem was with the valve itself and not the
motor-operator.
We will continue to evaluate the need for a full-time onsite fire protection
coordinator, as was suggested in the report.
The report mentions various weaknesses identified in LER preparation. We are in
the process of reviewing NRC's report from AEOD on this issue dated July 21,
1986. This is the first formal feedback from the NRC on Millstone LERs.
Identified weaknesses will be addressed.
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Functional Area: RADIOLOGICAL CONTROLS
Board Recommendation: Improve radiation worker training to stress worker
awareness of and compliance with Health Physics procedures. Improve the
effectiveness of the ALARA program. Strengthen assurance of quality in the
,
transportation area.
Response:
This functional area contained numerous criticisms, the majority of which we
agree with. The SALP Board recommendations identified three major areas of
concern, namely radiation worker training, effectiveness of the ALARA pro-
gram, and assurance of quality in the transportation area. As a result of the
difficulties experienced in this area, NU has initiated changes to the
occupational radiation exposure controls program, the ALARA program, and the
radioactive waste management program.
The radiation exposure controls program changes being made are in both the
training and accountability areas. Radiation worker training is administered as a
part of our General Employee Training. This training of all radiation workers at
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NU, is modified annually to include lessons learned from the previous year, as
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weil as NRC/INPO and NU significant findings from the previous year. Since
most of our radiation workers, including contractors, have previously worked at
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our facilities and received such training, it is expected that these annual
reinforcements will heighten the awareness of these indivic'uals in this area. NU
also believes that supervisors are a key ingredient in assuring radiation worker
protection. Accordingly, we have reminded supervisors of their responsibility to
be fully cognizant of the tasks that they assign to their employees and
contractors. This includes providing all the tools, equipment, knowledge and
controls, such that these individuals can complete their tasks safely, efficiently
and in a high quality manner.
To provide the impetus to ensure that training and supervisory reinforcement are
effective, a program to monitor and enforce radiological practices will be
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developed and implemented by March 1,1987.
Regarding the Exposure Reduction and ALARA program, NU has recently
initiated a number of further actions in an attempt to lower collective exposures
to levels consistent with INPO goals.
Our efforts regarding Exposure Reduction Initiatives have been continuing and
are expected to yield paybacks in person-rem reduction. They include methods
to reduce dose rates and work scope, and improve worker efficiency. These
initiatives are currently receiving a multidiscipline (engineering, construction,
operations and ALARA-involving home office and site personnel) review for
prioritization and incorporation into the short-term (1 to 2 years) and long-term
(2 to 5 years) Soals program.
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It should be noted that, over the past few years, Millstone Unit No. I has been i
among the best domestic BWRs in regard to total occupational exposure. .
The radioactive waste management program has received considerable attention
since the formation of a special committee to review the entire radwaste
program. The results of that committee's efforts have led to the following
changes:
o The on-site radwaste handling group is being reorganized to provide a
dedicated, permanent staff with greater resources for implementation of
the program. The supervisory position was upgraded to attract and retain a
more skilled individual. Assistant supervisor and station technician post-
tions were created to assist with program administration. The authorized
working staff was doubled to reduce the number of contractors involved
with radwaste activities. It is expected that this organization will be fully
implemented and staffed by the end of 1986.
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o The training of radwaste handling and quality control personnel to increase
their knowledge of radwaste manifest preparation, shipping and burial
regulations is continuing. Radwaste supervisory personnel have attended,
- or are scheduled to attend, a training program in shipping preparations,
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classifications and burial regulations offered by Chem-Nuclear. The
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program includes a trip to the Barnwell, South Carolina facility aimed at
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Increasing the supervisors' awareness of radwaste shipment from the
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receiver's perspective.
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o NEO Procedure 6.07, " Quality Assurance and Quality Control in Station
Radioactive Material Processing, Classification, Packaging, and Transpor-
tation," defining quality aspects of the radwaste shipping process, has been
issued. Implementation of this procedure has resulted in meaningful
quality checks of the entire shipping process.
o Reactivation of the Radwaste Review Committee with an expanded
charter which includes transportation issues has occurred.
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o Increased attention by the quality organization through additional audits
and surveillances will be utilized to ensure the effectiveness of the
proposed corrective actions.
o A proposal for the formation of a dedicated home office engineering staff
to address broad radwaste issues such as volume reduction, burial alloca-
tion, radwaste system engineering, decontamination and decommissioning
has recently been approved for implementation in 1987.
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It is our expectation that these significant forward steps will resolve the
difficulties we have experienced in the radiological controls area.
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Functional Area: MAINTENANCE AND MODIFICATIONS
Board Recommendations: None.
Response:
We believe that the SALP Report in several limited respects does not accurately
reflect Millstone Unit No. I performance in this functional area. In the summary
^
of this section, the report states that "much outstanding maintenance work was
noted and the environmental qualification program was well implemented, but
- there were significant problems with the scram solenoid pilot valves, with the
emergency gas turbine generator, and with the main turbine mechanical pressure
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regulator. These indicate a need to more effectively assure that aging and/or
obsolescent equipment is replaced and, where appropriate, redesigned so as to
minimize the effect upon and challenges to safety systems." Additional
information regarding each of these three items is provided belows
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t 1. Scram Solenoid Pilot Valve Rework
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During the 1985 Refueling Outage, 45 scram solenoid pilot valves were
' reworked. The valves were selected as part of our continuing program to
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replace Buna-N material. This has been a routine maintenance and upgrade
activity during recent refueling outages. During control rod scram testing
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valves, three valve failures were experienced. Two of these valves had
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been rebuilt durin5 the outage. The SALP Report considers inadequate
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testing of the valves after rework and before power operation to be a
prime factor in these failures.
Contrary to this conclusion, adequate retest was a serious concern and was
discussed at length prior to performing the work. Since valve performance
affects control rod scram times, selection of the valves to be rebuilt, in
addition to other factors, was made based on the ability to perform scram
timing on those valves after the outage (by June,1986) without signifi-
cantly impacting plant capacity factor or introducing a possibility of
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challenges to safety systems. In-place retests cannot be adequately
performed during the outage because of the potential for subsequent
control rod drive seal damage that could occur when the reactor vessel is
not pressurized.
It was noted in the SALP Report that " discussions with maintenance
personnel revealed a high level of knowledge about current maintenance
activities. This included the scram solenoid rework effort. . . ". Again,
this comment recognizes the planning and attention to detail that went
into overall performance of this task.
The SALP Report also references our commitment to rebuild the remaining
solenoid valves by June, 1986. In the context of the report, this ,
commitment is presented as being an NRC mandate due to our rework
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schedule not being timely. Contrary to the above, it should be noted that
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this commitment was our initiative based on what we believed to be timely
completion of a rework program.
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In conclusion, we do not believe that the SALP summary reflects a true
understanding of our performance of this task, nor does it present a valid
conclusion in identifying our pro 6 ram as a significant problem. It should in
no way serve to lessen the SALP rating in this category. Instead, it should
serve as an example of our ability to effectively plan and carry out
maintenance activities, to react to unexpected conditions encountered
during performance of these activities, and to plan and perform appropri-
ate corrective measures.
2. Gas Turbine Performance
On November 27, 1985, the Gas Turbine received a start signal and failed
to start. Investigation revealed that the Gas Turbine tripped on high
exhaust temperature. The " root cause" of this event was a failure of the
Air Start Regulator Valve. This valve had just been installed prior to the
failure. The valve that failed had been rebuilt by the manufacturer and all
associated Q.A. documentation was in order. This valve was installed in
response to an SEP commitment to the NRC to replace governor controls
on a routine basis.
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On January 13, 1986, while performing an operational readiness demonstra- .
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tion af ter maintenance but before declaring the Gas Turbine operable, the
Gas Turbine failed to start. Preliminary information indicates that the
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event was due to a fault in the Electric Governor Regulator. This Electric
Governor Regulator had been installed on January 8,1986 as a result of a
preventative maintenance program. All Q.A. documentation was in order,
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and the testing of the Gas Turbine was the re-test for the EGR replace-
ment.
It is apparent that the two Gas Turbine failures were not due to our
inability to replace aging equipment. The second failure was caused by and ,
detected during the retest following s routine chanbeout of a governor
component. These failures shculd not even be included in this report, since
the failures were attributable to the replacement components which were
installed to preclude unanticipated failures.
Credit for proper routine maintenance efforts should be given. An example
of such an effort was the re-adjustment of the Servo-limiter that was
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performed on August 21, 1986. However, maintenance and routine
activities, "which may have prevented a failure," are very hard to
document and thus hard to credit.
The SALP Report states that our " procedures, training, trending of
equipment characteristics, and management overview have been increased,
but these actions were primarily responsive ones." We recognize that there
have been problems related to the Gas Turbine Generator. In the past, and
especially since 1982, we have made continuous changes in our procedures
and programs to increase the reliability of the machine. We have been
very successful in this effort, as can be seen from system performance
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improvement. Further experienced-based improvements to our programs
are being made, but to say that these actions are solely responsive ones is
both inaccurate and invalid. Instead, they demonstrate our ability to
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develop effective monitoring and maintenance pro 6 rams, to implement
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these programs, and to make changes to these programs based on new data 1
and operational experience. It should be recognized also that, since this
system is unique to Millstone Unit No.1, we are developing our programs
based on Millstone Unit No. I experience only, rather than from an industry
data base. Under these conditions, more frequent program changes and
longer program development times are expected. We believe that our
actions related to the Gas Turbine Generator have been both effective and
justified, and therefore do not provide reason for lessening the sal.P rating
.
in this category.
3. Mechanical Pressure Regulator Performance
on February 5,1986, the Mechanical Pressure Regulator (MPR) System
failed, causing a pressure oscillation resultin6i n a reactor scram. Mainte-
nance, which included planned replacement of the sensing bellows gasket
and the inspection of a snubber valve, had been performed on the MPR
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during our recent 1985 refueling outage. During this refuel outage, the
, snubber valve was found to have some slight contamination and was
cleaned. Following the reactor scram, the MPR was adjusted, tested, and
returned to service. Additional work on the MPR was scheduled for the
next outage. -
On May 21, 1986, while shutting down for a planned turbine rotor
inspection, a manual scram was initiated when reactor pressure began to
oscillate due to the malfunction of the MPR. Operator initiation of a
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manual scram was a conservative response by the operator to this
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situation. Planned maintenance was again performed on the MPR, which
included an inspection of the snubber valve as well as modifications to the
rate adjustments. The snubber valve had been clogged with a foreign
substance. The valve was cleaned and returned to service. The MPR was
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adjusted, tested, and returned to service. As an added preventative
measure, the snubber valve was scheduled for replacement.
On August 28, 1986, the snubber valve was replaced. The valve that was
removed was once again clogged. Further investigation revealed that the
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nickel plating had been worn off the valve. This most likely is the result of
steam passing through the valve when the MPR had a faulty gasket. The
valve had not been replaced earlier due to long lead times in obtaining
spare parts. Future inspections and preventative maintenance of the new
valve are planned to preclude future misoperation due to internal clogging
of the component. An investigation into the source of the clogging is
continuing. We are confident that the root cause is not associated with
aging components.
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The attention given to this system has been greatly increased over the past
several years. We are presently in a transition state, going from what once
was complete vendor support to an in-house maintenance program for this
system. In all cases, we have utilized experts from various manufacturers
and have followed their maintenance recommendations. It should be noted
here that actions taken to date have resulted in a marked improvement in
MPR operation. We believe that we will now begin to see a system
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reliability improvement associated with program enhancements. In gener-
al, we believe that this is another example of our ability to make effective l
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program changes to improve plant reliability and reduce the probability for
challenges to safety systems. MPR performance is not related to an ,
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inadequate maintenance program to replace aging components, and should
not serve to lessen the SALP rating in this area. l
Additional Maintenance Programs
The report does not give credit to upgrade programs that have helped to
increase our reliability. Some examples of these programs are listed
below.
Reactor Recirculation System
' A. Recirculation Speed Control components were replaced.
B. The installation of a new type of Motor Generator Field Brush with
significantly longer . operating life to minimize brush wear was
completed.
C. A program to test the Motor Generator is ongoing.
D. A new Motor Generator Field was procured.
i E. The existing Motor Generator Field was re-built.
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A-13
Feedwater and Drains System
A. Heater Bay Positioner upgrades to improve performance and reliabil-
Ity have been completed.
B. Periodic Feedwater Control Valves Positioner changeouts are
ongoing.
C. The installation of additional Feedwater Flow Transmitters to im-
prove plant monitoring capability has been completed.
D. The installation of new Reactor Level Transmitters has been com-
pleted.
E. The installation of new Reactor Pressure Transmitters has been
completed.
F. A program to replace Feedwater Control System components is
ongoing.
G. Routine performance checks of the following are ongoing:
1) Feedwater Control Valves and their lock-ups
2) Moisture Separator Drain System
3) Feedwater Heater Controls.
Gas Turbine Generator
l
A. Gas Turbine Regulator components have been replaced to improve
reliability.
B. A dehumidifier was installed in the regulator compartment to prevent .
corrosion damage to regulator components.
,
C. The Gas Turbine batteries were replaced.
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A-14
D. The Gas Turbine . Generator Rotor was replaced when inspection
revealed possible insulation problems.
Electrical Systems
A. Routine checks of the Main Generator Regulator are ongoing.
B. Routine checks of the station transformers to monitor performance
are ongoing.
C. Routine checks of the 4160 volt motors are ongoing. -
D. The calibration of all protective relays is ongoing.
E. A program to calibrate station time delay relays has been instituted.
F. The station 125V batteries have been replaced.
G. The Neutron Monitoring System batteries have been replaced.
H. All solenoids on the Main Turbine have been replaced.
I. Contact inte5rity tests of pressure switches are ongoing.
Balance of Plant
t
A. A balance of plant vibration monitoring program was initiated for all
rotating plant equipment.
B. Improvements to plant air systems to minimize potential for cross-
contamination of plant components were implemented.
C. Improved condenser leak detection methods to reduce personnel
radiation exposure and minimize plant capacity factor impact have
been implemented. ,
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A-15
D. A Service Water System inspections program to improve reliability
has been implemented.
E. The Service Water Strainer isolation valves were replaced.
F. The screen wash strainer body was replaced and the internals were
coated to increase component lifetime.
This list is incomplete, but is representative of the type of program development
and plant improvements that are being implemented at Millstone Unit No.1.
Based on them and on similar programs like them, we believe they should provide
a highly favorable impact on the overall SALP rating in this category.
Based on our review of the SALP Report and our perception of our performance,
we have not identified a basis for an overall rating of Category 2 in the area of
Maintenance and Modifications. It appears that the NRC assessment of items 1, -
2 and 3 above could be altered based upon the information contained in this
letter. We believe that the Millstone Unit No. I rating for this functional area
should be Category 1.
It should also be noted here that Millstone Unit No. I completed 374 days of
continuous power operation during the assessment period. Our success in
implementing successful maintenance and modification-related tasks is directly
reflected in this accomplishment. As plants get older, it is expected that
-
1
- attention to detail in planning and performance of component maintenance must
increase. Our operating accomplishments, capacity factor and availability
demonstrate our success in these areas. The capacity factor for Millstone Unit
j No. I was 81.2% for this SALP period (93.4% capacity factor not counting
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A-16
refueling period). This compares favorably with the average capacity factor for
US BWRs during 1985, which was 54.3 (1) The forced outage rate for Millstone
Unit No. I was very low, namely,1.7%, while the rest of the industry averaged
11.9
(1) " Operating Units Status Report," dated January,1986.
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in Functional Area: SURVEILLANCE
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- Board Recommendation
- None.
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- Response
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No comments.
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Functional Area: EMERGENCY PREPAREDNESS '
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Board Recommendation: Reassess effectiveness of commitm'e nt' tracking sys-
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Response:
There was no discussion in the SALP report relating to this recommendation.
However, it should be pointed out that a comprehensive; commitment follow
system is used for all drill and exercise critique findings. ~ This is periodically
updated. In addition, there are emergency preparedness (EP) surveillance
tracking systems to ensure that periodic emergency fac!!ity anc equipment test:
are accomplished. A station Administrative Control Procedure will be effective
in November,1986 to formalize this EP surveillance system. We suggest that
the NRC review the above systems at a future date.
.
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i Functional Areat SECURITY AND SAFEGUARDS
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Board Recommendation: None.
Response:
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No comments.
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Functional Area: REFUELING AND OUTAGE MANAGEMENT
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Board Recommendation: None.
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Responses s,
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This section of the SALP Report reflects what we believe to be an accurate
,
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representation of our performance during the 1985 Refueling Outage. No rating
~
was given due to what the inspectors determined to be insufficient time for
'
j'; performing an accurate evaluation.
As noted in the SALP Report, significant activitics were performed during the
,
period from October 25, 1985 to December 23, 1985. These activities included
weld overlay repair of the jet pump instrumentation vessel nozzles and isolation
condenser steam supply lines, replacement of safety-related valve motor oper-
ators with environmentally qualified units and the replacement of the emergency
gas turbine generator rotor. Not mentioned in the report, but considered by us
,
to b'e significant in nature, was cleaning of the recirculation pump MG set fields.
ThiC task was planned based on trending of component performance, and
.\k
demonstrates our ability to anticipate and correct situations that, if left
unattended, could result in signicant losses in unit availability and capacity
'
s factor. All major activities were completed with no significant problems, as ,
, noted in the report, due to planning and good communication during performance
,
of the work.
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A-21
The report also makes mention of our on-line management decisions that were
instrumental in effective implementation of piping repair activities. These
activities occurred without major impact on the outage duration because we
anticipated the piping problems and planned accordingly.
Although 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of inspection time represents only 2% of the total inspection
time that was expended to assess our performance, we believe it to be sufficient
in providing a rating in an area in which every aspect of our performance was
found to be outstanding. If more inspection time would have been available, we
believe that it would only strengthen the assessment made in the report.
Additionally, because of the manner in which refueling and outage management
data are presented to inspectors (e.g., published reports, daily updated schedules
and log books, etc.), assessments made in this area are not expected to require
the same number of inspection hours as would be required in other areas. Not
providing a rating for a functional area where we believe a Cr.tegory I rating is
deserved sends a negative signal to Millstone Unit No. I personnel involved in
this area. We would request that a rating be provided based on the inspection
performed. We firmly believe the correct rating is Category 1.
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A-22
Functional Area: ASSURANCE OF QUALITY
Board Recommendation: None.
Response:
This functional area is a synopsis of the assessments in the other nine areas. The
responses for the other functional areas address specific actions which are being
taken to minimize and/or eliminate problems in those areas.
,
As stated in our response to Maintenance and Modifications, we believe that we
have good programs to assure quality performance of aging equipment and
adequate post-maintenance testing. As is stated in our responses to both the
Radiological Controls and the Training and Qualification Effectiveness func-
tional areas, we are taking significant measures to improve worker adherence to
and endorsement of routine radiation protection controls. We will continue to
take measures to improve our assurance of quality in all areas.
.
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A-23
Functional Area: TRAINING AND QUALIFICATION EFFECTIVENESS l
Board Recommendation: None.
Response:
Since the end of this SALP period, four of ten training programs have been
accredited by INPO. The four operator training programs, for non-licensed
operators, reactor operators, senior reactor operators and shif t technical ad-
visors, received accreditation from INPO on August 21, 1986. On October 1,
.
1986, the Self-Evaluation Reports for the remaining six training programs were
submitted to INPO. INPO reviews and site accreditation visits for these six
programs are not expected to be completed until well into 1987. Although not
yet accredited, these training programs are already in place, with most of the
lesson plans complete. Including all four nuclear units at NU,1533 training
programs are scheduled for 1987.
The Nuclear Training Department undertook a major reorganization during the
SALP period to meet the corporate goal of " training excellence." The training
.
staff (which has tripled since 1984) is committed and dedicated to the develop-
ment and delivery of superior quality training in all operator and technical
,
disciplines. We expect these efforts to result in performance-based improve-
1
i ments of the job incumbents. Some of the changes that have been implemented
to re-orient operator and technical training include:
. - - - - -
A-24
(1) Installation of the Millstone Unit No. I Simulator
o On-site reverification testing was completed in May,1986.
o Availability of the simulator has resulted in significant enhancements
to Licensed Operator Training Program and provided opportunities to
support other station activities.
o Since July,1986, the simulator has been used to support the Licensed
.
Operator Requalification Program. It is anticipated that the simu-
lator will be used to support approximately 50 percent of licensed
operator requalification training in future years.
o ' The simulator has been integrated into both Reactor Operator and
Senior Reactor Operator Initial Training Programs. The simulator
portions of these programs, each consisting of approximately 200
hours, began on September 29, 1986, and is currently ongoing. A
Senior Reactor Operator upgrade class is currently scheduled to begin
approximately February 2,1987.
(2) I&C Technician Understanding of Technical Specifications
o The Instrument and Controls (l&C) instructional staff prepared and
delivered in May, 1986, a four hour presentation of Technical
specifications to 100% of the Millstone Unit No. I and 2 I&C
Department's Technician staff.
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. . A-25
.
(3) Radweste Transportation and Handling
As was stated in our response (2) to Combined Inspection No. 50-245/86-06,
50-336/86-06, and 50-213/86-04, several corrective steps to avoid radwaste
shipping problems are being taken.
Additional training has been provided to individuals involved in the
shipment of radioactive waste to assure suitable proficiency in the area of
transportation of radioactive material.
Title Dates
o NUS training session for Radwaste Handlers 03/31/86 - 04/01/86
o NUS training session for Radioactive 04/02/86 - 04/04/86
Materials Supervision, Shippers and QA/QC
Inspectors
o NUSCO Training Department course of 07/14/86 - 07/18/86
radioactive materials shipping 07/21/86 - 07/25/86
o CNSI Workshop on Radioactive Waste 05/28/86 - 05/30/86
Packaging, Transportation and Disposal
- attended by Radioactive Materials
Handling Supervisor
(2) J.F. Opeka letter to T.E. Murley, " Response to I&E Inspection No. 50-
245/86-06,50-336/86-06 and 50-213/86-04," dated August 21,1986.
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A continuing training program for Radwaste personnelis being developed.
o- The Health Physics section of the Technical Training Branch of the
Nuclear Training Department will complete a job analysis and pro-
cedure based task analysis in accordance with procedure NTM-1.06,
" Systematic Instructional Design" for the following areas: Radwaste
Handlers, Radwaste Supervision and Station Technician (R/W), and
Radwaste QA/QC by February 28,1987.
o A set of instructional objectives resulting from this analysis effort
will be produced and approved by the Training Program Control
Committee for Radwaste by March 30,1987.
o A performance based cor.tinuing training program consisting of
classroom and on-the-job training will be developed by July 30, 1987
and completely implemented prior to December 31,1987.
(4) At our request, INPO conducted an accreditation assistance visit at NU on
August 25-26, 1986, to review and make recommendations on our accredi-
tation efforts for the radiological protection technician training program.
,
. (5) The following items represent additional enhancements to our training
.
program:
o An electrical switchgear and motor control center lab has been created.
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o Two new instrument and controls labs have been established.
o Full-scale mock-ups for reactor coolant pump seal replacement training
have been procured for all four nuclear units.
o A full diesel engine has been procured for diesel overhaul maintenance
training.
o A full chemistry lab including all of the instrumentation used on all four
nuclear units has been established.
o A gamma spectroscopy lab has been built.
o A fully equipped and staffed graphics department has been established to
suppo-t the training department,
o A fully equipped technical library has been established.
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Functi'n-1 Ar a: LICENSING ACTIVITIES l
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Board Recommendations: None.
Response:
No comments.
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9
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_ Docket No. 50-336
Attachment B
Northeast Nuclear Energy Company
Millstone Unit No. 2
Response to SALP Report
.
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November,1986
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B-1
Functional Area: PLANT OPERATIONS
Board Recommendations: None.
Response:
We will continue to evaluate the need for a full-time onsite fire protection
coordinator.
.
The report mentions various weaknesses identified in LER preparation. Millstone
Unit No. 2 has reviewed the NRC's report from AEOD on this issue dated July
21, 1986, evaluating suggested improvements and specifically reviewin5 the two
,
" principle weaknesses" identified in the report summary: (1) failure to provide an
'
assessment of the safety consequences and (2) the lack of identified failed
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components.
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Concerning the failed component deficiencies, the report referenced 5 of the 10
l LERs reviewed as not having completed the failed component fields. NUREG-
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1022, including its supplements, requires that the failed component field be left
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blank if the event is not attributable to a failed component. Mr. Hebdon, the '
<
author of the 10CFR50.73 rule, confirmed this method of LER preparation at an
.
NRC/ Utility Symposium in 1985. Therefore, this identified weakness is un-
founded.
.
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The safety assessment, though implied in the LERs, was not specifically
identified or annotated as a safety assessment of the event. Therefore, in an
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B-2
effort to clarify LERs in the future, Millstone Unit No. 2 will adopt an outline
format in its LER preparation. This should eliminate the weakness as described
in the evaluation and ensure consistency in its LERs.
In addition to the proposed outline format, the entire evaluation by the NRC was
discussed with Millstone Unit No. 2 engineering department personnel to ensure
completeness in future LERs.
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Functional Area: RADIOLOGICAL CONTROLS
Board Recommendations: Improve radiation worker training to stress worker
awareness of and compliance with Health Physics procedures. Improve the
effectiveness of the ALARA program. Strengthen assurance of quality in the
transportation area.
Response:
..
See Millstone Unit No. I's response.
It should be noted that Millstone Unit No. 2 has had high exposure primarily
because of extensive steam generator repair requirements.
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Functional Area: MAINTENANCE AND MODIFICATIONS
Board Recommendations: None.
Response:
No comments.
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B-5
Functional Area: SURVEILLANCE
Board Recommendation: None.
Response:
The report discusses 2 violations occurring during the performance of the Local
Leak Rate Test (LLRT) program for Millstone Unit No. 2. The following actions
.
have been taken to ensure that similar violations do not occur in the future:
.
o Af ter the last LLRT was performed, a complete review of the program was
undertaken. This included a review of procedures, forms, and equipment
used during the LLRT program. The outcome was a revision to the
procedures and forms and an upgrade in equipment and its maintenance. In
order to address the finding on lack of calibration, each test requires the
operator to verify calibration dates prior.to the start of the test. In order
to address the finding on failure to follow procedures, the procedures were
.
clarified to provide clear direction and the operators were familiarized
with the use of the procedures.
'
o A discipline engineer has been assigned on a full-time basis the direct
responsibilitly of supervising the performance of the 1986 LLRT program.
His duties include assuring procedural compliance and scrutinizing every
aspect of the program for weak points or areas of uncertainty. He reports
directly to the Operations Supervisor.
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o The same discipline engineer mentioned above will recommend long-term
improvements to the LLRT program. It is anticipated that additional
procedural upgrades and procurement of state-of-the-art equipment will
ensure not only a program that complies with present regulations, but also
a LLRT program that could be a model for other facilities.
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Functional Area: EMERGENCY PREPAREDNESS
Board Recommendation: Reassess effectiveness of commitment tracking sys-
tem.
Response:
See Millstone Unit No. I's response.
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Functional Area: SECURITY AND SAFEGUARDS
!
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Board Recommendation: None.
Response:
No comments.
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.B-9
Functional Area: REFUELING AND OUTAGE MANAGEMENT
!
Board Recommendation: None.
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Response:
In the Facility Perforrnance table on page 6 of the report,it is incorrectly stated
that a Category 2 rating was assigned for the previous SALP period for the
Refueling / Outage Management functional area. A Category I rating was
actually assigned.(I)
,
, (1) See the T.E. Murley letter to J.F. Opeka, " Systematic Assessment of .
Licensee Performance," dated May 20,1985, page 5 of Millstone Unit No. ~
2's report. -
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-Functional Area: ASSURANCE OF QUALITY
Board Recommendation: None.
Response:
As stated in the report, this functional area is a synopsis of the assessments in
the other nine areas. The responses for the other functional areas address
specific actions which are being taken to minimize and/or eliminate problems in
those areas. We will continue to take measures to improve our assurance of
quality in all areas.
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B-11
Functional Area: TRAINING AND QUALIFICATION EFFECTIVENESS
Board Recommendation: None.
Response:
See Millstone Unit No. I's response.
.
(1) Installation of the Millstone Unit No. 2 Simulator
,
o Training on the simulator began on August 12,1985.
o Availability of the simulator has resulted in significant enhancements
to Licensed Operator Training Program and provided opportunities to
support other station activities.
o The simulator is being used to support the Licensed Operator
.
Requalification Program. It is anticipated that the simulator will
continue to be used to support approximately 50 percent of licensed
operator requalification training.
o The simulator has been integrated into both Reactor Operator and
Senior Reactor Operator Initial Training Programs. The simulator ,
i portions of these programs consist of approximately 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> and
!
[ 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, respectively. A licensed operator class and a licensed
operator upgrade class, each including simulator training, were
'
completed on July 3,1986.
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Functional Areat LICENSING ACTIVITIES
Board Recommendations: None.
Response:
No comments.
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