B11979, Forwards Updated Response to SALP Rept for 18-month Period Ending 850228.Util Mgt Active in Numerous Industry Initiatives & Various Industry Groups Addressing Wide Range of Nuclear Issues

Forwards Updated Response to SALP Rept for 18-month Period Ending 850228.Util Mgt Active in Numerous Industry Initiatives & Various Industry Groups Addressing Wide Range of Nuclear Issues

ML20138A785
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	03/13/1986
From:	Fee W, Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
B11979, NUDOCS 8603200086
Download: ML20138A785 (29)

Text

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GJm NT UTILITIES cener.i Orrico. . seioen sireet, e riin. connecticut 9 sin tes a cowa= P.O. BOX 270 l

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, (203) 66s-s000 March 13,1986 Docket No. 50-213 50-245 50-336 MI2J72)

Dr. Thomas E. Murley ,

Regional Administrator Region 1 __ g U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Systematic Assessment of Licensee Performance The SALP Board Reports (l) for the 18-month period ending February 28,1985, for Haddam Neck, Millstone Unit No.1, and Millstone Unit No. 2 were issued on May 20,1985. Af ter a meeting between members of the Staff, Connecticut Yankee Atomic Power Company (CYAPCO), and Northeast Nuclear Energy Compan 2)(NNECO) on June 4, 1985, Northeast Utilities (NU) submitted a response to the SALP Board recommendations for each of the individual evaluation categories.

The purpose of this letter is to provide an update on the status of the implemen tation of the corrective actions discussed in our July 5, 1985 correspondence. Items which were completed as of the July 5,1985 response are not discussed in this letter. Attachment I to this letter contains the status of the corrective actions related to the Haddam Neck unit which were incomplete as of July 5,1985. The status of the corrective actions for Millstone Unit No. I and Millstone Unit No. 2 are contained in Attachments 2 and 3, respectively.

(1) T. E. Murley letter to 3. F. Opeka, Systematic Assessment of Licensee Performance (SALP), dated May 20,1985.

f2) 3. F. Opeka letter to T. E. Murley, Systematic Assessment of Licensee Performance, dated July 5,1985. 1 l

J 8603200086 G60313 PDR ADOCK 05000213 0 PDR i, I g)O g

We are again taking this opportunity to offer some additional observations on our level of performance during the past year. In particular, we note that Northeast Utilities executive management is active in numerous industry initiatives, having made presentations at public meetings before the Commission as well as participating in meetings with senior Staff management. NU management personnel are active in, and in many instances chair, various industry groups addressing a wide range of nuclear issues.

Provided as Attachment 4 is a summary description of some of our attempts to further improve the quality of the regulatory process by providing the regulators with a continuing opportunity to become more familiar with our plants, procedures, and personnel.

We trust that the actions presented in the attachments for addressing the concerns of the Board will be useful in subsequent SALP evaluations. Feel free to contact us Ji any questions arise on these matters.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY s \ r J peka /

Se@nior Vice President

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By: W. F. Fee Executive Vice President l cc: C. I. Grimes A. C. Thadani ,

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i Docket No. 50-213 B11979 l l

Attachment I s.

Connecticut Yankee Atomic Power Company Haddam Neck Plant Updated Response to SALP Report O

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N Functional Area: PLANT OPER ATIONS Board Recommendations:

(A) Improve the quality and aggressiveness of self appraisal (B) Continue emphasis on operator requalification (C) Continue initiatives to improve procedural review (D) Assess the adequacy and timeliness of PIR/CR disposition UPDATE:

(A) Increased management concern for self appraisal and self identification programs has resulted in an upgrading of several existing programs.

The Plant Infor.mation Reports (PIR) system is undergoing procedural changes to place more emphasis on root cause analysis and corrective action. The improvements in the analysis of cause should make the PIR a more effective mechanism.

The Nonconformance Control Reporting system is functionally sound, but at times a backlog exists due to overall workload. Quality Assurance (QA) reviewers have been instructed to put greater emphasis on ensuring that cause and corrective actions are adequately addressed.

The QA audits are becoming more performance oriented. For example, technical specialists are used on QA audit teams, an engineering assurance function in the QA branch is being developed during the first quarter of 1986, and the use of QA surveillances to review field activities has been increased.

The Beneficial Suggestion program has been very successful, with employees making many excellent suggestions for improvement on a wide variety of topics. This is a unified system which includes Housekeeping, ALAR A/ Radiological Safety, Fire Safety, and Personnel / Industrial Safety.

An evaluation of required resources to handle the large quantity of suggestions will be performed af ter the 1986 refueling outage.

The Radiological Incident Report procedure has been upgraded and includes a description of the responsibility of the individuals involved in preparing the report, the methods of filing the report, and the actions to be taken.

The Station Housekeeping and Inspection Program was expanded to include department heads performing periodic inspections.

(B) The Connecticut Yankee Plant Reference Simulator officially began

" Customer Factory Acceptance Testing" at the Link Facility in Silver Spring, MD on August 5,1985. The trainer has since been delivered and its installation recently completed. Reverification testing is expected to be com' leted by the end of Marc  ? 86.

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rw (C) Improvements in procedural review and adherence are continuing. A method currently in use at the Millstone site involving management review and reissue of appropriate standing memos to station personnel as a reminder of the importance of following procedures and, where required, initiating changes to procedures, was implemented at the Haddam Neck Plant effective March 31,1986.

The new Emergency Operating Procedures (EOPs) are in final draft form, and the first stage of classroom training has been conducted. Validation is scheduled to be completed by the end of March,1986. Simulator training on the EOPs will start following validation with implementation scheduled for September,1986.

Annunciator response procedures for all applicable control room alarms have been completed.

(D) The Controlled Routing (CR) completion trend continues to improve. A comparison of 1985 to 1984 indicates a 29% decrease in the backlog of CRs even though there was a 19% increase in CRs issued. A similar trend exists with Plant Information Reports (PIRs), which shows a 26% improvement in the backlog of PIRs for the same time period. The data for 1986 CRs and PIRs has not been evaluated.

se Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:

(A) Efforts should be .made to strengthen management oversight and intradepartmental communications. An effective system far evaluating and correcting self-identified deficiencies should be developed.

(B) The licensee should expedite . efforts to seek a Technical Specification Amendment for PASS containment isolation valves to allow resumption of full system surveillar ce.

UPDATE:

(A) A task force's recommendations to improve coordination of work activities amongst departments were presented to the Station Superintendent, and are currently being implemented. Many of the recommendations have already been implemented and have been beneficial. During refueling outages, one individual from the op'e' rations department and one individual i from the maintenance department for each shif t have been assigned, as their full time duty, to coordinate and keep abreast of the status of equipment and work on a daily basis. Health Physics (HP) technicians now use " zone coverage" to facilitate identifying the appropriate HP technicians. In house HP technicians, as opposed to contractor personnel, are used in the field as much as possible to develop familiarity and trust between maintenance and HP personnel, in addition, more first line  !

supervision from HP and maintenance are active in the field.

(B) CYAPCO submitted a proposal to revise its Technical Specifications to allow ' for surveillance testing of normally closed, non-automatic containment isolation valves that are part of the Post-Accident Sampling System (PASS) on October 31, 1985. The proposed revision to Technical Specifications 1.8, Containment Integrity (definition) and new Table 3.11-2, Non-automatic Containment Isolation Valves, will allow testing of normally i

closed isolation valves in the PASS during operation modes 1,2,3, and 4 to ensure operahility. This revision was approved and issued by the Commission (l> as Amendment No. 72 to Facility Operating License No.

DPR-61 on February 19, 1986.

(1) F. M. Akstulewicz, Jr. letter to 3. F. Opeka, Technical Specifications to Permit Testing of the Post-Accident Sampling System, dated February 19,1986.

Functional Area: SURVEILLANCE Board Recommendations:

(A) Continue initiatives to upgrade surveillance procedures.

(B) Improve management control over items like CLRT issues :n order to assure that resolution is not unduly delayed.

UPDATE:

(A) A previously existing initiative to upgrade the surveillance program is on schedule and is expected to be completed in June,1986.

(B) Management control over Local Leak Rate Testing (LLRT) and Integrated Leak Rate Testing (ILRT) has been strengthened by reshaping our LLRT/lLRT program to achieve consistency and quality for all of NU's operating nuclear units. Nuclear Engineering and Operations Procedure, NEO 2.20, " Containment Leakage Rate Testing Program," was issued on December 10, 1955. This procedure establishes the methodology and interface responsibilities necessary to comply with 10 CFR 50 Appendix 3 requirements. Per the provisions of NEO 2.20, the Connecticut Yankee 1986 ILRT Plan was issued and is being implemented. The Plan delineates all NUSCO and CYAPCO engineering responsibilities and logistical activities necessary to conduct the ILRT.

As part of CYAPCO's effort to resolve containment leak rate testing concerns, a December 23, 1985 submittal (2) addressed several unresolved containment leak rate testing issues. In addition, a comprehensive reviev of the status of the Haddam Neck Plant's conformance with 10CFR50, Appet i .x 3 is currently being performed and is scheduled to be submitted in March,198, .

l (2) 5. F. Opeka letter to T. E. Murley, Haddam Neck - 10CFR50, Appendix 3 Compliance, dated December 23,1985.

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4 Functional Area: FIRE PROTECTION / HOUSEKEEPING Board Recommendations:

(A) Maintain attention to fire barriers.

, (B) Discuss with NRC the status of findings and corrective actions related to the Appendix R implementation program.

UPDATE:

$ (A) Fire barrier integrity is emphasized in General Employee Training, which is given to all employees. The Instrument and Controls Department held a

, training session on control of fire doors and penetrations. All of the

, station fire doors that are referenced in the technical specifications have a new sign describing in detail the commitments on fire doors.

1 (B) As a result of a comprehensive (3) review of CYAPCO's position relative to

Sections Ill.G, 3, and L of 10 CFR 50, Appendix R, new exemptions and

modifications were identified. Eight new subsequently filed on September 16, 1985(4) exemption requests were which incorporated the i

recommendations of the comprehensive review and the guidance provided by Generic Letter 85-01. The NRC Staff is presently reviewing the exemption requests and visited the Haddam Neck plant on l December 10,1985 to personally inspect the affected fire areas.

i The non-outage related hardware modifications were completed on August 14, 1985 in accordance with 10 CFR 50.48 schedules. Some of the outage related work is expected to be completed during the present refueling outage. The need for schedular relief was identified in the September 16,1985 submittal for the extensive switchgear room modifications. Circumstances surrounding the need for relief have been discussed informally with the Staff during the past several weeks. A

, formal schedular exemption request was submitted on March 7,1986.(5) 1 i

i (3) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated 4

June 18,1984.

(4) 3. F. Opeka letter to H. L. Thompson, Fire Protection, dated September 16, 1985.

(5) 3. F. Opeka letter to C.1. Grimes, Fire Protection - Schedular Exemption, date.d March 7,1986.

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Functional Area: EMERGENCY PREPAREDNESS Board Recommendations:

(A) Continue efforts to improve the coordination of emergency response activities.

UPDATE:

(A) The systematic computational comparison between licensee dose modeis and those used by the state was completed on October 28, 1985. The results of the comparison have been transmitted to the State of Connecticut. This was the only unresolved item in this functional area.

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l Functional Area: DESIGN CHANGE CONTROL / QUALITY ASSURANCE i

! Board Recommendations:

(A) Continue implementation of DCC/QA program improvements and review the effectiveness of the QA/QC surveillance effort.

UPDATE:

(A) In response to the December 13, 1984 Order modifying the Haddam Neck license,(6) the 355 Plant Design Change Requests (PDCRs) processed at the ,

Haddam Neck plant from January 1,1979 through December 31,1984 were '

reviewed to determine if any involved design changes of potential safety significance. in addition,20,294 Work Permits / Orders from the same time  ;

period were reviewed. The Plant Design Change External Review Gro transmitted the group's final report to the NRC on September 6,1985.py vi Included in that transmittal were the findings of the Connecticut Yankee Plant Design Change Task Group (CYPDCTG). A plan and schedule for the implementation of improvements in the design change process based on the recommendations November 6,1985. 81 (o( the CYPDCTG were submitted to the NRC on NUSCO Quality Assurance conducted a review of the coverage and effectiveness of quality control surveillance activities at Connecticut Yankee during October,1985.

The plant monitor program, designed to assess the actual "in-process work," was determined to need more in-field verification of ongoing ,

activities. Since 1984, the focus of the monitor program has been shifting more toward operating activities of a makr type such as startup testing.

The percentage of monitors involving actual in the field verification has been steadily improving. The content of the monitor reports is currently being improved to provide a better description of the activities observed.

(6) 3. M. Taylor letter to W. G. Counsil, Order Modifying License and Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-213, EA-84-il5, dated December 13,1984.

(7). D. E. Vandenburgh letter to T. E. Murley, Connecticut Yankee Plant Design i Change External Review Group Final Report, dated September 6,1985. '

(8) 3. F. Opeka letter to T. E. Murley, Haddam Neck Plant Response to December 13,1984 Order Modifying License, dated November 6,1985.

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The QA/QC activity surveillance program, which is intended to verify that quality controls have been established and maintained in the work areas, needed to be reinstituted, according to the review. More frequent performance of activity surveillances and routine participation by QA/QC I

personnel during preventive / corrective maintenance and operational surveillances were suggested. The use of the activity surveillance program is being expanded by setting target goals for the number of surveillances to be performed in particular areas. This program is being incorporated into l the tracking system for open items. Methods to improve the guidance for i

performing activity surveillances are still being assessed. Periodic trend reports are provided to management. All surveillances that result in a quality problem result in a Nonconformance Control Report (NCR). NCRs

, are trended monthly with a report to all department heads and to the Plant

Operating Review Committee (PORC).

The assessment team concluded that the development and implementation of a strong QA/QC activity surveillance program would provide a useful management tool in the evaluation of overall work performance.

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Functional Area: LICENSING ACTIVITIES -

Board Recommendations:

(A) As indicated in Sections B and D, the licensee should aggressively pursue licensing resolution in the areas of 10 CFR 50 Appendix J compliance and, (B) Operation of the post-accident sample system at power.

UPDATE:

(A) On December 23, 1985, CYAPCO submitted a letter (9) addressing the seven unresolved containment leak rate testing items which were identified in Inspection Report No. 50-213/84-13.(10) As part of the Haddam Neck Plant Integrated Safety Assessment Program (ISAP), CYAPCO is planning to provide the NRC Staff with a summary of the status of compliance with 10 CFR 50 Appendix 3 by March,1986.

(B) CYAPCO submitted a proposal to revise its Technical Specifications to allow for surveillance tes ting of normally closed, non-automatic containment isolation valves that are part of the Post-Accident Sampling System (PASS) on October 31, 1985. The proposed revision to Technical Specifications 1.8, Centainment Integrity (definition) and new Table 3.11-2, Non-automatic Containment Isolation Valves, will allow testing of normally closed isolation valves in the PASS during operation modes I,2,3, and 4 to ensure oper(abjlity. This revision was approved and issued by the Commission ll as Amendment No. 72 to Facility Operating License No. ,

DPR-61 on February 19,1986.

(9) 3. F. Opeka letter to T. E. Muev, Haddam Neck - 10CFR, Appendix 3 Compliance, dated Decembe: 73,1983.

(10) T. T. Martin letter to W. G. Counsit, inspection Report No. 50-213/84-13, dated October 17,1984.

(11) F. M. Akstulewicz, Jr. letter to J. F. Opeka, Technical Spec}fications to Permit Testing of the Post-Accident Sampling Sys tem, dated February 19,1986.

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1 al Docket No. 50-245

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i i Northeast Nuclear Energy Company 4

Millstone Unit No. I j Updated Response to SALP Report t

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Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:

(A) Evaluate specific training for first-level supervisors as a measure for improving adherence to requirements.

(B) Upgrade adherence to routine radiation protection requirements by individual workers.

UPDATE:

(A) & (B) The Nuclear Training Department acted to ensure that all station personnel were instructed on the importance of establishment, implementation, and maintenance of radiation protection procedures.

New Employee Indoctrination incorporates a section on Nuclear Engineering and Operations (NEO) Procedure familiarization, covering the main topics of each procedure. NEO 2.05, Radiation Protection and Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable, is included in the training. New employees who are potential radiation workers must take Level 1 Radiation Worker Training to receive in-depth instruction on specific radiological controls procedures. Instruction is given on the function, purpose, and use of Radiation Work Permits (RWPs) and on proper entry into and exit from radiologically controlled areas. Employees are required to pass (80% correct) a 50 question examination, of which 5-10 questions pertain specifically to radiological controls.

Employees are also required to demonstrate proper entry / exit to/from a Radiologically Controlled Area including reading comprehension, and adherence to an RWP.

General Employee Training is given annually and includes a two hour Level 3 Radiation Worker Requalification Program, to requalify employees as Radiation Workers. In the 1985 program, specific emphasis was placed on adherence to RWP requirements, including proper dress, documentation of radiation exposures, familiarity with the radiological environment, and documentation of all entrances into and exits from radiological areas.

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Functional Aren SURVEILLANCE <

Board Recommendation:

(A) Upgrade QA of critical surveillance testing such as containment integrated leak rate testing.

UPDATE:

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! (A) Millstone Unit i Engineering Department instruction 1-ENG-3.01, Primary Containment Integrated Leak Test, was issued on June 3,1985. Detailed, plant specific information for planning and execution of the Integrated Leak Rate Test (ILRT), including training and inter-department

involvement, is given. The procedure is to be reviewed and revised, if

necessary, af ter receiving comments from the other NU nuclear units when

, they conduct ILRTs.

Nuclear Engineering and Operations Procedure, NEO 2.20, Containment Leakage Rate Testing Program, was issued on December 10, 1985.

1-ENG-3.01 has recently been revised and refers to NEO 2.20 in appropriate sections. 1-ENG-3.01 is in conformance with NEO 2.20, and is more detailed in plant specific areas.

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Functional Areas FIRE PROTECTION / HOUSEKEEPING Board Recommendations:

i (A) Address the cluttered yard condition.

(B) Resolve Appendix R implementation.

UPDATE:

(A) The Radwaste Reduction Facility has been completed and was in use as of September 27, 1985. This facility will increase indoor storage capability.

In addition, the area near the Unit I transformer yard has been cleared of all stored material.

(B) As a result of a comprehensive review (1) of Millstone Unit l's position relative to Sections III.G, 3, and L of 10 CFR 50, Appendix R, new exemptions and modifications were identified. Eight new pxemption requests were subsequently filed on November 21, 1983t2) which incorporated the recommendations of the comprehensive review and the '

guidance provided by Generic Letter 85-01. The exemption requests are l presently under RC review and additional information was requested by j the NRC Staff.

Hardware modifications which are non-outage related are scheduled to be completed by August 6,1986 in accordance with 10 CFR 50.48 schedules.

Implementation of the outage related work is scheduled for the 1987 refueling outage. l l

(1) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated June 18,1984.

(2) J. F. Opeka letter to H. L. Thompson, Fire Protection, dated November 21, 1985.  :

(3) Conference Call between NUSCO and the NRC Staf f on January 27,1986.

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l l Functional Area: EMERGENCY PREPAREDNESS Board Recommendation:

(A) Evaluate measures for assuring timely completion of action items.

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l l (A) Lessons plans for emergency preparedness training have been developed t

l and were closed outimplemented in the 1985) by the NRC Region 1.(4 emergency training. This item has been (4) T. T. Martin letter to 3. F. Opeka, inspection No. 50-423/85-39, dated October 10,1985.

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Functional Areat REFUELING AND OUTAGE MANAGEMENT Board Recommendation:

(A) Improve self-assessment to identify items such as failure to follow through on commitments and design modifications.

UPDATE

(A) Millstone Unit I commitment items have been incorporated into the Unit 1 i Superintendent's assignment list, in an effort to improve tracking of l commitments. This list has high visibility and receives significant management attention in managing important projects on the unit. The list is updated approximately weekly, and is distributed to all Millstone Unit 1 -

department heads.

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Functional Area: LICENSING Board Recommendations:

(A) Improve management of IIcensing activities to avoid late responses.

(B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project status.

UPDATE:

(A) Senior NU management is routinely and aggressively involved in the management of licensing issues. Additional resources have been added to the licensing staff to improve the timeliness of responses. Despite the emphasis on schedular performance, the quality of docketed submittals cannot and will not be compromised merely to meet a deadline.

With respect to our performance in this area, we invite your attention to comments made by the Staff at a Commission briefing on ISAP on February 19,1986. The Staff stated to the Commission:

l "So, in sum, we came up with 80 topics for Millstone Unit No.1 and 70 topics for Haddam Neck as a result of our screening i

reviewing.

Shortly thereafter Northeast began submitting the topic reviews for Millstone Unit No.1, and between August 13th, 1985 and November 25th,1985, they submitted evaluations for each of the 80 topics that we identified for Millstone Unit No.1.

I would note that that is probably the fastest response that I have ever seen to that large a number of issues. But there again we have to temper that judgment with the lead time that they had from the time that we originally envisioned the concept of ISAP. So they had done a lot of legwork. But they pulled it together very f ast."

Later in the briefing, Mr. Stello commented:

"There's one other area that we probably ought to give a lot of credit to Northeast as a leader in how they go about doing their analysis. They have an enormous in-house staff, and involve the I

people in the plant, which has yet an additional benefit of doing the PRA, just the way they go about it, over and above having  ;

it done for you. And I think we ought to give them some credit for the way they go about it, because I do think they do a very good job."

(B) NU's licensing group has been coordinating activities with the Integrated Safety Assessment Program (ISAP) Project Directorate in order to implement the program. Activities have included timely submittals of the Millstone Unit No.1 Probabilistig Safety Study, deterministic reviews of all Millstone Unit No.1 ISAP topics and probabilistic risk oriented project evaluations, as well as several meetings on various aspects of the ISAP.

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Meetings on the Millstone Unit No.1 Provisional to Full Term Operating l License conver$ were held with the ACRS during November and December 1985' to facilitate NRC/ACRS approval of the license conversion. License conversion activities are ongoing. Our view is that we have been responsive to this recommendation, and we welcome any additional feedback from the NRR Staff.

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, , s a Docket No. 50-336 Bf1979 Attachment 3 i

Northeast Nuclear Energy Company Millstone Unit No. 2 l

Updated Response to SALP Report l

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Functional Area PLANT OPERATIONS Board Recommendation:

) (A) Upgrade ' controls over computer codes, particularly of associated

qualification certifications.

UPDATE:

I (A) Phase II of the effort to upgrade the control of computer sof tware used by NUSCO for Category I engineering analysis is continuing. A Joint User Task Force was formed to review and upgrade existing procedures on quality related computer programs. The need for additional procedures and controls was identified. The required procedures have been draf ted, and 1

are in the review process.

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Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:

(A) Continue recent emphasis on improving radioactive material transportation controls.

(B) Assure better adherence to radiatior protection procedures by workers.

UPDATE:

(A) The R adioactive Materials Handling Department was reorganized to facilita*e better supervision and control of its activities. The Health l Physics Supervisor is now responsible for the operation of this group.

l A specific packaging procedure for LSA boxes, RW 6012/20612/36012,

" Packing Non-Compactible LSA Containers," was developed and ef fective as of August 1,1985.

(B) The Nuclear Training Department acted to ensure that all station personnel j

were instructed on the importance of establishment, implementation, and maintenance of radiation protection procedures.

! New Employee Indoctrination incorporates a section on Nuclear l Engineering and Operations (NEO) Procedure f amiliarization, covering the i main topics of each procedure. NEO 2.05, Radiation Protection and l Maintaining Occupational Radiation Exposures As Low As Reasonably l Achievable, is included in the training. New employees who are potential l radiation workers must take Level 1 Radiation Worker Training to receive I

in-depth instruction on specific radiological controls procedures.

l Instruction is given on the function, purpose, and use of Radiation Work l

Permits (RWPs) and on proper entry into and exit from radiologically contro!!ed areas. Employees are required to pass (80% correct) a 50 question examination, of which 5-10 questions pertain specifical:y to radiological controls. Employees are also required to demonstrate proper entry / exit to/from a Radiologically Controlled Area including reading comprehension, and adherence to an RWP.

General Employee Training is given annually and includes a two hour Level 3 Radiation Worker Requalification Program, to requalify employees as Radiation Workers. In the 1985 program, specific emphasis was placed on adherence to RWP requirements, including proper dress, documentation of radiation exposures, famillarity with the radiological environment, and documentation of all entrances into and exits from radiological areas.

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Functional Areat FIRE PROTECTION / HOUSEKEEPING l

i Board Recommendations:

I (A) Address the cluttered yard condition. Upgrade housekeeping in areas noted

] as candidates for improvement.

(B) Resolve Appendix R implementation.

j UPDATE:

' (A) As mentioned in the Millstone Unit I response to Fire Protection / Housekeeping recommendations, the Radwaste Reduction i Facility has been completed. Deficiencies in other identified areas have [

l been corrected. The enclosure building and equipment access hatch area have been cleaned. The area of the auxiliary building refueling water I storage tank pipe chase has been cleaned, cofferdams have been built to

! prevent water from running down the wall, and the wall has been repainted.

The safeguards pump rooms have been cleaned and the wall in the "A" room i; has been repaired.

(B) As a result of a comprehensive (l) review of Millstone Unit 2's position .

relative to Sections III.G, 3, and L of 10 CFR 50, Appendix R, new

exemptions and modifications were identified. Ten new exemption 3 requests were subsequently drafted and are currently undergoing internal

} review. The new exemption requests are scheduled to be submitted to the j NRC in April, 1986. The exemptions have incorporated the

! recommendations of the comprehensive review and the guidance provided by Generic Latter 85-01.

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, Hardware mcdifications which are non-outage related are planned to be l completed in accordance with 10 CFR 50.48 schedules. Implementation of i the outage related work will be scheduled following receipt of the NRC SEtt.

i i (1) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated

June 18,1984.

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Functional Area: EMERGENCY PREPAREDNESS Board Recommendation:

(A) Evaluate measures for assuring timely completion of action items.

UPDATE:

(A) Lessons plans for emergency preparedness training have been developed and were implemented in the 1985 emergency training. This item has been closed out by the NRC Region 1.(2)

(2) T. T. Martin letter to 3. F. Opeka, inspection No. 50-423/35-39, dated I October 10,1985.

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r Functional Area: LICENSING Board Recommendations:

(A) Improve management of licensing activities to avoid late responses.

(B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project status.

UPDATE:

(A) Senior NU management is routinely and aggressively involved in the management of licensing issues. Additional resources have been added to the licensing staff to improve the timeliness of responses. Despite the emphasis on schedula performance, the quality of docketed submittals cannot and will not be compromised merely to meet a deadline.

(B) Our perspective is that the Millstone Unit No. 2 licensing enginaer and the NRC's Project Manager for Millstone Unit No. 2 enjoy a very good woridng relationship. There is virtually daily communication between the NRC and NU in this regard with " face-to-face" update meetings at least quarterly !n order to maintain clear communications and agreements on outstanding information requests and other licensing issues. Currently, the NRC and NU are working together to identify items to be worked on during the next year and a priority ranking for each. The mechanics are in place to ensure that timely and responsive input is provided to the NRC.

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Docket No. 50-336 -

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Attachment 4 Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Inputs to S ALP Evaluation Process l

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i March,1986 i

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The following items provide a summary description of various meetings, letters, or other transactions which we believe are relevant to the conduct of the SALP process for our facilities. Only a summary of each of the pertinent elements is provided below. Further elaboration can be provided as desired.

o In April,1985 in order to facilitate an orderly transfer of a senior management position, our current and past Senior Vice President of Nuclear Engineering and Operations conducted a series of meetings with members of the Staff over a two day period.

o In May,1985 we met with the Staff to discuss IGSCC inspection plans and results for Millstone Unit No.1. Additionally, we kept the Staff informed via letters and meetings, of the status of the inspection results during the outage.

o One of the elements of our corporate strategy regarding steam generators at Millstone Unit No. 2 concerns a chemical cleaning process used during the 1985 refueling outage. In May,1985 we met with the Staf f to discuss

the results of this cleaning process. Additionally, information concerning i

this process was made available to the industry via available electronic network systems and owners groups.

l o In June, 1985 we hosted a meeting with the Region I Regional l

Administrator, members of the Staff, and NRC consultants on the subject of the application of PRA techniques at Northeast Utilities. Discussion topics included technical details of our PRA techniques and the ISAP program.

o in August,1985 we entertained a one-week visit by staf f personnel from the License Qualification Branch, Division of Human Factors Safety and i provided information on our Production Maintenance Management System.

The resulting Site Survey Report noted that we are " committed to acting quickly in solving problems; and to ensuring that extensive supervisory -

) involvement is present in every phase of each maintenance activity."

o in August,1985, at the request of the Director of the Office of Inspection and Enforcement (IE), we hosted a meeting with members of the IE Staff to discuss the Pilot Outage inspection Program. We discussed our experiences on work recently performed for the Haddam Neck Plant which was relevant to the formulation of the NRC Pilot Outage inspection Program, o in September,1985 we entertained a visit by the Brookhaven Reliability Research Team and Mr. Carl Johnson of the NRC Division of Risk Analysis and Operations to gather information on reliability techniques which we have found to be effective at Millstone Unit No.1. This was in support of NRC Technical Specification improvement Proicct and Maintenance and Surveillance Program. The resulting OSRR Project Team report noted that reliability activities at NU " appear to have strong management support and

ee v NU has a formalized reliability p6cgram that is conducted by a dedicated group of individuals."

o- In September,1985 we provided comprehensive long term maintenance records as input for the NRC Operationai Safety Reliability Research Program.

o During 1985, as an aid in personnel transitions within the NRC, we entertained visits by the new project manager for the Haddam Neck Plant and the new Branch Chief of Operating Reactors Branch #5 for discussion of licensing issues concerning Millstone Unit No. I and the Haddam Neck Plant. .

o In 1985 we were active participants in the AIF Committee on Reactor Licensing and Safety in both the steering group concerning the source term issue and the subcommittee on Technical Specifications for input to the NRC Technical Specification Task Force.

o NU has been an active member of the Industry Effort to resolve the USI-A-44, Station Blackout, issue. In this regard, the Industry, via the Nuclear Utility Management and Resource Committee (NUMARC) and the Nuclear titility Group on Station Blackout, has been working with the Staff towards a mutually agreeable resolution to this issue.

o During 1985, as chairman of the NUMARC working group on the issue of Engineering Expertise on Shif t, executive NU management continued to work with NRC Senior Staff management and the Commission toward development of a mutually agreeable and workable policy statement.

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