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SALP Repts 50-245/86-99 & 50-336/86-99 for June 1986 - Dec 1987
	ML20148M757
Person / Time
Site:	Millstone
Issue date:	02/25/1988
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20148M755	List: ML20148M757;
References
	50-245-86-99, 50-336-86-99, NUDOCS 8804060147
	Download: ML20148M757 (97)
	v • d • e

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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INSPECTION REPORT NUMBERS 50-245/86-99 and 50-336/86-99

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MILLSTONE NUCLEAR STATION, UNITS I & II

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ASSESSMENT PERIOD: June 1, 1986 to December 31, 1987

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BOARD MEETING DATE:

February 25, 1988

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8804060147 880329

{DR

ADOCKOSOOg2j5

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TABLE OF CONTENTS

PAGE

I.

Introduction..............................

1

..........................

A.

Purpose and Overview..............

1

........ ....................

B.

SALP Board Members..............................................

1

II.

Criteria.....................

3

.... ... . ............................

III. Summary of Results. ... .............................................

4

A.

Overall Summary - Unit

1........................................

4

B.

Background - Unit

1............

.

5

.... . .

...................

1.

Licensee Activities - Unit

1...............................

5

2.

Inspection Activities - Unit

1.......

.....................

6

C.

Facility Performance Analysis Summary - Unit 1...

..............

6

0.

Overall Summary - Unit

2.......

.. ............. ... ...........

7

E.

Background - Unit 2.................

................. .........

8

1.

Licensee Actie' ties - Unit

2......

........................

8

2.

Inspection Ac uvities - Unit 2.............................

9

F.

Facili ty Performance Analysi s Summa ry - Uni t 2. . . . . . . . . . . . . . . . . .

9

IV.

Performance Analysis..... .......... .. .. ..........................

10

A.

Plant Operations................................................

10

1.

Plant Operations - Unit

1.......

....... ..................

10

2.

Plant Operations - Unit 2. .....

14

..

... ... . . .

.

..

B.

Radiological Controls - Units 1 and

2.....

... .................

17

C.

Maintenance.......................

22

.............................

1.

Maintenance - Unit

1....

.... .............. .......... ...

22

2.

Maintenance - Unit 2................

.....

24

.. ............

D.

Surveillance.

26

.................... .. ..........................

1.

Surveillance - Unit

1......................................

27

2.

Surveillance - Unit 2. ..... ................. ............

30

E.

Emergency Preparedness - Units 1 and 2. ........................

33

F.

Security and Safeguards - Units 1 and 2......................

..

35

G.

Outage Management.......

38

................ ..............

......

1.

Outage Management - Unit 1.

38

..

.......... ....

. ...

2.

Outage Management - Unit 2..

40

... ......... ............. .

H.

Assurance of Quality - Units 1 and 2........

........ .. ....

42

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Engineering Support.....

44

..

... ... ...

........ .... ..

1.

Engineering Support - Unit 1.

45

...

.......

... .. ... .

2.

Engineering Support - Unit 2. .

48

..

.. . .. .. ........ ..

J.

Training Effectiveness - Units 1 and

2..

51

......... ............

K.

Licensing Activities.

55

.

...

.

.. ..

.

1.

Licensing Activities - Unit

1...

55

..

. ...... .

.. ...

2.

Licensing Activities - Unit 2....

... ... . ..

58

......

...

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Table of Contents

1

PAGE

V.

Supporting Data and Summaries........................................

62

A.

Supporting Data and Summaries - Unit

1.......

..................

62

1.

Allegation Review - Unit

1.................................

62

2.

Escalated Enforcement Actions - Unit

1.....................

62

3.

Management Conferences - Unit 1............................

62

4.

Licensee Event Reports - Unit 1..........

....-............

62

5.

Licensing Activities - Unit

1.......

..... . ....... ......

63

B.

Supporting Data and Summaries - Unit 2..

.......................

64

1.

Allegation Review - Unit 2. ........................ ......

64

2.

Escalated Enforcement Actions - Unit 2..

..... ...

65

.......

3.

Management Conferences - Unit 2.......................

....

65

4.

Licensee Event Reports - Unit

2.........

............ .....

65

5.

Licensing Activities - Unit

2....

...... ....... ........ .

66

TABLES

Table 1 - Inspection Hours Summary

Table 1A - Synopsis of Inspection Reports

Table 2 - Enforcement Summary

Table 2A - Synopsis of Violations for Units 1 and 2

Table 3 - Summary of Licensee Event Reports (LERs)

Table 3A - Synopsis of LERs for Unit 1

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Table 3B - Synopsis of LERs for Unit 2

Table 3C - Synopsis of Security Event Reports (SERs)

Table 4 - Summary of Forced Outages, Unplanned Trips, and Power Reductions

Table 4A - Synopsis of Forced Outages, Unplanned Trips, and Power Reductions for

Unit 1

Table 4B - Synopsis of Forced Outages, Unplanned Trips, and Power Reductions for

Unit 2

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I.

INTRODUCTION

A.

Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to periodically collect observations and. data

and evaluate licensee safety performance.

SALP supplements the normal

regulatory processes used to ensure compliance with NRC rules and regu-

lations.

It is intended to be diagnostic enough to provide a rational

basis for allocating NRC resources and to provide meaningful input to

licensee management on promoting quality and safety of plant operation.

The NRC SALP Board, composed of the members listed below, met on February

25, 1988 to' assess licensee petformance in accordance with the guidance

in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Perform-

ance".

A summary of the guidance and evaluation criteria is provided

in Section II of this report.

This SALP assesses the safety performance of the Hillstone Nuclear Power

Station, Units 1 and 2 fenm June 1, 1986 through December 31, 1987, a

19 month assessment period. The SALP is organized, except for areas

completely common to both units, into functional areas broken down into

Unit 1 and Unit 2 subsections.

B.

SALP Board Members

W. Kane, Director, Division of Reactor Projects (DRP), Chairman

W. Johnston, Director, Division af Reactor Safety (DRS)*

F. Congel, Director, Division of Reactor Safety and Safeguards (ORSS)

S. Collins, Deputy Director, ORP'

J. Richardson, Deputy Director, DRSS*

L. Bettenhausen, Chief, Projects Branch No. 1, DRP

R. Bellamy, Chief, Emergency Preparedness and Radiological Protection

Branch, DRSS*

J. Durr, Chief, Engineering Branch, DRS

E. McCabe, Chief, Reactor Projects Section No.18, ORP

J. Stolz, Director, Project Directorate I-4, NRR

M. Boyle, Unit 1 Project Manager, POI-4, NRR

0. Jaffe, Unit 2 Project Manager, POI-4, NRR

W. Raymond, Millstone Site Senior Resident Inspector, DRP

Part time attendees.

.

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Other Attendees

R. Bailey, Physical Security Inspector, DRSS"

S. Chaudhary, Senior Reactor Engineer, DRS*

R. Gallo, Chief, Operations Branch, DRS*

J. Jang, Senior Radiation Specialists, DRSS*

L. Kolonauski, Unit 1 Resident Inspector, DRP

J. Kottan, Laboratory Specialist, DRSS*

W. Kushner, Sa'eguards Scientist, DRSS*

W. Lazarus, Chief, Energency Preparedness Section, DRSS*

M. Shanbaky, Chief, Facility Radiation Protection Section, DRSS*

W. Thomas, Radiation Specialist, DRSS*

A. Weadock, Radiation Specialist, DRSS*

Part time attendees.

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II. CRITERIA

Licensee performance is assessed in selected functional areas.

Each func-

tional area represents aspects significant to nuclear safety and the environ-

ment, and is a normal programmatic area.

The following evaluation criteria

were used as appropriate.

1.

Management involvement and control in assuring quality.

2.

Approach to resolution of technical issues from a safety standpoint.

3.

Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Reporting and analysis of reportable events.

6.

Staffing (including management).

7.

Training effectiveness and qualification.

Based upon the SALP Board assessment, each functional area is clasM fied into

one of three performance categories.

These are:

Category 1.

Reduced NRC attention may be appropriate.

Licensee management

attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used so that a high level of

performance with respect to operational safety is being achieved.

Category 2.

NRC attention should be maintained at normal levels.

Licensee

management attention and involvement are evident and concerned with nuclear

safety; licensee resources are adequate and reasonable effective such that

satisfactory operational safety performance is being achieved.

Category 3.

Both NRC and licensee attention should be increased.

Licensee

management attention or involvement is acceptable and considers nuclear safety,

but weaknesses are evident; licensee resources appear strained or not effec-

tively used such that minimally satisfactory performance with respect to

operational safety is being achieved.

The SALP Board also considered categorizing the performance trend. A perform-

a.;ce trend is assigned only if the SALP Board concludes that continuation of

a trend may change the performance category.

Performance trend categories

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are:

Improving:

Licensee performance was determined to be improving near the close

of the assessment period.

Declining:

Licensee performance was determined to be declining near the close

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of the assessment period.

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III. SUMMARY OF RESULTS

A.

Overall Summary - Unit 1

Performance was consistently good.

Safe and conservative plant operation

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was evident. Operators responded well to plant trips. A high level of

safety performance was noted in Plant Operations, Maintenance, Surveil-

lance, Emergency Preparedness, Outage Management, and Training Effective-

ness.

There was a strong commitment to safety at all levels.

Significant improvements were noted in Radiological Controls, particu-

,

larly in the radwaste and transportation programs.

Performance in this

area has increased from Category 3 to Category 2 since the last SALP.

Performance in Security decreased to Category 2 during the SALP period.

The NRC found that guards were not identifying de" eiencies in meeting

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basic objectives, and that program oversight needed improvement.

The Licensing Activities performance rating also has decreased from

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Category 1 to Category 2.

Repetitive late submittals without, in some

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cases, arranging revised submittal dates with the NRC staff were the main

-

reascn for the lower rating.

Licensing Activities were otherwise found

to be well-managed and capably performed.

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Engineering support groups displayed good initiative in some issues and

were generally effective.

On the other hand, weaknesses in environmental

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qualification, slow response to identification of short pump foundation

a

bolts, and recurring main condenser tube leaks showed that significant

,

engineering support improvements can be made.

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The licensee was successful in improving performance on identified prob-

lems. Areas given management attention showed marked improvement. As

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the Security area assessment indicates, however, better self-identifica-

,

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tion of performance problems is needed to achieve high performance across-

the-board.

The prior SALP rated five areas as Category 1, three areas as Category

?

2, and one area as Category 3.

This SALP rated six areas as Category

.

I and five as Category 2.

It is particularly commendable that the ex-

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tensive corporate and site management changes made during the past

several years have occurred without impacting overall unit safety per-

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formance, which reraains high.

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B.

Background

1.

Licensee Activities

On June 1, 1986, the SALP period began. Millstone 1 was operating

at full power. Normal full power operation, with short power re-

ductions for corrective maintenance (e.g. , condenser tube and steam

leaks), lasted until November 30, when the unit tripped due to a

main transformer ground.

The transformer was replaced and the unit

was returned to full power af ter a 15-day outage.

Normal full power operation continued until March 22, 1987, when

the unit scrammed from 50% power due to closure of the Main Steam

Isolation Valves (MSIVs).

Low reactor pressure had resulted when

reactor pressure control was shif ted from the Electric Pressure

Regulator (EPR) to the Mechanical Pressure Regulator (MPR); the re-

sultant primary containment isolation signal caused the MSIVs to

close.

This trip was attributed to inadequate operator training

in shifting from the EPR to the MPR.

Full power operation was resumed until June 4, when a failing Steam

Jet Air Ejector necessitated a power drop to 40% to restore Main

Condenser vacuum.

The unit was then returned to full power until

shutdown began on June 5 for a planned 70-day refueling and main-

tenance outage.

In addition to the Cycle 12 reload, outage work

included replacement of the jet pump instrumentation nozzles, the

process computer, anc the motor-operators for certain safety-related

valves.

During the Cycle 12 startup on August 14, the unit tripped due to

Intermediate Range Monitor Hi-Hi flux created by operator-initiated

excessive control rod withdrawal.

A subsequent startup began on

August 15.

Full power was reached on August 20.

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A reactor trip from 100% power occurred on August 26 due to person-

nel error during surveillance of the Average Power Range Monitors

(APRMs).

Another trip from full power occurred September 3 due to

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low pressure in the scram pilot air header (equipment failure).

Full power was again achieved and continued until November 14, when

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the unit was taken to cold shutdown for a 64-hour outage to inves-

tigate and repair increasing unidentified drywell leakage (a valve

packing leak).

The unit was returned to full power for the rest

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of the assessment period.

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2.

Inspection Activities

The NRC resident and region-based inspections for the 19-month SALP

period totaled 2671 hours0.0309 days 0.742 hours 0.00442 weeks 0.00102 months , a rate of 1687 hours0.0195 days 0.469 hours 0.00279 weeks 6.419035e-4 months per year.

There were five special inspections during the SALP period to:

(1) review 'icensee resporse to IE Bulletin 80-11, Masonry Wall Oe-

sign; (2) review check vaive testing; (3) observe two annual emer-

gency exercises, and (4) review compliance with 10 CFR 50 Appendix

R fire protection requirements.

An inspection summary (Table 1A)

is attached to this report.

The NRC senior resident inspector for Millstone 1 and 2 was reas-

signed in September 1987. A new senior resident inspector was as-

signed to all three Millstone units in July 1987.

The Millstone

1 and 2 resident inspector was reassigned in September 1987. A new

resident inspector for Unit I reported in November 1987.

C.

Facility Performance Analysis Summary - Unit 1

Last Period

This period

(3/1/85 -

(6/1/86 -

Recent

Functional Area

5/31/86)

12/31/87)

Trend

A.

Plant Operations

1

--

B.

Radiological Controls

3

2

--

C.

Maintenance

2

1

--

.

D.

Surveillance

1

--

E.

Emergency Preparedness

1

--

F.

Security and Safeguards

1

2

--

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G.

Outage Management

Nore#

1

--

H.

Assurance of Quality

2

--

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Engineering Support

Nore#

2

--

J.

Training Effectiveness

2

1

--

K.

Licensing Activities

1

2

--

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Not assessed as o separate area in the last SALF

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Overall Summary - Unit 2

Facility performance was good.

Safe and conservative plant operation

was evident. Operators responded well to plant trips.

A high levc1 of

safety performance was noted in Maintenance, Emergency Preparedness,

Outage Management, and Training Effectiveness.

There was a strong com-

mitment to safety at all levels.

Significant improvements were noted in Radiological Controls, particu-

larly in the radwaste and transportation programs.

Performance in this

area has increased from Category 3 to Category 2 since the last SALP.

Performance in Security decreased to Category 2 during the SALP period.

The NRC found that guards were not identifying deficiencies in meeting

basic objectives, and that program oversight needed improvement.

Surveillance performance decreased to a Category 2 rating primarily be-

cause, af ter a refueling outage, the plant was restarted without correct-

ing steam generator tube flaws needing repair.

A subsequent outage was

required for corrective maintenance.

Licensee management responded

positively and conservatively to this operational safety concern.

The Licensing Activities performance rating also has decreased from Cate-

gory 1 to Category 2.

Repetitive late submittals without, in some cases,

arranging revised submittal dates with the NRC staff were the main reason.

Licensing Activities were otherwise found to be well-managed and capably

performed.

Engineering support groups displayed gooc initiative in some issues and

were generally effective. A need for improvement was, howevu, evident

from deficiencies in the Fire Protection Program, from weaknesses in

Environmental Qualification, and from two reactor trips related to design

deficiencies.

The licensee was successful in improving performance on identified prob-

lems. Areas given management attention showed marked improvement.

As

the Security area assessment indicates, however, better self-identifica-

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tion of performance problems is needed to achieve a high level of per-

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formance across-the-board.

The prior SALP rated seven areas as Cstegory 1, two areas as Category

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2, and one area as Category 3.

This SALP rated four areas as Category

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1 and seven as Category 2.

The lower ratings do not represent a signi-

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ficant safety degradation.

Therefore, the extensive corporate and site

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management changes made during the past several years have occurred

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without significantly impacting overall unit safety performance.

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E.

Background

1.

Licensee Activities

On June 1,1986, Millstone 2 tripped from full power.

The trip was

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due to operator error during transfer from the Reserve Station Ser-

vice Transformer (RRST) to the Normal Station Service Transfermer

(NSST).

That caused the loss of a 6.9 KV bus and subsequent under-

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speed of a reactor coolant pump.

Power operation was resumed and continued until increasing Reactor

,

Coolant System (RCS) leakage necessitated a power reductien for RCS

'

inspection within containment.

On August 12, during preparations

to reduce power, the unit tripped from full power due to low steam

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generator (SG) level caused by the loss of an :uxiliary oil pump

,

forthe-associatedsteamgeneratorfeedpump(SGFf). A.four day

maintenance outage was then conducte.

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Full power operation was resumed until September 3, when the unit

tripped due to low SG 1evel caused by the loss of both SGFPs due

to the failure of the reheater drain pump discharge header flow con-

trol vaive.

Full power operation resumed on September 5.

Tf.e unit

entered a two-week coastdown period prior to the planned refueling

outage, which began on September 20.

On December 23, during power ascerCon testing for Cycle 8, the unit

tripped from 50*4 power when a transformer alignment problem caused

a SGFP underspeed.

The unit was returned to power.

It next tripped,

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from 100*4 power, on January 2,1987 cue to low SG 1evel caused by

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the failure of a feedwater regulat^ ng valve (FRV) solenoid.

The

unit was returned to full power on January 5.

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Full power opeiation continued until January 29, when there was a

normal shutdown to correct primary to secondary leakag .

The outage

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was extended to repair other SG tube defects not prwiously cor-

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rected because o' faulty Eddy Current Testing (ECT) review. The

unit then operated at full power f tom February 16 until tripping

on April 16 due to a main generator trip from an endetermined cause.

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Normal full power operation was resumed until July 23, when the unit

tripped from 80*. power because a pressurizer spray valve malfunction

e, e d low SG 1evel.

The unit was returned to and remained at full

.c unti'

, September 2, FRV failure (valve plug and stem sepa-

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'aw SG level and a reactor trip.

ened to full po m until November 11, when the same

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The unit was returned to and remained at full power until, on De-

cember 6, coastdown for a planned refuelinn outage began. The unit

was brought to cold shutdown on December .'0,

1987.

2.

Inspection Activities

The NRC resident and region-based inspections for the 19-month SALP

period totaled 2595 hours0.03 days 0.721 hours 0.00429 weeks 9.873975e-4 months , a rate of 1639 hours0.019 days 0.455 hours 0.00271 weeks 6.236395e-4 months per year.

There were three special inspections during the assessment period

to: (1) observe two annual emergency preparedness exercises; and

(2) review licensee response to IE Bulletin 80-11, Masonry Wall Oe-

sign. An inspection summary (Table 1A) is attached to this report.

The NRC senior resident inspector for Millstone 1 and 2 was reas-

l

signed in September 1987. A new senior resident insi

tor, assigned

to all three Millstone units, reported in July 1987.

..s Millstone

1 and 2 resident inspector was reassigned in September 1987.

A new

resident inspector for Unit 2 reported in January 1988.

F.

Facility Performance Analysis Summary - Unit 2

Last Period

This period

(3/1/85 -

(6/1/86 -

Recent

Functional Area

5/31/831

12/31/87)

Trend

A.

Plant Operations

1

2

--

B.

Radiological Controls

3

2

--

C.

Maintenance

1

--

D.

Surveillance

1

2

--

E.

Emergency Preparedness

1

--

F.

Security and Safeguards

1

2

--

G.

Outage Management

1

--

H.

Assurance of Quality

2

--

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Engineering Support

None#

2

--

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Training Effectiveness

2

1

--

K.

Licensing Activities

1

2

--

Not assessed as a separate area in the last SALP

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IV.

PERFORMANCE ANALYSIS

A.

Plant Operations

General and Common Aspects

This functional area includes overall piint operations, housekeeping,

fire protection, staff performance, review committee activities, event

reporting and corrective actions.

The licensee's station and offsite review committees functioned as re-

quired by the plant technical specifications, and in conformance with

the applicable procedure.

The licensee regards committee membership to

be a serious commitment, as was evident by the attendance record.

The

licensee's commitment to conservatism and safety was evident in committee

review of complete modification packages in addition to the saftty

evaluation reviews required by the technical specifications.

The com-

mittees displayed a probing, questioning approach in resolution of safety

and technical issues.

Licensee Event Reports (LERs)

For both units, LERs were thorough and well written.

They adequately

described events, equipment, failures and corrective actions.

Root causes were clearly identified.

Updated LERs highlighted new information. NRC review of LERs identified

no recurring problems and no inattentiveness to problem identification

,

and correction.

Event safety assessments improved significantly during

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the recent assessment period. One case (Unit 2 LER 86-10) of not updat-

ing an LER within the planned six months was identified as an exception

to normal practice.

Overall, LER quality was high.

1.

Plant Conm tions - Unit 1 (1019 hours0.0118 days 0.283 hours 0.00168 weeks 3.877295e-4 months , 38*;)

The previous SALP rated this area as Category 1.

Sipificant

strengths noted were response to abnormal conditions (Hurricane

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Gloria), management oversight of operations, ar.J @ rating staff

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stability and professionalism.

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Operator alertness was routinely observed during day and back shifts.

Overall, operating shift functioning was evaluated as smooth and

professional.

Control room distractions were neithe.' allowed nor

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observed.

Activities were conducted carefully and with sufficient

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formality.

Shift turnovers were consistently thorough and effective.

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Operators were strong proponents of control room formality and ac-

tively ensured a professional atmosphere was maintained. Operators'

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attitudes were excellent during operations and outages.

Bri e f u.g s

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'or tests and infrequent evolutions, especially during the outage

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period. were detailed and involved frequent interaction among team

.r embe r s .

Frequent observance of evolutions showed that written

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procedures were routinely followed. Administrative support of plant

operations was effective, with logs and records found to be gener-

ally discrepancy free.

Two reactor scrams occurred as a result of operator performance

problems. One of these was a result of continuous withdrawal of

a high worth control rod during reactor startup.

Inadequate proce-

dural addressal of the rod worth condition contributed to this event.

The other such scram was due to psoblems with the transfer of tur-

bine pressure control between the mechanical pressure regulator

(MPR) and the electrical pressure regulator (EPR).

[Thislatter

scram is also evaluated in Section IV.J, Training Effectiveness.]

The licensee took appropriate action to clarify operating procedures

and to provide additional operator training on the EPR/MPR. Appro-

t

priate corrective actions were t iro taken to instruct operators on

the caution needed when withdrawing control rods in high worth re-

gions on new cores. Operator responses involving scrams were

otherwise good.

Management attention to operations and active involvement in over-

sight was evident in frequent plant superintendent control room and

plant tours.

Routine NRC inspection also consistently noted strong

management involvement in response to plant trips and other problems.

Monthly detailed plant material and housekeeping walkdowns generated

departmental actfon lists which were actively discussed at Plant

Operations Review Committee meetings.

'.isted items were corrected.

Management commitment to operator training was demonstrated by a

successful performance record in operator licensing. As noted in

Section IV.J. Training Effectiveness,16 of 18 operator license

candidates passed the NRC examinations and received licenses.

There was good communications between operations, upper management,

and other plant groups.

The licensee demonstrated a strong safety

orientation in problem resolution and a conservative approach to

plant operations.

Professionalism was evident at all levels.

Performance of the Plant Operations Review Committee (PORC) was a

major strength.

PORC members routinely exhibited probing and ques-

tioning attitudes.

Extensive discussions were ased to focut atten-

tion .a the safety implications of design changes and evolutions.

Active interplay among members contributed to a team approach to

making informed and correct decisions.

Special presentations were

j

highly effective in ensuring f: M understanding of technical issues.

PORC routinely exhibited a conservative and safety-oriented approar.h

to plant operation.

Excellent PCRC performance was especiA ly

cvident during the outage.

_ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

.

12

.

Overall, operating procedures were good.

No major procedure inade-

,

quacies were found.

Personnel routinely followed procedures and

'

properly identified and proposed appropriate changes.

The periodic

procedure review program ensursd that improvements, clarifications

and simplifications were implemented.

This period saw a marked

emphasis on implementation of "human factors" type procedure im-

provements.

A fire protection team assessed compliance with 10 CFR 50 Aspendix

R requirements with respect to the ability to safely shut down in

the event of a fire. Aggressive attention by corporate and site

management to fire protection issues was evident, with priority

given to problems requiring hardware fixes.

Several plant modificaticns were completed to comply with Appendix

R Sec tion III.G separation requirements. The fire hazard analysis

was thorough, detailed and technically adequate.

The licensee had

redundant means of achieving safe shutdown in the event of a fire.

Also, the licensee had developed adequate procedures, including

detailed repair procedures, and demonstrated that the procedures

would work.

Good planning and training were evident with respect

to the procedures.

The NRC concluded that the licensee's fire pro-

tection program was good. Major contributing factors were the rap-

port maintained by the fire protection staff and management and the

increased awareness of plant personnel to fire protection concerns.

Inspection of radiological housekeeping identified defielent control

of issued respirators, of used protective clothing, and of con-

taminated material bags.

Later observation found much improvement.

Overall, the NRC concluded that the licensee maintained plant ccm-

ponents in good condition and that housekaeping was satisfactory.

The three violations for this area involved a failure to update

technical specification surveillance requirements and snuhber tables,

and a failure to make a 10 CFR 50.72 report of multiple ADS valve

l

failures. Another violation, not cited because it lacked safety

i

significance, was for f ailure to update the technical specificatior.s

following modifications made in 1987 to change the low pressure ECCS

actuation logic.

The failure to make the report was still under

NRC and licensee review at the end of the SALP period.

Several occurrences during the assessment period, as demonstrated

by the events involving reactor scrams (LERs 87-07 and 87-34) snd

standby gas treatment system initiations (LER 87-05), suggested a

need to assure greater attention to detail in plant operations and

j

to ensure lessons are learned from past deficiencies.

_

.-. _ _ _ _

_

_ _ . _

_

__

__ _ .

.-

.

13

Overall, the licensee demonstrated continued excellent performance

in plant operations, with strong management involvement and over-

sight, good performance in operator licensing, clear management

support for training, and a successful Appendix R effort.

Plant

housekeeping, operator professionalism, and safety perspective in

problem resolution remained notable strengths.

However, the events

indicating a need for improved attention to detail and a better

lessons learned function also indicate that attention is warranted

to assure decreased performance does act cccur

Conclusion

Category 1.

Board Recommendations

None.

.

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14

i

2.

Plant Operations - Unit 2 (1065 hours0.0123 days 0.296 hours 0.00176 weeks 4.052325e-4 months , 40%)

,

The previous SALP rated this area as Category 1.

Strengths included

plant management interfaces with operating personnel and operator

professionalism.

Operator alertness was routinely observed during day and backshift

inspections. Operating shifts presented an efficient and profes-

sional attitude in the control room.

The unit had a dress code,

instituted to reflect this attitude.

Easiness was conducted in a

manner that clearly showed that the control room is not a gathering

place.

The operations department effectively limited personnel in

the control room.

Nine unplanned trips from power occurred; the overall trip rate was

about six per year. Operator response to all trips was satisfactory.

One of the trips resulted from operator error during breaker switch-

ing. Appropriate operator retraining was conducted.

'

Overall, operating procedures were good.

No major procedure inade-

quacies were found.

Operators followed procedures and proposed

appropriate changes when discrepancies were identified.

Good

operator knowledge of and regard for procedural requirements and

administrative controls was evident.

Periodic procedure reviews

effectively ensured that improvements were imp'.emented.

Plant management was observed to be in the plant frequently, and

,

!

to be discussing activities with the operating staff.

Thorough

knowledge of plant conditions was routinely exnibited by plant man-

'

agement during daily management meetings and during discussions with

NRC inspectors.

Routine inspectior, consistently showed plant man-

agement attention to operations and effective daily involvement to

coordinate operating activities and resolve problems.

Also, site

!

and corporate management attention to operations and active over-

sight of operating activities was evident in plant visits and plant

tours,

i

,

There was good communications between operations, management, and

i

other plant groups. Management involvement following plant trips

l

and events was evident during meetings and discussions with the

inspectors. A strong safety approach was taken in the resolution

of problems.

There was a generally conservative approach to plant

operations.

Professionalism was generally evident at all levels.

.

i

l

Plant Operations Review Committee (PORC) members exhibited a probing,

questioning approach to technical issues, and discussions focused

on the safety implications of events, design changes, and evolutions.

i

Good interactive discussions were consistently observed and special

!

- _ __ _ .

. _ - - -

- - . .

- - -

- _ - , - . -

. - _ ,

, - - - -

,- - -

. .

_

.

15

presentations were effectively used to fully evaluate technical is-

sues.

Excellent PORC performance wcs evident during outages and

after events or transients.

The POEC function was highly effective.

In April 1987, a pilot program for operating shift rotation was put

into effect.

The pregram reduces the shift changes over a twelve

week cycle, provides additional oays off around weekends, and pro-

vides longer continuous periods of off time.

Because it also pro-

vides 12-nour shifts on two consecutive days, specific back shift

inspections were made to observe plant operators on 12-hour shifts.

No problems were observed.

This program appears to be accepted by

operators and management as a markedly improved shift rotation.

Appendix R inspection found fire protection actions generally ac-

ceptable.

There were two violations, one for a missing fire damper

and the second for insufficient separation between the auxiliary

feedwater heaters and their isolation valves.

Also, fire coating

material was found unacceptable (LER 87-10), additional compensatory

measures were taken.

The licensee has an adequate fire protection

staff, but no one person has been made responsible for overseeing

fire protection.

(See Section IV.I, Engineering Support, for as-

sessment of the fire protection program.)

Fourteen of 17 operator license candidates passed the NRC examina-

tion and received

licenses. With regard to training in Appeadix

R modifications, however, some operators had difficulty in perform-

ing tasks such as locating some safe shutdown equipment and removing

some breakers.

(See Section IV.J. Training Effectiveness, for

evaluation of training aspects.)

The control rocm and control board interiors were generally clean.

In the plant, however, the licensee did not remove boron encrusta-

!

tion af ter leak repairs.

That did not contribute to the otherwise

good work practices, but the pipe and valve leakage control program

now addresses this.

Overall, housekeeping was evaluated as fair.

Extended inoperability of the ventilation coolers for the vital DC

switchgea; rooms was identified.

The licensee compensated for the

.

inoperable equipment by prescribing additional operator actions in

plant procedures, but these procedures lost detail over various

revisions.

Licensee actions on this item were not indicative of

the generally conservative approach taken to equipment opr"ability.

There was little safety significanct because operator actions would

have provided adequate cooling of the rooms.

Nonetheless, opera-

tional and plant management review of plant condi' ions should have

proTpted =arlier resolution of cooler inoperabilis,

In summary, the licensee demonstrated continued good performance

'

in nitnt operations, with strong management involvement and over-

signt, good parformance in operator licensing, and a generally suc-

.-

. .

f

.

,

'

16

cessful Appendix R effort. Operator competence was evident, and

their professionalism ard safety perspective in problem resolution

remained notable strengths.

Plant housekeeping was acceptable but

can be improved.

Conclusion

Category 2.

Board Recommendations

Licensee:

Improve equipment operability overview.

--

Assure proficiency in shutdown equipment operation.

--

Improve housekeeping.

--

.

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. ,

_ _ _ _ _ _ _ _ _ _ _ _ _

.

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17

B.

P.adiological Controls - Unit 1 (297 hours0.00344 days 0.0825 hours 4.910714e-4 weeks 1.130085e-4 months , 11')

- Unit 2 (265 hours0.00307 days 0.0736 hours 4.381614e-4 weeks 1.008325e-4 months , 10*4)

The licensee's Radiological Controls Program was rated Category 3 during

the previous assessment period.

Significant weaknesses in the radwaste/

transportation areas resulted in multiple NRC violations.

These re-

flected a lack of management involvement, inadequate QA, and ineffective

corrective action. Deficiencies were also noted in control of high

radiation areas, the ALARA program, and implementation of in-the-field

changes to Radiation Work Permits (RWPs).

A total of twelve inspections in the Radiologicci Controls area were

conducted during the current period.

Two violations were identified,

both in the radiological safety area.

Radiological Safety

The licensee's radiological safety organizational structure was clearly

defined and adequately staffed.

Effective procedures and policies were

in place. Adequate staffing upgrades were made to support outage acti-

vities.

The resume review and qualification process for contractor

technicians was effective and well-documented.

,

Training of radiation workers and contractor technicians was performed

effectively.

Deficiencies were noted, however, with the level of super-

vision of temporary personnel performing station health physics support

activities (whole body counting, respirator issue, etc..).

As i result,

minor problems were noted with whole body counting control charts, source

check records and temporary personnel training and qualification records.

Audits of the Radiation Safety Program were performed by the corporate

staff.

Review indicated that, although procedural requirements were met,

l

audits were compliance-oriented rather than performance-oriented, in that

procedure adherence was audited but not procedure and program adequacy.

I

l

Concerns were also identified with the independence of auditors, speci-

fically in the dosimetry area.

Both the auditors and the dosimetry group

,

j

reported to the same supervisor.

The licensee committed to change this.

Posting and control of high radiation areas (HRAs) continued to be a Unit

I weakness during the current period.

An uniocked HRA door was identi-

l

fied by the NRC during the Unit 1 outage; additionally, several temporary

j

HRAs were noted to be inadequately posted.

l

Weaknesses in radiological area posting and radioactive material labeling

were also noted during the Unit 1 outage.

There was a violation for

'

failure to label radioactive material.

These concerns suggest an in-

appropriate level of control and supervision over radiological field

activities during the Unit 1 out% e.

Posting and labeling practices at

Unit 1 during routine operations and at Unit 2 were noted to be effective.

,

j

Subsequent to the identification of the above concerns, the licensee in-

l

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,

_

, . . . . _ .

-_

_ . . _ _ . _

__

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

.

'

18

stituted a policy requiring more frequent surveillance of controlled

areas. A significant increase in upper-level station management atten-

tion and involvement in the implementation of the radiological safety

program was also noted in the last third of this period.

Several higt-exposure work activities were ef fectively controlled by the

'

licensee during the current period. Appropriate pre-work surveys were

taken and Radiation Work Permits (RWPs) prescribed effective work con-

trols.

Survey information was available and was communicated to radi-

ation workers.

Engineering controls were effective in minimizing air-

borne radioactivity.

Support services, including respiratory protection

and dosimetry, continued to adequately support the program.

Several

minor examples of failure to follow the RWP procedure were noted during

the Unit 1 outage, and resulted in a violation.

These examples indicated

a lack of HP technician and supervisor attention to detail and to effec-

tive control of the RWP system during the Unit 1 outage.

No difficulties

were observed with Unit 1 RWPs during routine operations.

Unit 2 imple-

mentation of the RWP system was effective.

While improvements were noted in the ALARA program during the current

period, continuing effort in this area is needed.

Deficiencies in the

ALARA goal-setting methodology were noted at the beginning of the period;

ALARA goals were being developed exclusively by the corporate group an'i

often did not reflect +.he specific scope of work planned.

It was noted

during the Unit 2 outage that widely discrepant site and corporate de-

rived goals were in place for the same activities.

Goals are now being

proposed by the corporate group, based partly on input from the site;

the site then reviews and Odjusts as necessary.

A significant scope of work was undertaken during the period, including

refueling at both units, jet pump nozzle work and torus decontamination

at Unit 1, and steam generator repair and fuel pool re-racking at Unit

2.

Adequate pre-job planning was typically in place.

It was noted,

however, that poor feedback from some station work groups resulted in

delays in ALARA planning during the 1986 Unit 2 outage.

Daily outage

exposure tracking was performed ef fectively and represented an improve-

ment over the previous period.

Exposure reduction techniques typically

utilized included steam generator channel head decontamination, mock-up

training, temporary shielding, and effective contamination control.

Addit;onal licensee initiatives in the ALARA area included the institu-

tion of a station ccbalt reduction plan and adoption of a zinc passiva-

tion process at Unit I to reduce overall dose rates.

Unit 1 exposure during the current period reflects a significant in-

provement over previous periods.

In 1986, a non-refueling outage year,

exposure totaled 162 person-rem.

In 1987, Unit 1 exposure totaled 710

person-rem, most of which was attributable (approximately 613 person-rem)

to the refueling outage.

.

--

, - . . _ - , . _ , - -

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

'

19

Unit 2 exposure continued to be high during outage years and totaled 962

person-rem in 1986.

The majority of this exposure (879 person-rem) re-

suited from the outtge. A significant scope of work generated much of

this expos.re; however, several equipment and performance problems con-

tributed to overall exposure.

These included significant difficulties

with steam generator (S/G) nozzle dam installation, relative ineffec-

tiveness of the S/G channel head decontamination, and remote equipment

limitations during tube plugging.

These problems contributed to the

steam generator inspection and maintenance exposure exceeding the ALARA

estimate by approxinately 120 person-rem.

The NRC staff noted improved

performance in the installation of steam generator nozzle dams during

the 1988 outage (after the SALP period).

This was directly related to

careful preoperational testing of the dams and detailed training of the

workers involved. These program improvements, along with the use of

remote manipulation equipment for tube pulling and nondestructive testing

inside the steam generator primary channel heads, contributed signifi-

cantly to lowering outage exposures.

Licensee efforts in this area

should continue to be directed towards increasing the effectiveness of

pre-work planning and reducina the incidence of equipment malfunction

and rework.

Unit 2 exposure for 1937, primarily an operational year, exhibited im-

provement over previous operational years and totaled approximately 154

person-rem.

Chemistry

A clear corporate commitment to and support for an effective water

chemistry control program was evident in review of the Unit 1 program.

'

The organization was clearly defined, suitably staffed with qualified

personnel, ind functioned smoothly in its interfaces with other plant

groups.

The licensee was responsive to NRC suggestions for improved

valve maintenance debris control and actions when contaminant levels ex-

ceed administrative limits.

The ongoing cobalt reduction program showed

a proactive management approach to corrosion product source term reduc-

!

tion.

In-line instrumentation and sampling was adequate for corrosion

and impurity ingress monitoring. Overall, the chemistry program effec-

l

tively supported plant operations.

.

Chemical measurement capability was evaluated against technical specifi-

cation and other regulatory requirements.

The licensee was adequately

l

staffed and had state-of-the-art equipment for nonradiological chemistry,

l

Weaknesses in laboratory calibration techniques indicated minor inatten-

tion to detail, however.

The gaseous and liquid effluent control programs were inspected during

thi s assessment period.

The Chemistry group was responsible for program

implementation.

Clear corporate support for effective implemertation

l

was evident.

Management controls were evident in the procedures for

controlling discharges as well as for scheduling surveillances.

Effluent

I

1.

,

_ _________________ -

_ _ _ _ _

.

20

control instruments were maintained and calibrated in accordance with

regulatory requirements. Air cleaning systems were also inspected during

this a>sessment. All release records were completed and well maintained.

Improcements had recently been made to vendor laboratory QA controls in-

cluding the assignment of one chemistry staff member to review and im-

piement in this area. Management audits of the program were generally

comprehensive and technically sound.

During this assessment period one independent measurement inspection was

performed using the NRC:I Mobile Laboratory. All split sample results

were in agreement between the licensee and the NRC.

During this assessment period, the licensee's whole body counting facil-

ity was examined. One deficiency in the whole body counting QC program

indicated a lack of attention to detail in this area.

The licensee

stated that this area would be reviewed and timely corrective action

taken.

The licenste's corrective action was not reviewed during this

assessment period.

Transportation

Two transportation inspections were conducted during this assessment

4

l

period.

Following incidents which resulted in several violations and

weaknesses in the last assessment period, the licensee restructured the

organization responsible for packaging and shipping radioactive materials.

The responsibilities and authorities of the Radioactive Material Handling

(RMH) Department were defined adequately. Job-related procedures and

QA audit procedures have been revised and improved.

The frequency and

scope of CA audit activities has also improved.

The Radwaste Review

Committee has been reactivated.

Documentation of shipments has been

improved, and all paperwork for a given shipment is now kept to; ether

as required.

!

Following violations pertainir g to radwaste transportation training our-

ing the last assessment period, licensee modules were ccmpletely rewrit-

ten. All staff received required training except for an individual who

could not complete the course due to health problems.

The training and

I

Qualification contributed a positive direction to the effectiveness of

RMH group's function.

Close management attention to nianning and imple-

!

menting the program was noted, with strong peer reviu of the technical

j

aspects of preparation, packaging and shipping activities.

Summary

!

Licensee performance during the current period reflects substantial im-

provement in the radwaste and transportation areas.

The in plant radio-

l

logical safety program was generally effective; however, a deficiency

in the level of control and supervision of field activities was identi-

I

r

. _ _ ______

__ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _

_ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _

_ _

_ _ _ _ _ _ .

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

e

'

21

fied and led to weaknesses, primarily in Unit 1 outage performance.

Im-

provements in ALARA were achieved; continuing licensee attention should

be directed in this area.

Conclusion

Category 2.

Board Recommendation

Licensee:

Improve control and supervision during outages.

--

Improve pre-job planning and work efficiency.

--

Continue improving the ALARA program.

--

f

.

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_

, . . _ _ _ _ , . . , , _ _ _ , .

_ _ _ _

_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

~

22

C.

Maintenance

The licensee's maintenance program provided effective planning, control-

ling and trending of maintenance activities through the licensee's Pro-

duction Maintenance Management System (PMMS). The system has b'en a good

planning tool that helped to assure proper coordination of mair. nance

activities.

The tracking function of the program ensured that mainten-

ance activities were properly closed out.

1.

Maintenance - Unit 1 (174 hours0.00201 days 0.0483 hours 2.876984e-4 weeks 6.6207e-5 months , 7%)

The previous SALP rated Maintenance as Category 2, Consistent.

An

area identifieJ as requiring increased emphasis and management at-

tention was addressal of aging components.

Examples identified in-

cluded the scram solenoid pilot valves, the eeergency gas turbine

generator (EGTG), and the main turbine mechanical pressure regulator

(MPR).

There has been improved performance of the scram pilot

valves.

The EGTG maintenance program was improved, and the EGTG

exhibited much improved reliability.

Also, extensive maintenance

on the MPR improved its performance and reliability.

During this SALP period, maintenance was routinely reviewed by

resident inspectors and occasionally by region-based inspectors.

One scram (9/3/87: low scram air header pressure) was attributed

to maintenance.

Safety system readiness and reliability, and In-

Service Testing (IST) performance evidenced the effects of good

preventive and corrective maintenance. Consistently satisfactory

"as found" surveillance results also indicated successful mainten-

ance.

Management attention in this area was evident at Unit 1 by an on-

line updating of maintenance activities on a per-shift basis. Also,

the maintenance department used data trending technt.;ues in review-

ing and analyzing the preventive and corrective maintenance records.

This was a positive step toward improving effectiveness of mainten-

ance activities.

Corrective maintenance was generally perft rmed in strict accordance

with policies, procedures and work orders

Troubleshooting and sig-

nificant supervisory involvement led to E: curate problem assessment

and formulation of croper corrective actions. Werk was thnrough

and technically sufficient.

Rework was seldom required. A compre-

hensive trending program was established and well implenanted. Only

one maintenance inadequacy was observed: the "as-found" containment

integrated leak rate test (CILRT) failed on August 6, 1987 due to

leakage through isolation condenser steam vent valves.

The rect

causes were poor post-maintenance valve stroke adjustment and an

inadequate post-maintenance test.

Foliewing valve overhaul, main-

tenance personnel had failec in set valve stroke sufficient to en-

_ _ _ _ _ _ - _

_

__

_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.___ _ ______ _________

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

__ _____ __ __ - _________

.

23

sure positive seating.

Licensee planning to implement a training

program to cover proper post-maintenance valve adjustment was ap-

propriate to correct the deficiency.

The maintenance department was staffed with well trained, competent

and dedicated mechanics, electricians and machinists. Additional

maintenance assistance was available from the other Northeast

Utilities plants on an "as needed" basis. Observations and discus-

sions showed maintenance supervisors and managers to be knowledge-

able, as well as active in quality assurance activities.

Highly

effective planning minimized outage and operational scheduling im-

pacts.

The strength and flexibility of the organization was par-

ticularly evident in excellent outage performance. Also, coordina-

tion with other departments was excellent.

Licensee performance of maintenance during the 1937 outage was

particularly noteworthy. A very significant outage work 1 cad was

completed.

The maintenance activities were well planned and exe-

cuted.

Licensee attention to plant cleanliness during the outage

and during routine power operation was very good.

Licensee perfoe.:ance in the maintenance area has significantly im-

proved over the assessment period.

Conclusion

Category 1.

Board Recommendations

,

None,

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--

- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _________ __

_ _ _ - - - _ _ _ _ _ _ _

_ - - _ _ - - _ _ _ _ _ _ _ _ _

.

24

2.

Maintenance - Unit 2 (131 hours0.00152 days 0.0364 hours 2.166005e-4 weeks 4.98455e-5 months , 7?e)

The previous SALP rated the maintenance area as Category 1.

Strengths included machinery history, modification testing, pre-

ventive maintenance, procedural compliance, safety, work practices

and documentation.

During this SALP period the licensee's performance on major job

tasks displayed excellent knowledge of systems and the details of

modifications.

These activities included the installation of a new

containment pedestal crane to support faster crane evolutions in

high radiation areas, a pilot fuel consolidation project, replace-

ment of Turbine Building Closed Cooling Water heat exchangers, and

renewal of containment isolation valve seats.

In addition, support

to Steam Generator Non-Destructive Examination (NDE) inspections

and the replacement of the main condenser added unusually heavy

wt.a.. loads for maintenance supervision.

The jobs were nonetheless

well managed.

Maintenance management kept the work backlog at minimum levels.

In addition, use of thermcgraphy surveys of electrical equipment

d9tected a loose connection on a Reactor Coolant Pump (RCP) pene-

,

tration, and corrective action was taken prior to cable failure or

malfunction.

Detailed involvement of quality control persnnnel,

supporting engineering groups, purchasing, material, and construc-

tion groups was evident.

Examples of thorough QC overview were

noted in fuel reconstitution and fuei consolidation, activities

which were supported by the maintenance department.

Upper management support of maintenance was demonstrated in the

'

!

construction of new Un t 2 maintenance facilities. The I&C shop

was expanded.

In acaition, a new snubber repair and test facility

was added.

'

Eetter performance by the Production Test Department appears to be

needed.

This group was responsible for three events, including two

reactor trips. One was a 7oss of normal power (LNP) while shut down

(LER 86-20); one was a LNP/ reactor trip from 50*4 power (LER 86-22).

,

j

These were both caused by improper closure of a 4 KV bus potential

l

transformer drawer, resulting in misaligned stabs.

One trip was

caused by inadequate review of the effects of a design change to

'

!

a fire protection system module on the main boards-(LER 87-02).

'

Two trips during the period were attributed to feedwater regulating

valve failures.

Two other trips occurred due to equipment problems,

one involving the pressurizer spray valve and a second involving

,

!

an apparently spurious opening of tha main generator field breaker.

These foui equipment problems w:re net correlated to maintenance

'

deficiencis.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

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25

The maintenance program was staffed by dedicated, thoroughly trained,

knowledgeable engineers, mechanics and technicians.

Corporate man-

agement commitment to training was shown by the purchase of RCP

seals and a diesel for training purposes,

t

A positive approach was demonstrated by implementing a preventive

maintenance program to systematically maintain containment isolation

valves such that containment leak rate is minimized.

One of the

associated actions was replacement of the T-ring seats for Fisher

valves. Also, for two globe valves in the containment sump, the

licensee proposed installation of screens to prevent debris accumu-

lation which previously contributed to valve degradation and leakage.

Unlike Unit 1, the Unit 2 Maintenance Department has not implemented

a comprehensive trending program.

Unit 2 trending was done on a

selected component basis,

d

One issue identified at the end of the SALP period and still under

NRC review involved inadequately maintained seals on ventilation

system joints and access doors.

The worn seals provided an unin-

tended control room air inleakage path, and airborne ncble gas ac-

r

tivity from the auxiliary building ente *. d the control room.

Lic-

ensee short term actions to correct the worn seals were appropriate.

In summary, good licensee performance in this area was demonstrated

by good management and control of maintenance by a qualified staff.

,

Initiatives to address recurring charging system maintenance prob-

lems were noted as was the management commitment to

(vrovement of

the maintenance facilities.

Improvements can be realized by imple-

menting a more comprehensive trending pregiam, by improving Produc-

tion Test Department performance, and by reducing the number of

plant trips due to equipment problems, Although no significant

performance change was noted late in the performance period, and

although the equipment problems encountered may require engineerir;

i

support resolutions, licensee attention may be needed to assure that

maintenance performance does not decrease during the next SALP

'

l

period.

Conclusion

Ca tegory 1.

l

Board Recommendations

None.

,

t-

-

._-

_-

. - -

.

_

_ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

_ _ _

. _ _ _

___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

.

26

D.

Surveillance

The licensee's calibration and surveillance program has been well defined

and administratively controlled.

The program was well managed and effec-

tively implemented.

Surveillances and calibrations were controlled and

scheduled via automated work orders, and complex surveillances were iden-

tified as such.

Records were well maintained and complete.

Completed

surveillances were routinely farwarded to records storage on a monthly

or quarterly basis.

Surveillance and calibration procedures were found

to be technically adequate.

Test personnel were adequately trained and well versed in procedural and

regulatory requirements.

Supervision was involved in the conduct and

review of completed test results.

Measuring and test equipments (M&TE)

used for surveillances and calibrations were found to be calibrated, and

well controlled wnen not in use. M&TE was routinely returned to storage

after each shift or upon completion of the activity.

Each department onsite was responsible for maintaining a status list of

surveillances they are responsible for per administrative procedure.

These lists were up-to-date and well maintained.

Management also effec-

tively used QA/QC to monitor surveillance program implementation. An

example was QC surveillance of I&C Department control of M&TE, requested

as a result of a transfer in responsibility for the control of M&TE.

As expected, several problems were noted.

These were quickly resolved

and corrected.

The program for calibration of installed instrumentation was accurate,

clearly described and well managed.

Both the computerized scheduling

at Unit I and the schedule sheets used at Unit 2 controlled the assign-

ment and completion of tasks.

The I&C staff and supervision had a clear

understanding of the administrative control system.

l

Technicians performing calibrations knew their duties and the procedures

!

being used.

Execution of work steps was done conscientiously and in a

confident manner. A notable human factors improvement in the conduct

of in plant calibration of instrumentation was the use of a personal

computer at Unit 2 to display work steps, guide the technicians, deter-

mine acceptability of results, automatically initiate corrective action

documents when appropriate, prompt and require workers to follow proce-

dural steps, and retain results for record purposes.

,

Management involvement and support was evident and reflected in the qual-

,

1

ity of the established program, the manner in which it was implemented

and being improved, and the effort to enhance QA overview effectiveness.

I

!

l

1

- _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

__

_

____ _

_ _ _ _ .

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

27

1.

Surveillance - Unit 1 (438 hours0.00507 days 0.122 hours 7.242063e-4 weeks 1.66659e-4 months , 16%)

The surveillance program at Millstone 1, including In-Service In-

spection and Testing, received resident and region-based inspection.

During the preceding SALP assesst.ent period, a rating of Category

1 was assigned.

A large number nf surveillance tests were observed by the NRC with

little or no warning.

The depth of knowledge and the pride in

workmanship displayed by individual technicians was noteworthy.

An active licensee review and upgrade program existed, and the

quality of procedures used in surveillance tasting was generally

good. However, as evidenced by occasional inspector-identified

procedural deficiencies (especially in long standing, frequently

used procedures; e.g. , weekly station battery checks), the upgrading

system was not fully effective.

The Unit 1 Containment Integrated Leak Rate Test (CILRT) was well

planned and o ganized, as evidenced by the availability of call-

brated instruments and sensors, approved test procedures, and

trained personnel. QA coverege of the test tiso was well planned

and implemented.

Leak inspections were well organized and properly

coordinated by the test director.

Test documentation was adequate

and plant evolutions during the test were well documented as evi-

denced in the official test log book and control room shif t super-

visor's log bcok.

Even though the "as found" CILRT failed due to

leaks through Isolation Condenser valves, the test was well con-

trolled and executed.

The good overall test performance reflected

the licensea's emphasis on detailed planning of surveillances.

The program for calibrating technical specification-related instru-

mentation included identification of instruments needed to satisfy

the technical specifications, and verification that these were

calibrated and in the calibration program. Data sheets had been

developed and maintained for such instrumentatien.

The program for

control and calibration of portable measurement and test equipment

l

was adequate to provide for calibration frequency, accuracy and

l

history of use of the equipment

Administrative controls over this

equipment were effective.

l

While the overall surveillance program was good, follow-up on iden-

tified concerns needed more emphasis.

This was evide;.t by the delay

in the resolution of short hold down bolt concern in the Low Pres-

sure Coolant Inhction (LPCI) and Core Spray systems.

(This is

evaluated in the Engineering Support Area,Section IV.I).

l

The use of technically qualified (NDE Level III) personnel to sur-

l

Veil ISI vendor activities was a positive way of assuring that these

l

activities were performed in accordance with requirerents. Manage-

l

ment involvement in plant activities was evidenced by the consist-

l

i

l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _

.

28

i

ency with which the licensee informed the NRC, prior to performing

examinations, of how NRC requirements regarding the detection of

intergranular stress corrosion cracking (IGSCC) would be met.

Pre-

outage meetings were held to discuss compliance with applicable

requirements.

Effective licensee control of contractors was demon-

strated by the licensee training given to In-Service inspection

(ISI) vendor personnel, who were further required to demonstrate

their ability to detect IGSCC prior to performing work.

Surveillance activities contributed to operational events during

the 1987 outage and upon startup.

The events included: (1) an RPS

actuation while shut down, due to failure of I&C technicians to ade-

quately verify initial conditions during Main Steam Isolation Valve

(MSIV) functional testing (LER 87-28); (ii) an actuation of LPCI

with discharge to the reactor vesse! due to inattention to detail

and f ailure to provice required inaependent verification during

surveillance (LER 87-33); and, (iii) an Engineered Safety Feature

actuation as a result of inadequate control of surveillance testing

(LER 87-36).

The one violation for this area (IR 87-21) involved what appeared

to be a declining personnel performance trend.

Licensee corrective

actions appeared effective, in that no further problems have oc-

curred.

Four licensee event reports involved missed or past due surveil-

lances (LERs 87-04, 35, 37, and 39) and a fifth addressed a defi-

cient test method used for the standby gas treatment system (SGTS)

flow distribution (LER 87-44).

The appropriate corrective action

for the SGTS test method requires further licensee and NRC review,

but it appears that the test method used was adequate.

In regard

to the missed surveillances, four in 19 months was not considered

significant in view of the total number scheduled and completed

satisfactorily.

However, attention may be warranted to assure a

declining trend does not develop.

'

The licensee had established procedures to implement Technical

Specification related Surveillances and the ISI program.

Planning,

scheduling and conduct of the surveillances and ISIS were found to

be adequate and met Technical Specification requirements.

The in-

dividuals performing these activities were adequately trained and

indoctrinated.

Surveillance and ISI documentation.was properly

reviewed, approved and controlled.

I&C was reviewing I&C procedures

to incorporate current and accurate information and references.

l

The licensee also established off-normal procedure ONP-5148 to en-

hance their winterization program.

In additicn, the plant opera-

tions staffs periodically made rounds and verified that safety-sig-

nificant equipment, systems, and process lines were adequately pro-

tected against cold weather.

!

. _ _ _ _

_ _.

_ . . _ .

__

_ _ _ _ .

_

_. ,

-_

. . _ .

_ . _

_ . _ , _

_ _ _ - _ _ _ _ _ _ _ _

_ _ _ _

_

________ __

___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

____

- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

29

Staffing and staff training were evaluated as sufficient and ef fec-

tive.

In summary, the calibration and surveillance program for safety-

related equipment was well established, and implemented by qualified

personnel.

Involved supervision provided program oversight and used

the QA/QC function effectively.

Performance of surveillance per-

sonnel was generally good.

Performance of the Containment Inte-

grated Leak Rate Test and the Inservice Inspection Program was not-

able.

The three operational events related to surveillance activi-

ties were not assessed by the board as indication of a declining

trend.

However, attention is warranted to assure decreased per-

formance does not result from missed surveillances or from surveil-

lance-related plant events.

Conclusion

Category 1.

Board Recommendations

None.

___

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

_ _ _ _ _ _ .

.

30

.

2.

Surveillance - Unit 2 (397 hours0.00459 days 0.11 hours 6.564153e-4 weeks 1.510585e-4 months , 15'4)

During the preceding SALP assessment period, this area was rated

Category 1.

The surveillance test program was considered a notable

strength.

Surveillance activities inspected during this assessment period in-

cluded: surveillance testing and calibration control; in-service

<

'

inspection; seismic instrumentation; and steam generator work.

1

Performance of local leak rate testing (LLRT) and the supervision

exercised over it were very good.

LLRT technicians were competent

and familiar with their assignments. Technicians were supervised

by an operations engineer to assure procedural adherence and engi-

neering oversight.

The planning and test results evaluation was

the responsibility of another engineer, who also provided overall

L

program oversight.

Good planning and effective administrative con-

trol of LLRT reflected the licensee's commitment to enhance the

surveillance program.

]

A comprehensive steam generator (SG) tube ma!ntenance program was

implemented, including monitoring and control of secondary-water

'

chemistry, inspection of condenser tubes, and performing material

accountability to avoid leaving foreign objects in the SGs.

The

inspection sample size established by the licensee exceeds that

required by technical specifications.

These licensee activities

represented good initiatives, ;nd indicated a strong and aggressive

management involvement in activities affecting safety and quality.

Procedures and planning for steam generator surveillance were good.

The eddy current test (ECT) prncedures were suf ficiently detailed

and emphasized precautions nt.;ssary for satisfactory performance

of the measurement.

Testing personnel were required to demonstrate

their ability to complete their assignment in a safe and timely

'

manner during on-site training before the actual work, in order to

minimize radiation exposure and potential contamination.

After returnirg to power operation after to the 1986 outage, the

licensee identified a leak, within acceptable limits, in steam

generator SG-1, and initiateo a plant shutdown.

Hydrostatic test

determined that a hot-leg tube was leaking.

Re-review of ECT data

showed a 3P4 threugh wall indication at the leakage location.

The

re-review of outage ECT data also disclosed that a defective cold-

i

leg tube had not been plugged in SG-1.

Thorough re-analysis of the

ECT data identified 36 additional tubes (29 in SG-1, 7 in SG-2) with

defects, some in excess of technical specification limits, which

the licensee decided to plug.

The testing deficiencies exhibited

ineffective QA/QC review of the earlier eddy current data reduction

'

and ev.iluation.

The licensee generally maintained good control over

i

.

- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ ___ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ .

- _ _ _ _ _ _ _ _ .

.

31

contractor activities, but this failure to identify tubes needing

plugging prior to returning to operation was in part the risult of

failure to adequately monitor a contractor.

The licensee took the conservative action of plugging the tubes sur-

rounding the leaking tube to safeguard against the leaking tube

causing other tubes to fail if it severed.

The licensee thoroughly

assessed the cause of the failure to identify the pluggable steam

generator tubes and implemented appropriate corrective actions.

Additionally, after the present SALP period, surveillance during

the 1938 outage identified 3 defective steam generator tubes that

were to have been plugged during the 1936 outage.

They were not

'

plugged due to an error in indexing the inspection equipment.

This

was a second example of the need to better control contractor acti-

vities.

In addition to normal in-service inspection, the licensee initiated

an aggressive program to assess wall thinning due to erosion /corro-

sion in secondary system high-energy piping.

The licensee has

voluntarily funded a three year research project at the Massachu-

setts Institute of Technology to develop methodologies for such

inspection and analyses.

This is a good initiative and results of

the research may benefit plant operations and the industry as a

whole.

The licensee has established both preventive maintenance (PM) and

corrective maintenance (CM) procedures.

NRC review of surveillance

testing found that the PMMS system was t. racking TS requirements and

that testing was being performed on t.me.

Surveillance procedures

were well written and had the necessary controls to assure that test

data and system work were controlled and monitored by supervision.

Maintenance and I&C swervisors were considered knowledgeable and

well informed in the surveillance area.

Also, the I&C staff ap-

peared to be well trained and to have sufficient personnel to per-

form their task.

,

I

i

The quality control organization was notified of safety-related work

l

being performed and inspet,ted on a sampling basis.

In summary, the calibration and surveillance program for safety-

related equipment was well established and implemented by qualified

personnel.

Involved supervision provided program oversight and used

l

the QA/QC function to monitor program implementation.

Performance

l

of local leak rate testine, was notable, and the steam generator tube

I

inspection and maintenance program was generally very good.

However,

i

there was

need to bprove contractor control and assure quality

'

in the correct interpretation of steam generator tube eddy current

data.

The importance of this aspect is such that it was a major

element of performance in the surveillance area.

l

.-

.

..

.

..

!

.

L

b

32

Conclusion

Category 2.

Board Recommendations

Licensee:

i

/

Improve the evaluation of ECT data,

--

Improve contractor oversight and control.

--

_

-

I

~

33

,

E.

_ Emergency Preparedness - Unit _1 (138 hours0.0016 days 0.0383 hours 2.281746e-4 weeks 5.2509e-5 months , 5%)

- Un1t 2 (148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months , 6%)

During the previous assessment period, licensee performance in this area

was rated as Category 1.

Emergency preparedness is a site function with common Emergency Plans,

facilities and personnel.

This assessment covers the June 1, 1986

through December 31, 1987 period.

It represents an evaluation of all

three Units, but does not repeat applicable parts of the three unit

assessment in the Millstone 3 SALP for the period ending February 28,

1937.

During tiie current assessment period, a partial participation

exercise was observed, one routine safety inspection was conducted, and

changes to emergency plans and procedures were reviewed.

The routine safety inspe: tion was performed in June / July, 1987.

This

inspection examined all major

'eas of the licensee's emergency prepared-

ness program. Weaknesses were .,9ntified in the independent audit pro-

gram, specifically related to audit checklist preparation, auditor quali-

fications, and content of audits.

Additionally, the NRC had difficulty

determining which organization, corpcrate staf f or on-site staf f, had

overall responsibility for evaluation of and corrective action on audit

findings. The licensee resolved program responsibilities before the end

of the inspection.

The licensee had undertaken corrective action on

previously identified weaknesset, as well as actions to strengthen the

overall program.

Included in these actions was a complete Emargency

Action Level review incorporating, as appropriate, plant specific para-

meters, human factors reviews, and training.

A partial participation exercise was conducted on October 8, 1987.

The

licensee demonstrated a good emergency response capability.

This per-

formance was improved over the previous annual exercise. Actions by

plant operators were prompt and effective.

Event classification was

accurate and timely.

Personnel were generally well trained and qualified

'

for their positions. No significant exercise weaknesses were identified.

The licensee's training program has been effective as demonstrated by

their performance in the annual emergency exercise.

Management involve-

ment has been generally effective as evidenced by the timely completion

of correction actions, as well as a willingness to upgrade program cap-

abilities.

However, the interface between the Corporate Staff, on-site

emergency preparedness staff, and on-site management could more be

clearly defined, particularly in regards to audit program responsibili-

ties,

Northeast Utilities continues to maintain a very good relationship

with all off-site agencies.

I

i

,

_ _ _

.

_ _ _

.

34

"

Conclusion

Category 1.

Board Recommendations

None.

-a

.

_ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _

, _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ -

-_

O

35

,

F.

Security and Safeguards - Unit 1 (77 hours8.912037e-4 days 0.0214 hours 1.273148e-4 weeks 2.92985e-5 months , 3%)

- Unit 2 (84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months , 3%)

During the previous SALP, the licensee's performance in this area was

Category 1.

That rating was largely influenced by the timely completion

of Unit 3 systems and equipment and integration of those with the exist-

'

ing systems and equipment for Units 1 and 2, while still maintaining an

effective security program at Units 1 and 2.

During this assessment

period, four routine unannounced physical security inspections were per-

formed by region-based inspectors.

Routine inspections by the resident

inspector continued throughout the period.

Six violations wete identi-

fied during the physical security inspections.

Sever &l of those viola-

tions had existed for an extended period and should have been obvious

to knowleogeable and attentive security personnei.

Corporate security management involvement in site security program mat-

ters was apparent early in the period.

It included visits to the site

by the corporate staff to provide assistance, program audits and direct

support in the budgeting and planning processes affecting program modi-

fications and upgrades.

Corporate security management personnel also

continued to be actively involved in the Region I Nuclear Security As-

sociation and other industry groups engaged in nuclear plant security

matters.

This demonstrated program support from upper level corporate

management. However, an apparent reduction in the oversight and audit

function occurred as a result of the loss of two key corporate personnel

during the period, as discussed in the following paragraph.

During the previous assessment oeriod and in the early part of this as-

sessment period, the licensee wss heavily involved in integrating the

Millstone Unit 3 security program into the existing program for Units

1 and 2.

This was accomplishea with minimum impact on the cverali

security program.

The licensee decided that, with the integration of

the Unit 3 program, modifications to and restruct.uring of the proprietary

and contract organizations would be necessary to accommedt.te the in-

creased work load. While that decision was made in late 1985, it was

never formally instituted and coes not appear to have been actively pur-

sued.

Several proprietary supe rvisory positions to which the l'censee

had committed were filled on a rotating basis without ensuring that the

incumbents understood their dut.ies and responsibilities and without pro-

perly monitoring their perfernance.

Therefore, the majority of the in-

creased workload, which the licensee previously had identified, remained

the responsibility of one individual on-site. As a result, effective

oversight, interface and communications between the licensee and the

contractor organi:ation begar to degrade.

Concurrently, it appears that

a complacency with program implementation and an insensitivity to NRC

requirements began to occur.

These conditions were identified during

an NRC inspection late in the SALP period.

That inspection resulted in

a civil penalty. While the individual violations were of low signifi-

cance, they represented a significant larse in management attention to,

and control of, the security program at Millstone.

-

..

.

._ . ..

.

.-

__.

___________

l-

.

f

as

-

l

The annual audit of the security program, performed by the licensee's

quality assurance group, appeared to be comprehensive in scope and depth.

i

However, the number of violations identified by NRC during the period,

several of which had existed for some time, calls into question the ef-

fectiveness of the audit relative to the security progratn meeting NRC

objectives.

Review of the licensee's security event reports and reporting procedures

found them to be consistent with the NRC regulation (10 CFR 73.71) and

,

l

implemented by personnel knowledgeable of the reporting requirements.

The reports were generally clear and contained sufficient information

for NRC assessment.

The licensee's actions following each of the events

were prompt and appropriate, reflecting the proper degree of management

oversight. During the previous SALP period, 10 security event reports

(SERs) resulted from security computer-related problems.

The licensee

established a dedicated security maintenance group.

There were 7 ccm-

puter-related SERs during this period.

The remaining SERs, including

seven degradations of vital barriers, were not causally linked.

As previously stated in this assessment, some problems were encountered

with the licensee's oversight of the contractor's security force.

Several of the violations identified by the NRC should have been obvious

to trained and attentive security personnel.

Members of the security

force, as well as licensee supervisors, patrol the site frequently and

should be alert for deficiencies. Of significance is that the violations

were not previously identified by security force members.

There was also

a number of performance related events reported during the period.

The

licensee needs to determine the root cause(s) of this problem and in-

crease its oversight of the contractor to preclude recurrence.

Staffing of the contractor's security force is adequate.

The training

and requalification program appears sound and well developed, but because

of the problems identified during this assessment period, it needs to

be reviewed along with the manner in which it is being implemented.

During the assessment period the licensee submitted two revisions to the

Millstone Nuclear Power Station Security Plan ano one revision to the

Guard Training and Qualification Plan under the provisions of 10 CFR 50.54(p), and provided a response to the Miscellaneous Amencments to 10 CFR 73.55, codified by the NRC in August 1956.

These inputs were of good

quality and incicated knowledge and understanding of NRC security program

objectives.

In summary, the licensee's security program, when properly implemented,

is sound and effective as evidenced by the licensee's past performance

record.

The NRC believes that the decreased level of performance ex-

hibiced by the licensee curing this period can be attributed to a reduc-

tion in . manage ent oversight and involvement in the program as evidenced

by not carrying out plans to restructure the organization to accommodate

i

..

.

W

'

37

l

the inc* eased workload from Unit 3, by not filling vacant positions

promptly, and by not recognizing early indications of potential program

degradations.

Conclusion

Category 2.

,

Board Recommendations

Licensee:

Re-evaluate effectiveness of security self-assessment function,

--

assuring that program adequacy aspects are evaluated in addition

to program compliance.

Reassess effectiveness of management overview of security.

--

Reassess adequacy of the security training program and its imple-

i

--

nentation,

tRC: Review licensee security program to assess the effectiveness of

j

corrective actions on tne security inadequacies which resulted in

'

escalated enforcement action,

i

.

!

'

i

,

l

5

i

,

.

u

- - - - - - -- - .. - - - - - , _

. , - _ - - . . _ _ _ _ - . - . - . - - , , _

_

-

. . - . _ _ _ _ _

_ _ , _ _ - . . _ . -

-

.-____ - _____

.

38

-

G.

Outage Management

1.

Outage Management - Unit 1 (265 hours0.00307 days 0.0736 hours 4.381614e-4 weeks 1.008325e-4 months , 10*.)

i

!

Planning for the 1987 refueling outage began shortly after the con-

clusion of the 1985 outage.

Early planning helped to ensure that

critical items were included in the outage work package and that

long lead time procurements were initiated to avoid unnecessary

impact on the outage schedule.

This also smoothed pre-outage

,

'

schedule development and supported early identification of safety

significant issues.

Early and increasingly frequent formal outage

planning meetings, coupled with extensive multi-disciplinary at-

tendance and participation, aided in early problem identification

and resolution. These meetings also promoted interdepartmental

cooperation and the disciplined and cohesive team that existed at

the commencement of outage activities.

The licensee committed personnel and financial resources to computer-

based outage planning.

The detail provided by this system proved

to be a key to successful outage management. The flexibility of

the system was tested when senior management determined shortly be-

fore the outage that two weeks needed to be trimmed from the sched-

ule and outage commencement was reouired one week earlier than pre-

viously planned.

These changes were incorporated with minimal im-

pact.

Detailed outage activity reviews by the NRC concluded that

schedule compression and early commencement had not adversely im-

pacted work quality or proper attention to safety issues.

Outage staffing was designed to respond to the increased pace and

complexity of outage activities. Operations Department shift

staffing was increased to ensure adequate activity coverage and

coordination, and maintenance of a safety perspective.

Establish-

ment of an Outage Coordinator early in the planning phase strength-

ened the scheduling process. During the outage, the coordinator

providSd supervisory oversight of activities, plant evolutions and

,

l

conditions, and inter-departmental liaison. A management represen-

tative augmented Outage Coordination during the outage. This posi-

i

tion was filled on a shift basis by unit department heads and other

,

I

management level personnel.

This representative brought a manage-

ment perspective to outage activities and implemented problem iden-

tification, resolution, and expediting activities.

The overall

staffing plan proved highly effective in ensuring the quality of

safety-related activities.

I

Real-time management of outage activities was provided during regu-

larly scheduled twice-daily status meetings.

Current project pro-

gress as w?ll as an expanded time-base printout of the projected

events during a one week window was provided daily to supervisors.

Daily meetings were characterized by accurate assessments of work

in progress and resolution of conflicts.

Special meetings were

.

39

~

\\

-

!

'

I

scheduled as necessary to focus sufficient and appropriate resources

on specific problems.

During these meetings, the licensee displayed

9eration and a very positive attitude toward both nu: lear safety

e'

a..a high quality work. The Plant Operations Review Committee (PORC)

provided excellent oversight of outage activities and issues (IR

87-12, Detail 21). The inspector noted, however, that valuable PORC

time was spent reviewing routine procedure changes and other items

that could have been accomplished prior to the outage.

Although

a certain amount of such review is expected, efforts should be made

to clear routine work prior to outage commencement.

The success of outage planning was demonstrated by several activi-

ties which demonstrated excellence in outage coordination and the

licensee's maintenance of a safety perspective.

These examples

include: response to loss of Jet Pump

"K" flow indication as a re-

sult of installing new instrument no:zles; torus repair / painting;

Motor-Operated Valve Automated Testing System (MOVATS) testing dur-

ing initial implementation of the program; the lack of coordination

problems as evidenced by maintenance of proper plant conditions to

support outage activities; success of the Emergency Core Cooling

System (ECCS) Inte0 rated Test; and success of the Start-up Test

program.

A few isolated instances (e.g., ESF actuations) of less ef fective

control occurred during the outage.

The events appear as a minor

perturbations in a successful outage program. Overall, there was

good planning and oversight of outage activities.

Conclusion

Category 1.

Board Recommendations

None.

. .

_ _ _ _ _ _

_ _ _ _

_ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ .

______ _ _-

.

.-

40

'

2.

Outage Management - Unit 2 (280 hours0.00324 days 0.0778 hours 4.62963e-4 weeks 1.0654e-4 months ,10'o)

Previous licensee performance in this area was rated Category 1.

Cycle 8 pre-refueling activities were reviewed by the resident in-

spector during monthly pre-outage meetings.

Detailed planning for

major evolutions were reviewed in the areas of material availability,

personnel requirements, ALARA reviews, design change packages status

and the time allotment for the completion of each activities. Man-

agement involvement in the early planning stages contributed to a

well run 1936 refueling / maintenance outage.

Refueling and outage activities were reviewed, including refueling

or,erations, steam generator nondestructive testing, replacement of

the Turbine Building Closed Cooling Water (TBCCW) heat exchanger,

local leak rate testing, and replacement of the main condenser in-

ternals and associated feed heaters and piping.

The licensee outage management organization included twenty-four

hour coverage by outage coordination and senior licensed personnel

(Management Representatives), including shift supervision and staff

assistants on all shifts as Containment Coordinators. Dedicated

department coordinators and planners for I&C, operations, mainten-

,

ance, and Betterment Engineering were assigned to suoport operations.

Routine, twice-daily management meetings contributed to effective

]

control of the schedule and to the prompt identification of new

'

problems,

During the outage, critical activities that were not meeting sched-

ules were identified for resolution. Corrective actions were ap-

plied in the form of additional manpower, changes in jcb activities,

and additional shifts.

The Production Maintenance Management System

(PMMS) with its ability to address plant maintencnce activities in

the areas of boundaries, tag controls, activity status and required

recests contributed to ef fective tracking of major and minor repairs.

Major outage efforts involved steam generator nozzle dam installa-

tion and removal, secondary and primary side hydrolazing for reduc-

tion of exposure during ultrasonic testing of steam generators, the

4

1

replacement of the TBCCW heat exchanger, and the replacement of the

!

main condenser tubes (with titanium ones), tubesheets and condenser

end bells, and its associated heaters.

The new condenser tubes were

a critical path item.

Completien of this major projcct, which re-

moved copper-bearing material from feedwater systems, eliminated

a source of material for sludge formation in the secondary side of

the steam generators.

This program was ar. axcellent example of

i

management etfectiveness, initiative, and good control of the work

in a short outage.

All phases of engineerino, material acquisition,

'

1

and personnel planning were coordinated to ccmplete this project

j

en schedule.

Approximately 90'e of copper-contributing materials

i

,

,----_--,.-.--,..---r-,.

---e

. . - - . - - . - - _ . - - - . , - . , , , _ , , - - - , -

- -

_ _ _ .

_ _ _ _ _ _ _ _

_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

.

-

41

have been removed.

In addition, make up water modifications to

control secondary plant impurities to comply with EPRI guidelines

were completed.

Direct management supervision was excellent. Goals

for installation and retests were met.

The secondary water chemis-

try has since shown marked improvement in maintaining low concen-

trations of solids.

,

The licensee eddy current testing (ECT) of steam generator (SG)

tubes indicated a reduction in the number of needed tube repairs

'

(2S tubes plugged and 225 sleeves installed). Most defects were

between the top of the tuoesheet and the first tube support.

The

SGs were hydrostatically tested and found satisfactory.

SG local leak rate testing (Types B & C) during the outage identi-

fied leakage in excess of the technical specifications.

The licen-

see therefore increased the scope of repairs to renew T-ring seats

on butterfly valves during every other outage.

Post-outage pre-

critical, low power physics and power ascension tests were well

coordinated and performed, with active involvement of QA/QC,

!

The unit returned to power on December 19, 1936 and was shutdown

on January 29, 1987 due to primary to secondary leakage.

Subse-

quently, reanalysis cf steam generator ECT data, (see Surveillance,

Section IV.D of this SALP) revealed tube defects that should have

resulted in tube plugging. Additional analysis resulted in an 18-

l

day euttge for data review and plugging of an additional 91 tubes.

The NRC noted lapses in control of overtime during the January-

l

February 1937 outage: there nere seven examples of ovartir.i6 i r, c -

cess of established guidelines without the requisite management

approvals.

Licensee actions were responsive and will be reviewed

for effectiveness during the next SALP period.

This appeared to

be a minor deviation from the effactive program established to man-

age outage activitics.

Conclusion

Category 1.

Board Recommendations

<

None.

.

i

_

-

_.

_ _ . _ _ _ _ , _ _ . . _ _

_

_ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _

.-, _ _ _ . _ _ _ . . _ . . _ _

_ _ _ _ _ . -

_. ._

_ _ _ _ _ _ _ _ _ _

.

42

-

H.

Assurance of Quality - Unit 1

- Unit 2

Assurance of quality is addressed as a separate functional area even

though it is an evaluation criteria in the other functional areas.

The

defined quality assurance program is included, but the assessment pri-

marily addresses the effectiveness of licensee management efforts to

assure quality in day-to-day activities. Worker performance, attitudes,

involvement by supervisors, and the adequacy and use of management and

administrative controls were used as performance indicators.

High quality in the operating and outage activities for both units was

evident in good worker attitudes and pride in their work at all levels.

Procedures and administrative requirements were generally well estab-

lished and implemented by a qualified staff.

Plant personnel approached

their work with the idea of doing the job right the first time, and there

was good regard for the quality assurance function.

A professional attitude was exhibited by the operating departments at

all levels.

Safety conservatism was demonstrated in the resolution of

problems and in routine activities.

There was good regard for meeting

commitments anri regulatory requirements.

Site and corporate management

were effective, by example and leadership, in establishing safety as well

as efficiency as the goal of operations.

The Plant Operational Revie,e C:mmittees (PORC) fer both units functioned

as required by the Technical Specifications and the applicable procedure.

The licensee regards membership in the committee as a serious commitn.ent,

as evidenced by the attendance record.

The licensee's commitment to

conservatism and safety was displayed by ccmmittee review of completed

riedification onckages in addition to the safety evaluationi required by

Technical Specifications.

First line technical supervisors were actively involved with work in the

'

plants.

The effectiveness of this supervision was reflected in good

plant performance records, general success of operating activities, and

low rework in maintenance, testing, and modification activities. There

was a good regard for established administrative controls and a good

record of following plant procedures.

As noted in tne other functional areas, there are several areas where

improvements can be realized: reductions in Unit 2 trips, more effective

self-assessment by the security force, especially first line supervisors;

control of Unit I locked high radiation area doors, and the posting and

control of Unit I radiation areas.

Licensee management recognized the

problem areas, was responsive to NRC initiatives, and aggressively pur-

sued corrective actions.

The licensee's cuality assurance program for procurement control (pur-

chase, receipt, storage, and handling) was adequate, although additional

attention is needed to contrcl over shelf life for materials that age

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _

..

43

~

in storage.

Other aspects of material storage and control were adequate.

Access control, housekeeping and cleanliness in the warehouse, and re-

ceipt documentation were acceptable.

The licensee's audit program was comprehensive and included all facets

of plant operation.

The audits were planned and scheduled, and had well

organilec check lists.

They were in-depth and conclusive.

Research and

analyses of the QC inspection results history to prioritize QC surveil-

lance and to more effectively use resources was commendable. An auditing

improvement was also evident in the more frequent use of discipline

engineers to evaluate of the acceptability of completion of an activity.

This enhanced effectiveness of the QC function.

The design change program, though satisf actory, needed more attention

to documentation and recordkeeping.

Design change request packages con-

tained sufficient information but completed packages were disorganized,

records were misplaced and, in some cases, there wa', a lack of orderli-

ness. While Engineering provided thorough QC overview of the fuel con-

solidation project, in other engineering projects a lack of follow-up

was evidenced by the failure to adequately review the Unit 2 SG ECT data

and oversee the contr1ctors, by delayed resolution of the short hold-down

bolts for the Unit I low pressure ECCS pumps, and by weaknesses in EQ.

NRC review of the licensee's response to IEB 80-11,-Masonry Walls, found

the licensee's engineering and field activities technically thorough and

responsive.

A marked improvement was noted in radwaste transportation. Trequency

and scope of associated QA audits also improved.

Ongoing failures to comply with the submittal schedules established with

the NRC Licensing Project Manager adversely affected the performance

rating for Licensing Activities.

In summary, both plant management and staff were committed to high qual-

ity in operations as evidenced by effective implementation of the formal

QA function, diligent and conservative PORC sessions, and the general

success of operations and activities in direct support of operations.

However, significant inadequacies were noted in several engineering pro-

jects and in repeated failure to submit licensing amendments on a timely

basis.

Conclusion

ritegory 2.

M rd RecoSmendations

None.

_ _ - _ _

-

.

44

-

1.

Engineering Support

This is the first evaluation of this SALP functional area for Millstone

1 and 2.

The area encompasses technical activities in addition to those

provided by the operations, maintenance, and instrumentation and controls

(I&r' departments.

Northeast Utilities maintained an appropriately sized engineering staff

in both the operating company (NNECO) and the support company (NUSCO).

The NNECO engineering department included onsite reactor, mechanical,

and electrical engineering groups.

Each group has a NNECO engineer as

supervisor. Onsite groups reported to unit management; offsite groups

reported to management at utility headquarters. Additional technical

support was provided by the Production Test Group.

These electrical and

electronic technicians and enoineers, rainly concerned with generation

and distribution equipment, were used for complex troubleshooting and

repair problems.

The groups were composed of technically knowledgeable

personnel with skillful, seasoned supervision.

They exhibited persever-

ante and dedication while performing tasks correctly the first time.

Having the Engineering Supervisor and his assistants hold operator

licenses improved coordination with the operating staff.

Based on the inspection of the environmental qualification program, man-

agement involvement was inadequate, in that it had not recognized the

extent of the EQ effort.

Responsiveness to NRC environmental qualifica-

t

?- (EQ) iaitiatives was we J

An eva rle was the licensee letter dated

4

December 10, 1936, which addressed a comprehensive walkdown of Unit #2

EQ equipment, the resulting findings and the corrective actions.

To

determine the significance of the issues and the adequacy of the correc-

tive action, the inspectors asked for the supporting documents for the

corrective actions.

Two violations, one on wire nuts and the other on

spray pump motor terminations, resulted from this inquiry. The refer-

enced letter also incorrectly stated that the motor terminations were

replaced with NUREG ESB qualified terminations when the licensee used

Bishop splices (IR 87-15). Also, the licensee was unable to produce

auditable documentation on Limitorque wiring data af ter two days effort.

A third violation concerned inadequate qualification of Curtis 1.-type

terminal blocks in a Unit 1 valve operstor.

Further, the licensee did

not have an effective tracking program to follow-up on EQ issues raised

by NRC.

This resulted in lack of traceability of corrective actions on

management commitments to NRC in the EQ area.

Two licensee efforts to enhance the availability of preferred normal and

backup emergency power supplies were notable.

These were modifications

comoleted daring the 1986 outage to prov'de a 4 KV, Unit I to Unit 2

cross-tie capability to enhance the ability to handle a loss of offsite

pa.ersblackout event. AO:itionally, the licensee was coating the insula-

tors in the 345 KV switchyard to decrease sensitivity to salt water

Bu I

-.

.

'

45

spray, and developed a new controlled shutdown procedure with the Con-

necticut Valley Exchange (CONVEX).

Both of these efforts were positive

steps toward improved electrical power availability.

Appended Table 4 lists 11 forced power reductions and shutdowns (both

units) involving steam, condenser tube, and packing leaks; a generator

breaker trip, a stuck open pressurizer spray valve, and feedwater regu-

lating valve problems.

Some of these occurrences were attributed to

Engineering Support. Many had no SALP area assignment.

Nonetheless,

careful Engineering Support review of all such occurrences could prompt

changes beneficial to facility and Engineering Support performance.

1.

Engineering Support - Unit 1 (263 hours0.00304 days 0.0731 hours 4.348545e-4 weeks 1.000715e-4 months , 10%)

Millstone 1 had a generally strong engineering staff.

The extensive

work and effort put into each project was evident.

Support of major

outage design changes and projects was very good.

ISI/IST was very

gcod with a strong commitment to a quality program as evidenced by

.

'

Intergranular Stress Corrosion Cracking (IGSCC) and Pump and Valve

programs (IR 87-16).

Success of the fire orotection program (as evidenced by IR 87-19)

was due to thorough engineering work.

Voluntary establishment of

the General Electric Zinc Injection Passivation (GEZIP) system (IR

87-05) as supported by Engineering demonstrated a well planned

approach to and an innovative method for reducing drywell radiation.

Also, parallel engineering review of diesel fuel system design de-

ficiencies (IR 87-04) demonstrated a comprehensive and aggressive

,

program for early identification and processing of generic items.

'

There were delays in upgrading the electrical bus undervoltage

4

'

scheme in response to NRC degraded electrical grid voltage concerns.

The associated design change has been in the works since 1984, and

final installation was to have been in 1937.

Verification of the

design using the simulator revealed flaws, and implementation was

!

deferred. While timely resolution of this issue remains c concern,

engineering reviews of the issue showed effective use of simulator

<

i

ano the probabilistic risk assessment (PRA) process to thoroughly

evaluate proposed plant modifications.

<

l

Comprehensive review of generic issues was generally evident for

Service Information Letter (SIls), Information Notices (ins), NRC

Bulletins (IEBs), and INP0 notepad items .

These reviews were al-

,

most always in-depth analyses.

Often the issue pro'.ed to be not

i

applicable with the review raising other questions that were at-

,

tively pursued. An example was IN 85-45 on seismic II/I concerns

for incore flux mapping systems.

Although this IN was not applic-

able to Unit 1, licensee follow-up identified a comparable situation

of the Traversing Incore Probe (TIP) ball and shear valves being

,

mounted on the same "table" as the heavy shield box.

A seismic

,

!

,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

t

!

-

I

46

event could cause the whole table to fail, resulting in the poten-

i

<

tial loss of the associated containment isolation valves.

The lic-

ensee developed a design change to address this.

Some examples of

f

less satisfactory engineering support are noted below.

In 1984, NNECO identified the potential for short foundation bolts

'

for low Pressure Injection and Core Spray pumps.

NUSCO engineering

was slow to respond to associated site initiatives and slow to

i

a

recognize that the problem existed.

The presence of short bolts

was not confirmed and corrected until 1987.

.

The recurrence of main condenser tube leaks requiring frequent power

maneuvers to identify and repair needs design resolution (see Table

4A). A contributing cause for the August 1987 reactor scram was

the failure to incorporate appropriate new core design precautions

into the operating procedures.

These examples show the need for

.

better engineering support initiatives to resolve long standing,

l

recurrent problems, and to assure timely completion of design inputs

!

into operating controls.

[

l

s

i

Engineering incorrectly concluded that inoperable ADS check valves

!

(multiple common mode fcilures) were not reportable to the NRC.

This issue, which was issued as a violation in Inspection 87-33,

reflected a need for greater licensee sensitivity to reporting re-

quirements.

!

A review of Licensee Event Reports (LERs) showed that fifteen events

were the result of lack of follow-through by the technical staff.

,

For example, the inadequate fire coating of the diesel generator

'

ceiling, nonconforming foundation anchors for the low pressure

'

coolant injection and core spray systems, and failure to obtain a

Technical Specification change for removal of the low pressure in-

!

jection and core spray pump start logic permissive switches showed

a lack of thoroughness in engineering reviews.

Also, preventive

engineering reasures could have eliminated or reduced problems with

i

source range monitor drive relays affecting the intermediate range

eonitors and with Target Rock main steam line safety / relief valve

,

setpoint drift.

i

j

In summary, the engineering and technical support groups were com-

i

petent and actively involved in plant modifications, design im-

'

provements, and resolving problems.

The onsite and corporate eng-

L

'

ineering staffs exhibited an in-depth commitment to safety.

Cngi-

neering support effectiveness was clearly evident in the success

q

of the Appendix R program. While initiative was shown in the ad-

dressal of issues, improvements could be reali:ed in resolving

long-standing problems, and in assuring design inputs / changes are

correctly translated into operating procedures and the license.

.

'

\\

!

[

-

. . _. - . -

.

- _ - -

-

.

- - . - - -

-

- - -

-

. _ - _ __ _

_ _ _ _ _ _ _ _ _ _

i

l

.

47

-

Conclusion

Categcry 2.

Board Reconmendations

None.

I

. . .

_ _ _ _ _

_ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

._ . _ _ _

.

l

'

48

i

2.

Engineering Support - Unit 2_ (277 hours0.00321 days 0.0769 hours 4.580026e-4 weeks 1.053985e-4 months , 10%)

!

l

The onsite engineering department cont.isted of a department super-

visor and 20 engineers and technicians.

In general, they performed

in-depth reviews of information notices, bulletins, and vendor in-

formation.

These on-site engineers and technicians were thoroughly

knowledgeable and put safety concerns to the fore during projects

and day-to-day decision making.

The engineering staff generally

supported other unit departments effectively.

The NRC attendeu numerous plant operating review committees meetings

on design changes.

Engineering staff inputs were essential to

changes that reflected safety-significant commitments.

In addition,

the engineering department program for bslance of plant piping in-

spections led to repairs which allowed the unit to operate through

cycle eight with no leaks in any large bore piping on the extraction

steam, feedwater and condensate systems.

Examples of significant engineering staff actions were found in the

areas of fuel reconstitution and consolidation.

The fuel reconsti-

tution program was managed by the engineering staff and concisted

of a new approach to eddy current testing.

The vendor fuel was not

designed for reconstitution.

New techniques were used to rotate

fuel assemblies on end and replace failed fuel with stainless steel

rods.

Fourteen assemblies were reconstituted, with the engineering

staff monitoring all phases of the project.

The Engineering Department and Corporate Engineering successfully

ccmpleted a pilot Fuel Consolidation Pro; ram.

This project was

groundwork for extencing nuclear plant soent fuel pool capacity

throughout the nuclear industry.

Six fu4l assemblies were included

in the first successful "hot" demonstration of a 2:1 consolidation

process using irradiated assemblies.

Si> spent fuel assemblies were

consolidated into three storage boxes.

Engineering provided suc-

ressful designs and evaluations.

There were no procedural viola-

tions.

DuringthepreviousSAI.Pperiodthelicensee'sreviewofplantde-

sign changes was faulted due to a miswiring of pressurizer spray

controls.

During this SALP period, the NRC attended a number of

licensee design change reviews and found that the reviewers were

knowledgeable.

In-depth and technically sound discussions were

observed. On a number of occasions, design changes were sent back

for additional review.

Design changes that were safety significant

included the replacement of the

"C" Reactor Coolant Pump (RCP) motor

with one with a more reliable upper bearing design, installation

of a new control room computer while still maintaining control room

programs with the old computer in service, addition of a new fire

damper, and the previously described fuel reconstitution and pilot

fuel consolidation program.

___- __

_ _ - _ _ _

_ - _ -______-_- _____ _____ __ ____-________ ____ _ ______

__-__ _

_ __.____

!

4

l

-

49

Several fire protection problems are identified in Section IV. A,

Plant Operations. Also, as is evident from the Appendix R corres-

pondence, the licensee has not effectively resolved Fire Protection

and Safe Shutdown matters.

Six years after the Appendix R regula-

j

tion was issuea, the licensee was still submitting exemptions re-

,

vising their Fire Hazard Analysis and was still asking for issue

clarifications.

Installation records for components required for

r

shutdown showed that items such as emergency lighting that were to

be installed in 1933 were installed in late 1986 or early 1937.

<

Fire protection will require additional review after the 1938 outage.

1

The licensee has not been notably attentive to NRC fire protection

initiatives.

For example, the NRC issued Information fictices in

1933 concerning problems with the installation of fire dampers.

l

In 1936, the licensee issued an LER describing a fire damper in-

i

stallation problem.

This slow response could have been avo W d by

timely addressal of the ir. formation notices.

The licensee has conducted in-depth reviews on both minor and major

modifications.

Safety concerns and the effects of modifications

t

i

on operations were addressed. Management dispicyed awareness of

l

the significance of design changes that effected nuclear and balance-

,

of-plant operations.

l

Design changes that increased safety and reliability included: in-

!

-

stalling a pressuri:er pressure deviation alarm; placing a contain-

!

ment tendon grease pressurization system in service to eliminate

!

,

'

water intrusion; and a change to the electrical system to allow a

'

cross-tie between Unit 1&2 to supply shutdown power from an alter-

nate source.

Although numerou; projects were successfully completed by the engi-

neering staff, the steam generators were returned to service without

i

correction of tube defects,

In this case, the ECT data review

elements were not specified and depended on vendor review.

Results

t

review for tube defects did not include review of conflicting in-

terpretations, and faulty resolution of a conflicting interpretation

resulted in the start-up with tube defects in excess of repair cri-

teria.

The licenste aggressively took steps to correct this and

i

I

to eliminate further problems through a training program, with

,

l

testing, and with additional corporate hvolvement in determining

!

status of steam generators prior to their return to service.

Two reactor trips during the assessment perico were caused in part

by design deficiencies.

One involved an air line on the reheater

,

j

drain control valve that was not adequately supported (12/23/S6

scran).

The second involved the improper overcurrent trip setpoint

,

e plant electrical buses powering the preauri:er heaters.

Fol-

!

low-up acticns to identify and correct these deficiencies were

l

proper,

,

1

i

-

.

50

A problem with charging pump discharge blocks, which have continued

to exhibit cracking, has been addressed by obtaining three pre-

stressed (shot peoned) blocks. Also, the licensee is assessing the

feasibility of modifying the charging system by adding a fourth

centrifugal charging pump.

These are steps toward resolution of

this long-term problem.

A review of Licensee Event Reports (LERs) showed ten events were

the result of lack of follow-through by the technical staff.

For

example, technical suoport inadequacies were shown by inconsistency

of the reactor coolant pump requirements with the safety analysis

assumptions for Modes 3, 4, and 5, an error in the service water

flow through RBCCW heat exchanger FSAR Table, and inadequate fire

protection for charging pump supports in the main cable vault and

raceway.

In tummary, the engineering and technical support groups were com-

petent and actively involved in design modifications, plant im-

provements, and in resolving problems.

Good initiative was shown

in the fuel reconstitution program.

Engineering support resulted

in an acceptable Appendix R program, but improve-<nt was needed in

responding to NRC initiatives and achieving tinely resolution of

long-starding regulatory issues.

The onsite and corporate engi-

neering staffs exhibited an in-depth ccm.mitment to safety.

r

..s..t..

e

Category 2.

Board Reccemendations

None,

,

-

y

,,

7

-,

-

7-

-- -

-

- . _ _ _ - _ _ _ - _____ -

_ _ _ - _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ .

.

l

51

'

,

?

J.

Training Effectiveness - Unit 1

- Unit 2

l

During the previous SALP period, this area was rated as Category 2.

A

j

general strength was coted in training with the exception of training

in rad,(aste shipments.

That training has since been found to have been

improved substantially,

t

!

The effectiveness of training and qualification, as evidenced by the

. performance of licensee personnel, is integral to all aspects of plant

operation.

As such, the assessment of training effectiveness is compiled

!

from the assessments of the other SALP areas.

Major training areas included INPO accreditation, non-licensed staff

training, and licensed operator training. All applicable training pro-

,

i

grams for Millstone 1 and 2 were accredited by INP0 during the SALP

t

assessment period.

i

'

In this assessment period, there was evidence of increased emphasis by

licensee management on non-licensed technical training.

The licensee

'

increased the training staff and added and upgraded training facilities

,

l

in this aspect,

The licensee also implementec management changes in the

training organization to enhance its effectiveness.

'

Training effectiveness was demonstrated in many specific aspects includ-

ing local and :entainment integrated leak rate test programs, the emer-

,

.

gency plan and implementing procedures; the conduct of outage related

I

4

surveillances, maintenance, fuel shuffle and design change activities

and plant operating procedures and administrathe controls,

The licensee also instituted departmental Training Program Control Com-

l

i

mittees, each consisting of a first line supervisor and members of the

i

training staff. This allows better communication in establishing and

prioritizing training needs The licensee also provided intensified

i

s

training for first line supervisors, realizing that effective management

l

requires more than technical proficiency.

The training and requalification program for the security force was

!

generally well developed and implemented.

However, NRC-identified prob-

,

lems and the associated escalated enforcement action showed that addi-

[

-

tional attention was needed to assure the force is adequately trained

i

in basic program objectives and is capable of detecting deficiencies in

!

meeting those objectives.

)

i

Unit 1 management supoort of training and recognition of operator pro-

!

'

i

ficiency was evident.

Northeast Utilities developed an excellent train-

ing facility housing a modern plant specific simulator and the in-house

{

,

training staff. Management involvement in training was evident in their

j

j~

knowlecgeable discussions with NRC personnel, in their interaction with

<

the training staff, and in their observance of training activities.

!

i

.

. .. . ..--- _ _ _ . - ._ ,,._ - _, - , _ ,. _ _..._-._ _ ,~ -_ _ _ _ .-

-

_ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -

. _ _ _ _____-__-_____ __. - _ _ _ _ _ _ _ _ _ _ _ _ _ -

_ _ _ _ _

_____

.

52

-

Evidence of sound Unit I non-licensed technical training was observed

during this $ ALP period.

The maintenance department had a well trained

staff as evidenced by the absence of maintenance-related scrams or chal-

lenges to protective systems.

The maintenance department demonstrated

ef fective training in the repair of equipment associated with 10 CFR 50

Appendix R requirements.

Training of staff engineers effectively im-

proved the quality of LERs, as noted in the operations section.

In re-

sponse to NRC findings, the Instrumentation and Control Department ex-

panded its on-the-job training program and training on significant in-

dystry events.

A training inadequacy was identified when the unit scrammed in March 1987

while transferring reactor pressure control from the EPR to the MPR.

Subsequently, the operators routinely transferred pressure control be-

tween the regulators when routine power reductions were performed to

increase their experience with this manipulation.

There were no further

plant transients as a result of faulty EPRMPR transfers.

During this assessment period, the NRC administered replacement examina-

tions in December 1956 and September 1987 for Unit 1.

Nine senior reac-

ter operator (SRO) candidates, and nine reactor operator (RO) candidates

were examined.

Seven SRO and all RO candidates successfully completed

the examinations and were licensed.

During the Unit 1 1936 examination, the NRC identified some generic weak-

ness in the training program for licensed operators.

These weaknesses

were: 1) knowledge of location and use of drawings; 2) familiarity with

refueling interlocks; and 3) the use and interpretation of Technical

Specifications.

In 1987, the examiners noted proficiency in the use and

interpretation of Technical Specificatiers; drawing use and refueling

interlock knowledge were not identified as continuing weaknesses.

The simulator was a valuable asset in providing high quality training.

However, several problems were encountered during the 1937 simulator

examinations due to inadequacies in the cause and malfunction book and

failures of a computer board and an electrical power supply to a specific

panel,

The malfunction book did not include sufficient detail in de-

scribing the effects of certain malfunctions.

For example, loss of DC

power did not include recirculation pump trips as one of the effects.

The malfunction and cause book needed more management attention and re-

view.

Except for the simulator cause and malfunction book, the Unit I

training program was effective.

Sufficient management attention was

provided to further improve the program.

The licensee was generally

responsive to NRC initiatives, and effective corrective actions were

implemented to solve preolems.

Daring this assessment period, Unit 2 sponsored 17 candicates for hot

licenses, with 14 candidates recom*.erded for licenses.

Replacement ex-

aminatices were acministered in July 1986 and December 1986.

Nine senior

_ __ -__

_ _ _ _ _ _ __-. ________ _________ ___ ___ ______

_ _ _ _ - _ _ _

. _ _ _ _ _ _ _ - _ _ _ _

___ _ __

. _ _ _ _ _

.

53

i

reactor operator candidates were examined; eight passed.

Eight reactor

operator candidates were examined; six passed. Weaknesses noted in July

1986 were not found in December 1986.

In general, the overall perform-

ance in the operating exams was considered good. This indicated that

,

the training department was able to properly prepare personnel for their

operating licenses and took action to correct weak areas.

,

.

In December 1986, a training program inspection consisted of the parallel

grading of written examinations for 20*4 of the licensed operators and

audits of three simulator examinations and one oral examination. Overall,

,

q

the requalification program was found to be satisfactory with some minor

exceptions. The format of the simulator examinations did not allow for

l

adequate followup questioning to distinguish individual weaknesses from

group weaknesses.

In one isolated case, the program did not adequately

<

train the operators on the applicable Technical Specifications associated

with the remote shutdown panel.

This weakness was previously identified

during the 1985 requalification cycle.

Subsequent training was inade-

quate as shown by operator errors described in LER 86-07 relative to the

Technical Specifications for this panel.

The training department has

since acceptably addressed this area as demonstrated on the SR0 examina-

tion in December 19S6.

l

During the examinations, several procedures were found to have errors

i

or to conflict with other procedures.

These were discussed with the

licensee during the exit meeting in July 1986 and were corrected prior

to issuance of the examination report.

This demonstrated quick addressal

of NRC concerns. Overall, the operator training program was rated as

satisfactory based in the results of the replacement examinations and

he evaluation of the requalification program,

i

tvidence of good Unit 2 non-licensed technical training was observed

1

during this SALP period.

The maintenance department demonstrated effec-

tive training in the repair of equipment associated with 10 CFR 50 Ap-

pendix R requirements.

Training of staff engineers has effectively im-

4

!

proved the quality of LERs issued by the licensee, as noted in the

!

operations section.

The need for improvement in the training on fire

protection modifications was identified, in that some operators hao

problems locating safe shutdown equipment and removing certain breakers.

.

An extensive eddy current testing (ECT) training program has been insti-

tuted.

Cogni: ant site and corporate engineers have received additional

formal training and have formulated a training program for the ECT in-

spectors who will examine steam generators at the next outage. Manage-

mert commitments to ensure proper outage item repair to the committed

training programs have been reflected in good control of design changes.

In sLmmary, training effectiveness was demonstrated in the overall good

performance noted in the various functional areas, with -ignificantly

a

improved performance in the area of radwaste packaging and transportation.

!

i

}

4

m

. . ~

. .

.

s._

_ . - -_ _ _ _ _ _ . _ , _ . . . . _ . , . - , _ _ - _ _ _

. _ _ _ _ _ - _ _ _ _ _ _ - . _ _ _ _ - _ - _ _ _ - _ - _ _ _ _ _ _ _ - - _

_ _ _ _

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.-

8

i

-

i

!~

54

i

',

'

,

i

!

,

!

i-

j

Management support and ccmmitment to high quality training was demon-

!

)

strated in initiatives to improve the non-licensed training, and in the

j

success of the licensed operator and requalification programs.

-

.

>

3

L

.!

Conclusion

"

<

F

Category 1.

Board Recommendations

,

1

None.

i

f

i

t

i

!

g

4

d

,

a

i

b

?

-

i

\\

'

+

j

1

t

,

i

r

f

!

t

.

,t

-

.

>

I

4

,

N

I

d

i

l

~

i

l

t

!

.

"

,

4

i

!

I

>

!

f

i

!

'I

f

J

p

-

.

-

.

-

- - -

-

.

_

_ _ _ _

._

_ _ _ _ _ _ - _ _ _ _ _ _ _ - _ ___ ______ ___ _ ____ - _

_ _ _ _ _ _ .

,

55

-

K.

Licensing Activities

1.

Licensing Activities - Unit l_

Ouring the previous SALP period, the licensee was rated Category

1. Consistent. The previous SALP noted that the licensee continued

to show good management overview of licensing activities, which are

conducted by a competent staff with ready access to the various

technical resources that contribute to the effective resolution of

safety issues.

These activities were also supported by a 'aowl-

edgeable, experienced, and dedicatec plant operating staff. How-

ever, that SALP also noted that schedules for written commitments

should be improved.

At the beginning of the current SALP period, the licensing backlog

for Millstene I was 43 items, representing a mixture of licensee

and NRC staff initiatives. During the SALP period, 33 licensing

actions were completed including 13 amendments to the operating

license. A backlog of 41 items remained at the end of the SALP

period.

During the current SALP period, the licensee continued to to be

actively irvolved in the assurance of quality in licensing activi-

ties.

Most submittals by the Itcensee showed good evidence of prior

planning in that they were substantially complete and supported the

proposed licensing position. A good example of the licensee's prior

planning, as indicated in submittals to the staff, was the deter-

ministic ard probabilistic Integrated Safety Assessment Program

(ISAP) evaluations together with the licensee's proposed integrated

assessment of issues.

These submittals required not only good prior

planning for the individual issues, but also a substantive effort

in the preparation of the proposed integrated assessment of all

issues. Another example of prior planning was the Full Term Oper-

ating License, which was issued on October 31, 1986.

A third ex-

aeple was the December 24, 1956 application for a full 40 year

cperating license.

The licensee showed initiative by providing

corresponding information for Millstone Unit 1 if questions on a

similar license request was asked for by the staff for Millstone

Unit 2 or Haddam Neck.

Although most NRC/ licensee interactions were at the working level,

the licensee's upper manage *ent followed licensing activities and

became involved as needed. An example was licensee executive vice

president involverent in ISAP roetings with the NRC staff.

The licensee de onstrated a ce> ire for open and frank communication

with the NRC,

Licensee management participated in keeping the NRC

amare of current arc projected licensing activities.

_ __ _______ ______ _ __

_

l

,

-

,

l

!

56

i

-

i

l

With regard to the resolution of technical issues, at the conclusion

of the review of each licensing action (license amendment, exemption,

'

!

code relief, etc.) the adequacy of the licensee's technical exper-

tise was particularly evident during interactions with the staff,

j

An example was response to staff questions regarding the startup

,

>

)

of Millstone Unit I from its 1987 refueling outage with less than

all twenty jet pumps operable.

i

.

l

With regard to responsiveness to NRC initiatives, the licensee ex-

perienced problems in providing timely responses to NRC requests

for information during most of the current SALP period.

The licen-

l

-

see's tardiness in their submittals tended to slow the pace in a

3

l

number of key licensing actions.

In the case of changes to the

Technical Specifications for Primary Containment Isolation submitted

i

as a corrective action for a Region I Violation (50-245/87-05-01),

l

the submittal was unduly late since the violation cited the untimely

,

a

application for TS changes.

In another instance, the licensee

l

applied for a change to .he Technical Specifications to reflect the

r

deletion of the low pressure switches from the ea:ergency core cool-

!

i

ing system (core spray and Icw pressure coolant inspection) pump

i

,

{

start logic.

These switches were deleted during the 1987 refueling

outage and the request for technical specification changes was not

'

submitted until two conths after plant restart.

This delay was due

.

to an oversight by the licensee.

!

1

!

1

During the current SALP period, the NRL staff initiated its Safety

l

Issues Management System (SIMS) to improve tracking of Safety issues.

l

The licensee was responsive to the SIMS initiative and met with the

!

l

staff to help bring the Millstone 1 SIMS data up to date.

!

With regard to Staffing and Training, the licensee maintains a

l

I

cualified ano traired staff to pursue both the licensee and NRC

!

initiatives, recognizing the need to prioritize such initiatives.

l

<

I

As an example, the licensee's participation in ISAP has been out-

i

!

i

standing.

Their initiatives in probabilistic risk assessment have

l

provided greater in-house analysis capability that has provided the

j

plant operations staff with rew insights on the plant's vulnera-

l

bilities and strengths.

The licensee's staff continues to be active

!

3

in industry groups and, accordingly, its submittals tend to reflect

i

industry viewpoints in addition to their own.

l

,

i

,

{

In sumary, the licensee maintained i well--anaged and knowledgeable

!

licensing staff, but delayed the submittal of information needed

i

j

oy the NRC fo- resolution of safety issues.

In some cases, the

1

licensee requested delays in submittal dates. More often, however,

j

the licensee simply notified the NRC that their submittals wmid

'

be delayed.

I

f

i

,

4

._

. _ - - _ _

- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -

__

_ _ _ .

. . _ _

__ _

,

.

,

.

3

l

4

In dealing with the NRC, the licensee proved to be mostly coopera-

p

tive.

The licensee continued to maintain an informal policy which

!

permitted the use of licensing contacts with the NRC technical staff

!

with the knowledge of the NRC Project Manager.

l

r

<

Conclusion

[

,

Category 2.

!

, Board Recom.mendations

.

Licensee: The licensee should identify any needed schedule delays

l

to the NRC staff at regularly scheduled quarterly meetings

[

]

rather than adopt such delays unilaterally,

j

I

'

]

NRC:

The NRC staff should closely monitor the licensee's pro-

f

gress in meeting their licensing obligations and commit-

,

l

ments.

j

!

i

t

!

j

!

t

i

,

i

r

I

i

!

9

i

P

i

-

t

!

'

l

r

I

t

'

i

4

_ _ _ _ _ . . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _

,

i

ss

-

l

i

2.

Licensing Activities - Unit 2

i

_

During the previous SALP period, the licensee was rated as Category

1, consistent, in this functional area.

The previous SALP noted

,

that the licensee had demonstrated considerable technical capabili-

J

ties in licensing activities; however, the NRC staff expressed the

l

view that responses to NRC initiatives could be further improved.

l

i

At the beginning of the current SALP period, the licensing backlog

!

for Millstone Unit 2 was 30 items, representing a mixture of licen-

l

See and NRC staff initiatives. During the SALP period 31 licensing

items were completed including 11 license amendments. A backlog

l

of 17 licensing items remained at the end of the SALP period.

j

!

During the current SALP period, licensee management was actively

involved in the assurance of quality in licensing activities.

Most

l

submittals showed good evidence o,' prior planning in that they were

i

substantially complete and supported the licensee's licensing posi-

1

tion.

One exanple of the licensee's prior planning, as indicated

>

in a submittal, was the December 22, 1986 application concerning

a full 40 year operating licensee (OL); this submittal effectively

'

integrated economic, safety and environmental inputs. A similar

!

instance of good prior pir ning was the May 21, 1986 submittal con-

!

'

cerning consolidation of spent fuel, which was also actively re-

viewed during the current SALP period.

Although most NRC/ licensee interactions were at the working level,

the licensee's upper management followed licensing activities and

beca~e involved as neeced.

One example of the Itcensee's management

involvement was the Cecember 10, 1987 meeting on the 40 year OL

between the NRC staff and the licensee.

This meeting involved

active licensee participation at tne vice president level.

The licensee demonstrated a desire for open and frank comunication

with tne NRC.

Licensee management participated in keeping the NRC

aware of current and projected licensie.g activities.

With regard to the resolution of technical issues, at the conclusion

of each licensing action (license c endment, exemption, code relief,

etc.), the principal reviewer provided covents concerning the ace-

quacy of the licensee's techn: cal approach to the resolution of

safety issues.

These co m ents were generally favorable during the

current SALP period.

The licensee *s technical expertise was par-

ticularly evident during the March 5,1987 steam generator tube

leakage eeetinC ::aring which the licensee prescribed and interpreted

an extensive body of data on steam generator tube degradation.

During the SALP pericd, in July 1987, the NRC audited the safety

evaluations prepared by the licensee in support of facility changes,

tests and esperiments udertaken without prior commission approval.

. _ _ _ _ _ .

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - _ _ _ _ - _ - _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _

l

-

t

59

!

-

!

l

The licensee maintained adequate procedural controls to determine

i

the existence of unreviewed safety questions in accordance with 10

t

CFR 50.59. "changes, tests and experinents." The evaluation con-

-

cerning Plant Design Change Request 7-89-85 (Spent Fuel Pool Rerack

!

Project) was particularly noteworthy for its completeness and in-

l

depth evaivations.

s.

1

During this SALP period, it was decernined that the vital chilled

!

4

water system which provides cooling for the vital DC switchgear

[

rooms had been inoperable for moee than 3 years.

The associated

l

10 C R 50.59 safety evaluation was adequate but lacked detail and

rigor to support U

inued inoperability of the vital chilled

!

.

water system.

The

see stated that the vital chilled watJr

!

,

system safety eval

had been prepared prior to upgrading the

!

,

procedures for prc

ion of 10 CFR 50.59 safety evaluations, and

that the procedures cresently in ef fect are core thorough and com-

3

j

prehensive.

The NRC concurred with this.

l

-

With regard to responsiveness to NRC initiatives, the licensee ex-

i

perienced significant problems in providing

A.ly responses to NRC

l

requests for inforttiation during most of the w w t SALP period.

I

The licensee's tardiness in their submittals e

d to slow the pace

i

,

in a number of key licensing actions.

In one case, involving

l

,

l

c6.anges to the Technical Specifications associated with TMI Action

!

i

Items (Generic Letter 83-37), the licensee was over two years late

!

in responding.

)

TU weakest area, in terms of responsiveness during the current SALp

I

period, was the licensee's fire protect, ion program. During 1936,

i

the licensee alerted the staff that they would submit a revised 10

t

J

CFR Part 50, Appendix R analysis for Millstone Unit 2.

The NRC

!

staff eadn a number of attempts to encourage the licensee to make

l

i

a timely submittal in order to assurc that any needed exemptions

j

'

could be issued prior to a statutory due date which corresponded

l

to the end of the January 1937 refueling outaga.

Following the re-

t

i

fueling outage, a February 24, 1937 neeting was held at NRC Region

(

j

I to discuss the submittal schedule.

It was not until May 29, 1937

i

j

that the fire hatards analysis was submitted. The lateness of the

!

'

]

licensee's submittal prevented the NRC staff from fully utilizing

their resources during the subsequent fire protectie, inspection

,

i

at Millstone Unit 2 during the week of July 10-17, since no prior

]

review of the s';tmittal could be made.

(See Section IV.I, Engi-

!

neering Support, for assessment of the fire protection program.)

i

!

l

Near the end of the SALP period, prior to the refueling outage, the

i

)

licensee failed to submit licensing requests in a tirely manner.

i

These requests included two changes to the Technical Specifications

[

l

and an exemption associated with use of the "mass point" nethod for

t

!

)

calculati9g containment leakage. Although the licensee was aware

!

,

t

j

4

.

-

- - - - - -

-

,

-_

._~

__

_

._ ,.

.

60

of the need for these licensing actions well before the refueling

shutdown, they delayed their submittal, thus requiring expedited

,

review by the NRC staff.

By letter dated.May 12, 1987, the NRC staff directed the licensee's

-

attention to four reviews where the licensee was late in responding

to requests for information.

These reviews were:

Relief Valve and

Safety Valve Testing, Regulatory Guide 1.97, Secondary Wa:er Chemis-

try, and Reporting of Relief Valve and Safety Valve Failures and

challenges.

In the licensee's response dated June 15, Ic87, a

.

schedule was provided for the necessary information and i. commitment

'

-

was provided toward improving responsiveness in the futu'e.

Initial

indications were that responsiveness on the part of the licensee

'

had improved.

During the current SALP period, the NRC staff initiated its Safety

Issues Management System (SIMS) to improve its tracking of imple-

mentation schedules associated with safety issues.

The licensee

,

was responsive to the SIMS initiative and provided several SIMS up-

'

dates, most recently on Octo'oer 8, 1987.

With regard to Staffing and Training, the licensee maintained a

qualifies tr'd trained staff to pursue both licensee and NRC initi-

atives, rt Nnizing the need to prioritize these.

-

!

T h license 's staff continued to be active in industry groups, most

noticeably the Combustion Engineering Owners Group anc the S.ismic

,

Qualification Utility Group. Accordingly, the licensee' submittals

often reflected wider industry viewpoints in addition to those of

their own.

In suinmary, the licensee continued to maintain a well managed and

knowledgeable itcensing staff. During the SALP period, the licensee

has delayed the submittal of information required for resolution

of safety issues.

In some cases, the licensee requested delays in

submittal dates. More often, however, the licensee delayed submit-

tais on their own initiative without renegotiating the submittal

date with the NRC.

This has become a chronic problem.

In dealing with the NRC, the licensee has proved to be mostly co-

operative.

The licensee continued to maintain an informal policy

'

which permits the use of licensing contacts with the NRC which

,

exclude the NRC Project Manager.

Conclusion

Category 2.

s

5

._

. -

.. - .

-

' _. m .. __ _ _ L,.i!

m

.

61

-

Recommendations

Licensee: The licensee should identify any needed schedule delays

to the NRC staff at quarterly meetings rather than atopt

such delays unilaterally.

NRC:

The NRC staff should closely monitor the l'.eosee's pro-

gress in meeting their licensing obligat'ons and commit-

ments.

,

e

-

<m

n

,

we-

- - - -

. , -

--e,+v

- ---- - --- - - - -,--- 4

n

- - - --

-- ,

,

.

62

.

V.

SUPPORTING DATA AND SUMMARIES

A.

Supporting Data and Summaries - Unit 1

1.

Allegation Review

Allegations about Millstone 1 were:

--

Main steam check valve base plate attachments were inadequate.

' ' was unsubstantiated.

That an individual was fired for failing to submit to urin-

--

alysis testing upon being fired.

This was confirmed and found

to be consistent with licensee practice.

This individual also

alleged improper security badge usage by another person and

improper installation of a conduit hanger; these allegations

were unsubstantiatec.

--

That there was radioactive material in an unlabeled box outside

the radiological area, in the turbine building.

This was

unsuostantiated.

2.

Escalated Enforcement Actions

Civil Penalty

$25,000 - IR 87-22, Physical Security

3.

Management Conferences

--

On June 18, 1986, an enforcement conference was held at the

NRC Region I Office to discuss repetitive radwaste transporta-

tion problems.

On November 3, 1987, an enforcement conferenca war held at the

--

NRC Region I Office to discuss stction security violations.

4

Licensee Event Reports

a.

Tabular Licensing

Type of Events

A.

Personnel Error

24

l

B.

Design / Mfg / Construction / Install Error

21

'

C.

External Cause

2

D.

Defective Procedure

5

E.

Component Failure

12

X.

Other

_0

TOTAL

64

,

l

!

L

..

_-

,. , . = -

-

_

- _ - _ _ _ _ _

. _ _

.

63

-

A tabulation of Licensee Event Reports (LERs) by functional

i

area, and an LER synopsis, is attached as Table 3.

Licensee Event Reports Reviewed

!

(

LER Nos. 86-17'through 86-32 and 87-01 through 87-44

b.

Causal Analysis

Unit l'LERs 86-19, 86-29, 87-05, 87-08, 87-13, 87-24, 87-29

and 87-44 cover the standby gas treatment system; 3 events

concerned system activities due to spurious radiation signals,

and 1 event concerned an inoperable system due to personnel

error; 1 event concerned an incomplete surveillance test method.

LERs 86-28, 16-32, 87-21, 87-32 and 87-40 addressed degraded

performance of various safety systems due to drift of component

actuation setpoints.

LERs 87-04, 87-37, 87-39, 87-42 and 87-44 addrested surveil-

lance testing deficiencies; 3 events involved surveillance not

done on time; 2 events involve system tests that were incom-

plete when compared to the Technical Specification requirements.

LERs 87-08, 87-28, 87-31, 87-33, and 87-36 concern reactor trip

signals or ESF actuation signals caused during surveillance

testing by either technical error or procedure problems.

5.

Licensing Activities

a.

Exemptions Granted

Valve motor operators

06/08/87

--

Appendix R Sections III.G and III.J

06/17/87

--

Appendix J Section III.A.3

10/15/87

--

b.

License Amendments

Number

Title

111*

Fire Protection Audit

09/09/86

Full Term Operating License

10/31/86

--

1

Multiple Requests

01/29/87

2

Halon 1301 Fire Suppression System 02/20/87

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

64

-

3

Addition of Water Suppression

06/05/87

systems to TS 3.12.B.1

4

RWCV system Isolation Setpoint

07/17/87

5

Standby Liquid Control System

07/30/87

6

Cycle 12 Core Reload

08/06/87

7

Emergency TS Change - Jet Pumps

08/06/87

3

Control Rod Drive Removal

08/14/87

9

Revision to P-T Limits

08/20/87

10

Maintenance Responsibility for

09/01/87

Switchyard Batteries

11

Containment Primary Isolation

09/08/87

12

Main Steam Line Radiation Monitors 09/29/87

13

ECCS Pump Start Logic

12/17/87

"This amended the Provisional Operating License.

B.

Supporting Data and Summaries - Unit 2

1.

Allegation Review

Allegations about Millstone 2 were:

That a contractor employee was fired because of his past con-

--

tacts with the NRC.

The Department of Labor found in favor

of the alleger, and the employer appealed.

Hearing of the

appeal has been postponed for an extended perioc at the alle-

ger's request.

NRC review has found no indication of a licen-

see practice of discriminating against individuals.

That fire dampers are undersized.

This was unsubstantiated.

--

'

That Litton-Veam connectors are inadequate in. moisture sealing

--

characteristics.

No immediate safety implications were iden-

tified.

The allegation was referred to the vendor inspection

branch because of generic considerations.

That significant radiation exposures occurred during a spill.

--

This was unsubstantiated; the precipitating event appeared to

be a spill drill with no radioactive material involved.

_ _ _

__

- . . ,

_

. . . _ _ _

_

_ ~ . _ _ _

_.

.

-

65

That electrical tagging procedures were not followed for non-

--

safety-related activities, and that the contractor involved

did not follow procedures adequately.

The alleger has provided

later information which is still under evaluation.

No safety

inadequacy has been identified yet.

--

That plant access was denied because of incorrect security

information being supplied by the alleger about an arrest in-

volving marijuana.

This was confirmed and found to be a normal

and acceptable licensee practice.

--

That a person had the wrong security badge ana key card for

about 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This allegation is still being evaluated. No

significant security hazard has been identified.

2.

Escalated Enforcement Actions

Civil Penalties

$25,000 - IR 87-20, Physical Security

3.

Management Conferences

On June 18, 1986, an enforcement conference was held at the

--

NRC Region I Office to d scuss repetitive radwaste transporta-

tion problems.

On February 24, 1987, a management meeting was held at the NRC

--

Region I Office to discuss the Appendix R status for Unit 2.

On November 3, 1987, an enforcement conference was held at the

--

NRC Region I Office to discuss station security violations.

4.

Licensee Event Reports

a.

Tabular Licensing

Type of Events

A.

Personnel Crror

20

B.

Design / Mfg / Construction / Install Error

13

C.

External Cause

2

D.

Defective Procedure

1

E.

Component Failure

17

X.

Other

TOTAL

53

A tabulation of Licensee Event Reports (LERs) by functional

area, and an LER synopsis, is attached as Table 3.

.

66

-

Licensee Event Reports Reviewed

LER Nos. 86-03 through 86-23 and 87-01 through 87-13.

b.

Causal Analysis

Unit 2 LERs 86-03, 86-07, 86-11, 87-01, 87-10 and 87-13 cover

deficiencies in the fire protection program and equipment used

for hot shutdown; 5 of the events are attributable to either

equipment failure (s) or personnel error (s).

LERs 36-04, 86-05, 86-17, 86-20 and 86-22 concern reactor trips

and/or loss of normal power events; 4 of the events resulted

from personnel errors.

5.

Licensing Activities

a.

NRR/ Licensee Meetings

Steam Generator Tube Inspection

11/24/86

--

Steam Generator Tube Leakage

3/05/87

--

Forty year Operating License

12/10/87

b.

NRC Site Visits

Plant tour and Training for site access

6/22/86 - 6/25/86

SALP Meeting

10/02/S6

Inspect Diesel Generators

4/5/87 - 4/10/87

Audit of 10 CFR 50.59 Analyses

7/13/87 - 7/17/87

Inspect' Service Water System

10/25/87 - 10/30/87

In>pect implementation of SIMS item

11/29/87 - 12/04/87

c.

Reliefs Granted

Inservice Testing of Emergency Diesel

11/02/86

Generator Auxiliaries

(ASME Code,Section XI)

d.

Exemptions Granted

Fire Protection - Emergency

1/15/87

Lighting (10 CFR Part 50, Appendix R,

Section III. J)

. _ . - _ - .

.

_

_ -

,

_

..

- ,.

_.

.

-

67

9

License Amendments Issued

Amendment

Title

Date

112

Fire Protection Audits

9/9/86

113

Cycle 8 Reload

11/8/86

114

Spent Fuel Pool

12/19/86

Temperature

115

Iodine Spikes

2/3/87

116

Number of Reactor Coolant 4/21/87

117

Spent Fuel Consolidation

6/2/87

118

Snubbers

3/1/87

119

Reporting of RV and SV

9/25/87

Failures, Secondary Water

Chemistry, Control Rcom

Leakage

120

GL83-37 (TMI Technical

9/28/87

Specification)

121

Plugging Limit for Sleeved

SE Tubes

11/13/87

122

Cycle 8 Coastdown

11/18/87

,

.

TABLE 1

INSPECTION HOUR SUMMARY

MILLSTONE 1

AREA

HOURS

?; 0F TIME

PLANT OPERATIONS

1019

38.2

RADIOLOGICAL CONTROLS

297

11.1

MAINTENANCE

174

6.5

SURVEILLANCE

438

16.4

EMERGENCY PREP

138

5.2

SEC/ SAFEGUARDS

77

2.9

OUTAGE MANAGEMENT

265

9.9

TRAINIi4G EFFECTIVENESS

ASSURANCE OF QUALITY

ENGINEERING SUPPORT

263

9.8

TOTALS:

2671

100.0

INSPECTION H0JR SUMMARY

MILLSTONE 2

AREA

HOURS

% OF TIME

PLANT OPERATIONS

1065

39.5

RADIOLOGICAL CONTROLS

265

9.8

MAINTENANCE

181

6.7

SURVEILLANCE

397

14.7

EMERGENCY PREP

148

5.5

SEC/ SAFEGUARDS

84

3.1

OUTAGE MANAGEMENT

280

10.4

TRAINING EFFECTIVENESS

ASSURANCE OF QUALITY

ENGINEERING SUPPORT

277

10.3

TOTALS:

2697

100.0

The inspection hours for these composite assessments are incorporated in the 8

functional areas.

T-1-1

_ _ . _ _

.

_..

.

. . -

_.

.

P

.

TABLE 1A

SYN 0PSIS OF INSPECTION REPORTS

MILLSTONE UNITS 1 AND 2'

'

REPORT NUMBERS

UNIT I

UNIT 2

TYPE

TOTAL

INSPECTION DATES

INSPEC,

HOURS

DESCRIPTION

86-09

RESIDENT

308

PLANT OPERATION, SURVEILLANCE, MAINTENANCE,

5/20-7/7/86

MAIN TURBINE INSPECTION, AND STATIC "0"

RING DIFFERENTIAL PRESSURE SWITCHES

SPECIALISI

104

RESPONSE, SUBSEQUENT ANALYSIS AND MODIFI-

86-10

-

6/23-27/86

CATIONS OF MASONRY WALLS IN RESPONSE TO

IE BULLETIN 80-11, MASONRY WALL DESIGN-

86-10

SPECIALIST

0

OPERATOR LICENSING EXAMINATIONS OF 8 SRO

-

'7/7-11/86

AND 7 R0 CANDIDATES

86-11

SPECIALIST

48

RADI0 CHEMICAL MEASUREMENTS PROGRAM USING

6/2-6/86

REGION I MOBILE RADIOLOGICAL MEASUREMENT

LABORATORY

,

l

86-12

SPECIALIST

54

PERSONNEL RADIATION TRAINING AND QUALIFI-

7/7-11/86

CATIONS, EXPOSURE CONTROL, SURVEYS, AUDITS,

ALARA, PREVIOUSLY IDENTIFIED ITEMS

t

86-13

RESIDENT

190

PLANT OPERATION, SURVEILLANCE, MAINTENANCE,

'

7/8-8/18/86

RADIATION PROTECTION, PHYSICAL SECURITY,

FIRE PROTECTION, IE BULLETINS

86-14

SPECIALIST

31

SURVEILLANCE TESTING AND PROCEDURES, CALI-

-

,

7/7-11/86

BRATION CONTROL, QA/QC CONTROL INTERFACES

'

AND PREVIOUS INSPECTION FINDINGS

!

86-14

86-15

SPECIALIST

36

NOTIFICATION AND COMMUNICATION EQUIPMENT,

7/7-10/86

PROCEDURES, FOLLOW-UP OF EMERGENCY PRE-

PAREDNESS ITEMS FROM PREVIOUS INSPECTIONS

t

86-15

86-16

SPECIALIST

40

IMPLEMENTATION OF INTEGRATED SITE SECURITY

-

7/14-18/86

PROGRAM

>

-

86-16

86-17

SPECIALIST

70

QUALITY ASSURANCE PROGRAMS FOR RECEIPT /

7/21-8/8/86

STORAGE & HANDLING OF FUEL, PROCUREMENT

'

CONTROL, PLANT DESIGN CHANGES, MODIFICA-

TIONS

l

T-1A-1

l

[

_

.~

- - .

._.

_

- _ - -

_

___

._-

-

1

s

Table 1A

-

.

REPORT NUMBERS

4

UNIT 1

UNIT 2

TYPE

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

86-18

SPECIALIST

57

PREPARATIONS FOR REFUELING INCLUDING NEW

-

8/11-14/86

FUEL RECEIPT AND TRAINING FOR REFUELING

86-17

86-19

RESIDENT

91

OPERATION, SURVEILLANCE, MAINTENANCE,

8/18-9/29/86

RADIATION PROTECTION, SECURITY, FIRE PRO-

TECTION, IE BULLETINS, & U-1 STANDBY GAS

TREATMENT SYSTEM

86-18

-

SPECIALIST

33

MAINTENANCE PROGRAM AND PROCEDURES, ELEC-

'

9/22-26/86

TRICAL, MECHANICAL AND INSTRUMENTATION

MAINTENANCE TASKS, QA/QC CONTROL INTERFACES

-

86-20

SPECIALIST

45

MANAGEMENT CONTROLS, PERSONNEL SELECTION,

10/6-10/86

QUALIFICATION & TRAINING, EXTERNAL EXPOSURE

'

CONTROL, ALARA

86-19

86-21

RESIDENT

271

0-1 OPERATIONAL SAFETY AND MAINTENANCE:

'

9/30-11/3/86

U-2 REFUELING OUTAGE INCLUDING REFUELING

OPERATIONS, LOCAL LEAK RATE TESTS, SAFETY

VALVE TESTING

i

86-20

SPECIALIST

0

CANCELLED

-

10/19-11/20/86

1

-

86-22

SPECIALIST

0

OPERATOR LICENSING EXAMINATION OF ONE R0

12/16/86-1/30/87

AND ONE SR0 CANDIDATES

86-21

SPECIALIST

0

OPERATOR LICENSING EXAMINATIONS OF 9 R0

-

12/5/86-2/15/87

AND 2 SRO CANDIDATES

86-22

86-23

RESIDENT

243

PLANT OPERATION, OUTAGE ACTIVITIES, SUR-

11/4/86-1/5/87

VEILLANCE, PERIODIC REPORTS, AND MAINTENANCE

86-24

SPECIALIST

34

EDDY CURRENT TESTING OF STEAM GENERATOR

-

11/3-7/86

TUBES INCLUDING ISI PROCEDURES, EQUIPMENT,

'

QUALITY CONTROL MEASURES, DATA COLLECTION

.

1

i

RECORDS

'

-

86-25

SPECIALIST

0

OPERATOR LICENSING REQUALIFICATION PROGRAM

,

11/12/86-1/31/87

AUDIT

f

'

86-23

86-29

SPECIALIST

82

OBSERVATION OF LICENSEE'S ANNUAL EMERGENCY

11/18-21/86

PREPARE 0 NESS EXERCISE OF 11/19/86 AND IN-

GESTION PATHWAY EXERCISE OF 11/20/86

,

i

l

T-1A-2

,

l

. , _ . _ _ _ , _ _ _ . . _ _ . _ _ _ _ - _ . _ _ _ _ . . _ _ _ _ _ _ _ . _ _ . _ , _ _ _ _ . _

,

'o

Table 1A-

REPORT. NUMBERS

-UNIT 1

UNIT 2

TYPE-

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

86-24

86-26

SPECIALIST

26

NON-LICENSED STAFF TRAINING PROGRAM

11/17-20/86

86-27

SPECIALIST

100

LICENSEE RESPONSES, SUBSEQUENT ANALYSES

-

12/8-12/86

AND MODIFICATIONS OF MASONRY WALLS RELATED

TO IE BULLETIN 80-11, MASONRY WALL DESIGN

86-28

' SPECIALIST

22

TEST WITNESSING AND PRELIMINARY RESULTS

-

12/2-5/86

EVALUATION OF LOCAL LEAK RATE TEST, PRE-

VIOUS ITEMS, COMMITMENTS FOR CONTAINMENT

ISOLATION VALVE PM

86-25

86-30

SPECIALIST

18

0FF-SITE REVIEW COMMITTEE (NUCLEAR REVIEW

12/1-5/86

BOARDS) ACTIVITIES

86-31

SPECIALIST

67

CYCLE 8 STARTUP PHYSICS TESTING INCLUDING

-

12/8-17/86

REVIEW 0F TEST PROGRAM, PRECRITICAL TESTS,

& LOW POWER PHYSIC TESTS

86-26

86-32

SPECIALIST

4

DEGRADED PROTECTIVE AREA BARRIER AND

12/11-12/86

LICENSEE'S CORRECTIVE ACTIONS

87-01

RESIDENT

117

PREVIOUS ITEMS, U-2 SHUTDOWN, IE INFORMA-

1/6-2/9/87

TION NOTICES AND BULLETINS, U-1 LERs,

ELECTRICAL BUSWORK INSULATION, OPERATOR

REQUALIFICATION

87-02

SPECIALIST

8

PROTECTION OF SAFEGUARDS INFORMATION IN-

^

1/27-29/87

CLUDING THE USE OF REQUIRED REPOSITORIES

AND HANDLING PROCEDURES

87-03

RESIDENT

201

PREVIOUSLY IDENTIFIED ITEMS. U-1 STANDBY

2/10-3/9/87

GAS TREATMENT INITIATION, U-1 EMER SERVICE

WATER, U-1 APRMS, PORC, U-2 FIRE PROTECTION

MEETING

-

87-04

SPECIALIST

29

EDDY CURRENT EXAMINATION OF STEAM GENERA-

2/3-6/87

TOR TUBES, PREVIOUSLY IDENTIFIED ITEMS,

INSERVICE INSPECTION DATA

87-04

87-05

RESIDENT

221

OPERATIONAL SAFETY, U-2 FUEL RECONSTITUTION,

3/10-4/13/87

U-1 ESF ACTUATION, U-1 TRIP, NEW RAD WASTE

TREATMENT, EDG FUEL OIL SUPPLY, PORC, RE-

PORTS

T-1A-3

.

Table 1A

-

REPORT NUMBERS

UNIT 1

UNIT 2

TYPE

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

87-05

-

RESIDENT

164

PLANT OPERATION, SURVEILLANCE, MAINTENANCE,

4/14-5/18/87

RAD PROTECTION, SECURITY, FIRE PROTECTION,

NEW FUEL RECEIPT, ZINC INJECTION TRIAL

PROGRAM

-

87-06

RESIDENT

111

PLANT OP, RAD PROTECTION, SECURITY, FIRE

4/14-5/18/87

PROTECTION, SURVEILLANCE / MAINTENANCE,

DIESEL GENERATOR, AUXILIARY FEEDWATER, TRIP

REVIEWS

87-06

87-07

SPECIAL(ST

22

SECURITY PROGRAM RECORDS, REPORTS, PHYSICAL

2/23-27/87

BARRIERS, PROTECTIVE AREAS, POWER SUPPLIES,

ACCESS CONTROL, DETECTION AIDS, ALARM

STATIONS

87-07

SPECIALIST

35

WATER CHEMISTRY CONTROL PROGRAM INCLUDING

-

2/23-27/87

MANAGEMENT CONTROL, PLANT CHEMISTRY SYSTEM,

SAMPLING / MEASUREMENT, PROGRAM IMPLEMENTA-

TION

87-08

SPECIALIST

34

SOLID RAD WAS'.E CLASSIFICATION, HANDLING,

3/9-13/87

AND TRANSPORiATION, RAD ENVIRONMENTAL

MONITORING, RAD CHEMICAL ANALYSIS, AND

CHEMICAL QA CONTROL

87-09

SPECIALIST

96

MAINTENANCE, TESTING, RECORDS, PROCEDURES,

-

4/20-24/87

AND FLOW OISTRIBUTION OF ASME BOILER AND

PRESSURE VESSEL CODE, APPENDIX J, AND CHECK

VALVE DISK

-

87-09

SPECIALIST

30

MAINTENANCE ORGANIZATION, PROGRAM, ACTIVI-

3/16-19/87

TIES, MEASURING AND TEST EQUIPMENT, TROUBLE

REPORTING, INSULATION DEGRADATION, QA/QC

INTERFACES

87-10

SPECIALIST

16

BI0 ASSAY WHOLE BODY COUNTING PROGRAM IH-

5/18-20/87

CLUDING RESULT COMPARISON, PROCEDURE REVIEW,

DATA COMPARISON

RESIDENT

136

PLANT OPERATION, SURVEILLANCE, MAINTENANCE,

87-11

-

5/19-6/22/87

RADIATION PROTECTION, PHYSICAL SECURITY,

FIRE PROTECTION, OUTAGE PREPARATION, AL-

LEGATION

T-1A-4

,

. _ .

.

. ..

.

.- .

-

. .

.

Table 1A

-

REPORT NUMBERS

'

UNIT 1

UNIT 2

TYPE

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

87-11

RESIDENT

122

PLANT OPERATION, SURVEILLANCES, APPENDIX

-

,

5/19-6/29/87

R MODIFICATION, CONTROL BOARD ENHANCEMENT,

'

ALLEGATION RESPONSE, STEAM GENERATOR AN-

ALYSES

87-12

RESIDENT

183

PREVIOUS ITEMS, PLANT OPERATIONS, SURVEIL-

-

6/23-8/10/87

LANCE, MAINTENANCE, RADIATION PROTECTION,

PHYSICAL SECURITY, FIRE PROTECTION, ALLE-

.

'

GATION, EFS-

87-13

87-12

SPECIALIST

21

EMERGENCY PREPAREDNESS PROGRAM

'

6/29-7/2/87

,

87-14

-

SPECIALIST

65

SURVEILLANCE.AND CALIBRATION PROGRAM IN-

7/20-24/87

CLUDING CALIBRATION TESTING, CONTROL OF

MEASUREMENT AND TEST EQUIPMENT, QA/QC

INVOLVEMENT

,

87-13

RESIDENT

93

OPERATIONAL SAFETY, UNIT TRIP, PORC REVIEW,

l

-

.

6/30-8/17/87

SPENT FUEL POOL DIVING, AUXILIARY FEE 0 WATER

'

SURVEILLANCE, DIESEL SURVEILLANCES, PRE-

,

{

REFUELING

87-14

SPECIALIST

40

STEAM GENERATOR SURVEILLANCE, PREVENTIVE

-

i

7/6-10/87

MAINTENANCE ACTIVITIES, ACTIONS ON PRE-

3

VIOUSLY IDEl;TIFIED NRC ITEMS

f

!

87-15

87-17

SPECIALIST

117

RADIATION PROTECTION ACTIVITIES ASSOCIATED

l

7/6-10/87

WITH UNIT 1 OUTAGE, INTERNAL AND EXTERNAL

EXPOSURE CONTROL, ALARA, POSTING, LABELING

l

87-16

SPECIALIST

36

ISI ACTIVITIES, AUGMENTED EXAMINATION PRO-

-

i

7/6-10/87

GRAM FOR INTEGRATED STRESS CORROSION CRACK-

ING, AND BALANCE OF PLANT EROSION / CORROSION

'

.

l

PROGRAM

l

87-17

87-15

SPECIALIST

56

FOLLOW UP ON EQUIPMENT QUALIFICATION IN-

[

7/15-20/87

INSPECTIONS 50-245/85-30 AND 50-336/85-35

l

'

l

INCLUDING CORPORATE FILES, CORRECTIVE AC-

l-

TIONS, AND VERIFICATION OF CONFORMANCE WITH

l

10 CFR 50.49

,

!

87-16

SPECIALIST

154

TEAM INSPECTION OF THE LICENSEE'S EFFORT

-

j

7/13-17/87

TO COMPLY WITH 10 CFR APPENDIX R. SECTIONS

'

III.G, J, AND 0 CONCERNING SAFE SHUTDOWN

AFTER A FIRE

!.

!

T-1A-5

'

r

h

,_._--.-..._,-_._,,__,,_-_.-,--_..,_,m.._,,__

.

.__-_,_-_-.m,_.-_...

. , -

.

. . - -

.

..

. _ _ -

.-.

. -

-

.

- -

Table IA

REPORT NUMBERS

'

UNIT 1

-UNIT.2

TYPE

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

,

87-18

SPECIALIST

73

CONTAINMENT INTEGRATED LEAK RATE TEST WIT-

-

j .

7/31-8/7/87

NESSING AND PRELIMINARY RESULTS EVALUATION

<

87-19

SPECIALIST

116

TEAM INSPECTION OF THE LICENSEE'S EFFORT

-

8/17-21/87

TO COMPLY WITH'10 CFR APPENDIX R, SECTIONS

III.G, J, AND 0 CONCERNING SAFE SHUTDOWN

AFTER A FIRE

87-20

87-18

SPECIALIST

36

RADI0 ACTIVE EFFLUENT CONTROL PROGRAM,

8/24-28/87

LIQUID AND GASE0US WASTE SYSTEMS, PROCESS

RAD MONITORING AIR CLEANING SYSTEMS, AND

AUDIT ACTIVITIES

87-21

-

RESIDENT

89

PLANT OPERATIONS, MAINTENANCE, SURVEILLANCE,

'

8/11-9/8/87

RADIATION PROTECTION, PHYSICAL SECURITY,

,

FIRE PROTECTION, PERIODIC AND SPECIAL

REPORTS

j

87-22

87-20

SPECIALIST

78

PROCEDURES, ORGANIZATION, PROGRAM AUDITS,

!

8/31-9/4/87

AND REPORTS, TESTING AND MAINTENANCE,

!

PHYSICAL BARRIERS, LIGHTING, ACCESS CONTROL,

'

SECURITY AIDS

,

'

87-23

SPECIALIST

0

OPERATOR LICENSING EXAMINATION OF 7 SR0

-

9/21-10/25/87

CANDIDATES

j

i

87-24

87-21

SPECIALIST

36

STATUS OF PREVIOUSLY IDENTIFIED ITEMS Rr_

i

9/14-24/87

LATED TO THE CAPABILITY FOR POST-ACCIDENT

.

SAMPLING, MONITORING, AND ANALYSIS

87-25

87-19

RESIDENT

95

OPERATIONAL SAFETY, AN ALLEGATION, U-1 CON-

l

8/18-9/25/87

TROL ROOM HALON TESTING, FAILURE OF U-2

'

-

!

DIESEL GENERATOR TO LOAD. U-2 CONTROL R00

!

ANOMALIES

87-26

87-22

SPECIALIST

100

ANNOUNCED EMERGENCY PREPAREDNESS TEAM IN-

10/7-9/87

SPECTION AND OBSERVATION OF THE LICENSEE'S

l

ANNUAL EMERGENCY EXERCISE PERFORMED ON

,

10/8/87

r

87-27

87-23

RESIDENT

114

FOLLOW UP ON PREVIOUS FINDINGS, PHYSICAL

l

9/26-10/26/87

SECURITY, PLANT OPERATIONS, DIESEL GENERA-

l

TOR TRIPS, SURVEILLANCE, MAINTENANCE,

FEEDWATER HYOROGEN INJECTION TESTING, AND

2

IE BULLETIN 87-01

.

,

T-1A-6

l

'

-

Table 1A

REPORT NUMBERS

UNIT 1

UNIT 2

TYPE

TOTAL

INSPECTION DATES

INSPEC

HOURS

DESCRIPTION

87-28

87-24

SPECIALIST

56

NON-RADIOLOGICAL CHEMISTRY PROGRAM INCLUD-

11/2-6/87

ING MEASUREMENT CONTROL AND ANALYTICAL

PROCEDURE EVALUATION

87-29

-

SPECIALIST

0

CANCELLED

11/3-20/87

87-30

87-25

RESIDENT

138

FOLLOW-UP ON PREVIOUS FINDINGS, SECURITY,

10/27-11/30/87

OPERATIONS, SERVICE WATER OPERABILITY, DC

SWITCHGEAR VENTILATION, UNIT 2 TRIP, SUR-

VEILLANCE, COMMITTEE ACTIVITIES, CONTROL

ROOM VENTILATION, FUEL ASSEMBLY PRESSURE

DROP TEST, AND LERS

87-31

87-26

SPECIALIST

16

PRIMARILY UNIT 3 OUTAGE INSPECTION, BUT

11/16-20/87

WITH SOME UNIT 1 AND 2 REVIEW OF TRAINING,

AND INTERNAL AND EXTERNAL EXPOSURE CONTROL

87-32

87-27

SPECIALIST

103

COMPLEX SAFETY-RELATED SYSTEM, IN-PLANT

11/30-12/4/87

INSTRUMENT CALIBRATION, MEASURING AND TEST

EQUIPMENT, COLD WEATHER PREPARATION, QUAL-

ITY CONTROL INTERFACES

-

87-28

SPECIALIST

14

STEAM GENERATOR EDDY CURRENT INSPECTION,

11/30-12/4/87

WATER CHEMISTRY CONTROLS, RADIOLOGICAL CON-

TROLS DURING STEAM GENERATOR INSPECTION /

REPAIR

87-33

87-29

RESIDENT

159

PREVIOUS INSPECTION FINDINGS, PHYSICAL

12/1-31/87

SECURITY, PLANT OPERATIONS, IMPLEMENTATION

OF LICENSE AMENDMENTS, IE BULLETIN 87-02 -

FASTENER TESTING, SURVEILLANCE TESTING,

SCRAM OISCHARGE VOLUME MODIFICATIONS, COM-

MITTEE ACTIVITIES, AND LICENSEE EVENT RE-

PORTS

87-34

87-30

SPECIALIST

29

SOLID RADWASTE AND TRANSPORTATION PROGRAM

12/7-11/87

INCLUDING MANAGEMENT CONTROL, SHIPMENTS

OF RADIOACTIVE MATERIALS, TRAINING, PRO-

CESSING, PACKAGE SELECTION AND QUALITY

CONTROL

87-35

-

SPECIALIST

34

LICENSEE'S RESPONSE TO GENERIC LETTER 84-11,

12/14-18/87

INTERGRANULAR STRESS CORROSION CRACKING

OF BWR RECIRCULATION SYSTEM AND ASSOCIATED

PIPING

T-1A-7

.

TABLE 2

ENFORCEPENT SUMMARY

MILLSTONE 1 VIOLATIONS

SEVERITY LEVEL

AREA

1

2

3

4

5

DEV

TOTAL

PLANT OPERATIONS

1

2

3

RADIOLOGICAL CONTROLS

2

MAINTENANCE

SURVEILLANCE

1

EMERGENCY PREP

SEC/ SAFEGUARDS

1

2

3

OUTAGE MANAGEMENT

TRAINING EFFECTIVENESS

ASSURANCE OF QUALITY

ENGINEERING SUPPORT

1

TOTALS:

1

5

4

11

MILLSTONE 2 VIOLATI QS

SEVERITY LEVEL

AREA

1

2

3

4

5

DEV

TOTAL

PLANT OPE.ATIONS

1

RADIOLOGIJAL CONTROLS

MAINTENANCE

SURVEILLANCE

EMERGENCY PREP

SEC/ SAFEGUARDS

1

2

3

OUTAGE MANAGEMENT

1

TRAINING EFFECTIVENESS

ASSURANCE OF QUALITY

ENGINEERING SUPPORT

2

4

TOTALS:

1

5

3

9

.

T-2-1

_

.

_,_

.

_. _ . _

.

..

.

. _ . _

.

a

'

.

TABLE 2A

SYNOPSIS OF VIOLATIONS -

MILLSTONE 1 AND 2

REPORT NUMBERS

^

-

UNIT 1

UNIT 2 REQUIREMENT SEVERITY FUNCTIONAL

'

,

INSPECTION DATES

VIOLATED

LEVEL

' AREA

DESCRIPTION

-

86-26

86-32

MP SECURITY-

4

SEC/SAFEGRDS DEGRADATION OF THE PROTECTED

4

12/11-12/86

PLAN

AREA BARRIER

2

87-02

10 CFR 4

SEC/SAFEGRDS FAILURE TO PROPERLY SECURE

'

i

1/27-29/87

73.21(d)(2)

UNATTENDED SAFEGUARDS IN-

FORMATION IN A LOCKED

,

'

-SECURITY STORAGE CONTAINER-

F

87-05

APPENDIX B,

5

OPERATIONS

FAILURE TO UPDATE TECHNICAL

-

,

4/14-5/18/87

CRI XVI

TECHNICAL SPECIFICATION

'

TABLE 3.7.1 TO INCLUDE CON-

TAINMENT ATMOSPHERE SAMPLE

LINE ISOLATION VALVES

l

,

87-05

TECH SPEC

5

OPERATIONS

FAILURE TO UPDATE TECHNICAL-

[

-

'

4/14-5/18/87

3.6.1.6

SPECIFICATION TABLES 3.6.1.A

i

AND 3.6.1,8 TO CORRECT

l

'

SAFETY-RELATED SNUBBER

,

i

LISTING

87-15

10 CFR 5

RAD CONTROL

SHIPPING BOX CONTAINING

-

>

7/6-10/87

20.203(f)

RADIOACTIVE MATERIAL AND

!

.

LOCATED IN THE RAILWAY

ACCESS AREA WAS NOT LABELED

AS REQUIRE 0

.

87-15

TECH SPEC

5

RAD CONTROL

THREE CASES OF WORKER (S)

-

7/6-10/87

6.11

NOT READING AN0/OR FOLLOWING

!

RADIATION WORK PERMITS

-

87-15

10 CFR 50.49

4

ENG SUPPORT

INADEQUATE EQUIPMENT QUAL

,

7/15-17/87

(f) AND (k)

DOCUMENTATION OF GE SIS WIRE

USED IN VALVES 2-SI-654,

t

2-CH-501, & 2-51-644

I

87-15

10 CFR 50.49

4

ENG SUPPORT

INADEQUATE EQUIPMENT QUAL

i

-

7/15-17/87

(1)

0F BISHOP CABLE SPLICE ON

i

MOTOR OPERATED VALVE

'

2-51-654 ON MAY 31, 1987

T-2A-1

l

.

&

, w~ m m e no

.

Table 2A

-

REPORT NUMBERS

UNIT 1

UNIT 2 REQUIREMENT SEVERITY FUNCTIONAL

INSPECTION DATES

VIOLATED

LEVEL

AREA

DESCRIPTION

87-17

10 CFR 50.49

4

ENG SUPPORT

INADEQUATE EQUIPMENT QUAL

-

7/15-17/87

(e)(1)

0F CURTIS L-TYPE TERMINAL

BLOCKS USED IN ISOLATION

CONDENSER VALVE I-IC-I

-

87-16

APPENDIX R

5

ENG SUPPORT

FIRE BARRIER SEPARATIN3 THE

,

7/13-17/87

SEC IIIG2

WEST ELECTRICAL PENETRATION

ROOM FROM THE AUXILIARY

BUILDING DID NOT MEET RE-

QUIREMENTS (ND FIRE DAMPER)

-

87-16

APPENDIX R,

5

ENG SUPPORT

INADEQUATE DISTANCE SEPA-

7/13-17/87

SEC IIIG1

RATING THE REDUNDANT AUXILI-

ARY FEEDWATER HEADERS AND

THEIR ISOLATION VALVES WITH

INTERVENING COMBUSTIBLES

87-21

TECH SPEC

4

SURVEILLANCE FAILURE TO PERFORM INDEPEN-

-

8/11-9/8/87

6.8.1.C

DENT VERIFICATION OF TEST

EQUIPMENT FOR AUTO BLOWOOWN

LOGIC AND FAILURE TO IM-

PLEMENT MAIN STEAM LINE

ISOLATION VALVE CLOSURE TEST

87-22

87-20

MP SECURITY

3

SEC/SAFEGROS MULTIPLE EXAMPLES OF INADE-

8/31-9/4/87

PLAN

QUATE PROTECTED AND VITAL

AREA BARRIERS, TWO EXAMPLES

OF VISITORS WITHOUT ESCORT,

IMPROPER COMPENSATORY MEA 5-

URES, AND OTHER ISSUES

87-25

10 CFR 50

4

MAINTENANCE

REDUNDANT VENTILATION

-

10/27-11/30/87

APPENDIX B

COOLERS FOR VITAL DC SWITCH-

GEAR ROOMS INOPERABLE SINCE

1983

87-33

-

10 CFR 4

OPERATIONS

FAILURE TO NOTIFY THE NRC

12/1-31/87

50.72(b)(2)

THAT 8 0F 12 CHECK VALVES

IN THE NITROGEN SUPPLY TO

THE AUTCMATIC BLOWDOWN

SYSTEM FAILED TO PASS THE

LOCAL LEAK RATE TEST

87-29

TECH SPEC

5

0UTAGE

FAILURE TO APPROVE EXCESS

12/1-31/87

6.2.2.g

MANAGEMENT

OVERTIME (7 EXAMPLES) PER

GUIDELINES DURING AN OUTAGE

T-2A-2

.

TABLE 3

SUMMARY OF LICENSEE EVENT REPORTS (LERs_1

MILLSTONE 1

AREA

CAUSE CODES

CODE

AREA

A

B

C

D

E

TOTAL

1

PLANT OPERATIONS

3

1

3

10

2

RADIOLOGICAL CONTROLS

2

1

3

MAINTENANCE

1

4

SURVEILLANCE

5

4

1

11

5

E!4ERGENCY PREP

0

6

SEC/ SAFEGUARDS

8

5

2

1

7

23

7

OUTAGE MANAGEMENT

0

8

TRAINING EFFECT

1

9

ASSURANCE OF QUALITY

0

10

ENGINEERING SUPPORT

4

11

15

TOTALS:

24

21

2

5

12

64

SUMMARY OF LICENSEE EVENT REPORTS (LERs)

MILLSTONE 2

AREA

CAUSE CODES

COCE

AREA

A

B

C

D

E

TOTAL

1

PLANT OPERATIONS

3

2

6

11

2

RADIOLOGICAL CONTROLS

1

3

MAINTENANCE

S

5

4

SURVEILLANCE

2

1

3

6

5

EMERGENCY PREP

0

6

SEC/ SAFEGUARDS

7

3

2

6

18

7

OUTAGE MANAGEMENT

1

2

8

TRAINING EFFECT

0

9

ASSURANCE OF QUALITY

2

10

ENGINEERING SUPPORT

2

6

8

TOTALS:

20

13

2

1

17

53

CAUSE CODES

A -- PERSONNEL ERROR

B -- DESIGN, MANUFACTURING, CONSTRUCTION /INLTALLATION

C -- EXTERNAL CAUSE

0 -- DEFECTIVE PROCEDURE

,

!

E -- EQUIPMENT FAILURE

X -- OTHER

i

T-3-1

i

.

~

.

..

_ . -

.--

-

-.

.

TABLE 3A

,

SYNOPSIS OF LICENSEE EVENT REPORTS (LERs)

,

MILLSTONE 1

,

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

86-17

5/21/86

E*

1

REACTOR.MANUA'.LY TRIPPED FOLLOWING FAILURE OF

MECHANICAL PRESSURE REGULATOR DURING PLANNED

REACTOR SHUTDOWN TO CONDUCT TURBINE INSPECTION

,

86-18-01 5/24/86

B*

10

WITH UNIT SHUTDOWN, REACTOR PROTECTION ACTUATION

DUE TO SOURCE RANGE MONITOR DRIVE RELAYS CAUSING

_

NOISE SPIKES ON INTERMEDIATE RANGE MONITORS 12

AND 16

t

86-19

5/31/86

A*

2

STANDBY GAS TREATMENT INITIATION CAUSED BY

SPURIOUS UPSCALE TRIP 0F THE STEAM TUNNEL VEN-

TILATION RADIATION MONITOR

{

86-25

11/14/86

B

10

NOTIFICATION THAT FEEDWATER COOLANT INITIATION

f

RELAYS DO NOT CONFORM TO SEISMIC QUALIFICATION

'

86-27

11/30/86

B

1

REACTOR TRIP ON GENERATOR TRIP CAUSED BY GENE-

l

RATOR LOCK-00T DUE TO PHASE-TO-GROUND FAULT OF

THE MAIN TRANSFORMER

!

L

86-28-01

12/3/86

B*

4

MAIN STEAM LINE LOW PRESSURE SWITCH SETPOINT

i

j

ORIFT

i

86-29

12/6/86

E*

2

DURING SHUTDOWN, A STANDBY GAS TREATMENT ACTU-

L

ATION CAUSED BY REACTOR BUILDING VENT RAD MONI-

l

TOR FAILING HIGH DUE TO FAILE0 SENSOR / CONVERTER

-86-32

12/30/86

E*

4

SURVEILLANCE OF CONDENSER LOW VACUUM SWITCHES

,

FINDS 2-0F-4 SWITCHES WITH SETPOINT DRIFT DOWN-

WARD

,

!.

87-01-01

1/13/87

B

10

CRACKING ALONG THE HORIZONTAL NORYL INSULATORS

i

0F 4160V DISTRIBUTION LOAD CENTER

}

i

87-04

2/1/87

D*

4

SURVEILLANCE OF "B"

STANDBY GAS TREATMENT OVEk-

,

OUE BY 6 HOURS FOLLOWING DECLARATION THAT "A"

l

SBGT WAS IN0PERABLE

l

\\

!

87-05

2/21/87

0*

1

STANDBY GAS TREATMENT SYSTEM INITIATION BY HIGH

RADIATION IN THE STEAM TUNNEL DUE TO AIR BEING

j

LEFT IN DEMINERALIZER "B"

T-3A-1

l

L

- -.-_,.- . -- _ .-,,,- - -.

- -

.

-

Table 3A

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

87-07

3/22/87

A*

8

REACTOR TRIP AND ISOLATION ON LOW MAIN STEAM

LINE PRESSURE DUE TO PRESSURE OSCILLATIONS

CAUSED BY CONTROL PROBLEMS WITH THE MECHANICAL

PRESSURE REGULATOR

87-08

3/10/87

A

3

REACTOR CUILDING VENT ISOLATION AND STANDBY GAS

TREATMENT ACTUATION DURING INSTRUMENT TECHNICIAN

WORK ON REACTOR BUILDING VENT RADIATION MONITOR

87-12-01 5/19/87

B*

10

EMERGENCY DIESEL GENERATOR CEILING FIRE C0ATING

DISCOVERED INADEQUATE TO PROVIDE THE REQUIRED

3-HOUR FIRE RESISTANT RATING

87-13

5/27/87

D*

1

STANOBY GAS TREATMENT SYSTEM ACTUATED OUE TO

HIGH RADIATION ON THE REFUELING FLOOR CAUSED

BY AIR IN THE SPENT FUEL POOL COOLING SYSTEM

AFTER FILLING AND VENTING

87-15-02 6/6/87

B*

4

SEVENTEEN CONTAINMENT ISOLATION VALVES, INCLUD-

ING TWO MAIN STEAM ISOLATION VALVES, FAIL LOCAL

LEAK RATE TEST

87-17

6/10/87

A*

1

REACTOR TRIP ON SCRAM VALVE AIR HEADER LOW

PRESSURE DUE TO LARGE D2 MAND ON STATION AIR

SYSTEM AND TRIPPING OF SULLAIR AIR COMPRESSOR

ON ELECTRICAL OVERLOAD

87-19

6/12/87

A

1

WHILE UNLOADING THE REACTOR CORE, FUEL ASSEMBLY

LY2729 WAS FOUND MISORIENTED IN CORE LOCATION

43-18

87-20-01 6/26/87

B*

10

INTERGRANULAR STRESS CORROSION CRACKING INDICA-

TION ON RECIRCULATION SYSTEM PIPE TO CAP WELD

RMBJ-1

87-21

6/30/37

B*

10

5 0F 6 TARGET ROCK MAIN STEAM SAFETY RELIEF

VALVE FOUND WITH SETPOINTS HIGHER THEN ALLOWED

BY TECHNICAL SPECIFICATIONS

87-22

7/2/87

B*

10

BASE METAL INCLUSIONS APPROXIMATELY 26 INCHES

LONG FOUND IN THE ISOLATION CONDENSER RETURN

LINE PIPING

!

87-23

7-03-37

8

10

AS-INSTALLED CONFIGURATION OF LOW PRESSURE

COOLANT INJECTION AND CORE SPRAY SYSTEM PUMP

FOUNDATION ANCHORS IN NCNCONFORMANCE WITH

ORIGINAL DESIGN

l

T-3A-2

.

Table 3A

.

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

87-24

7/15/87

A*

2

STANDBY GAS TREATMENT ACTUATION ON REFUELING

FLOOR HIGH RADIATION WHILE REPLACING LOCAL POWER

RANGE MONITORS

87-26

8/3/87

B*

10

FAILURE OF NINE HYORAULIC SNUBBER IN THE FIRST

FEW 10% SAMPLES REQUIRED ALL HYORAULIC SNUBBERS

TO BE TESTED IN ACCORDANCE WITH TECHNICAL

SPECIFICATIONS

87-28

8/13/87

A*

4

REACTOR TRIP SIGNAL GENERATED BY INSTRUMENT

TECHNICIAN WHILE PERFORMING MAIN STEAM ISOLATION

VALVE CLOSURE FUNCTIONAL TEST

87-29

7/24/87

A

10

STANDBY GAS TREATMENT SYSTEM INOPERABLE DUE TO

DEFEATED INTERLOCK ON ATMOSPHERIC CONTROL VALVE

1-AC-10 (VALVE REMOVED FOR MAINTENANCE)

87-30

7/26/87

B*

10

REACTOR TRIP SIGNAL, FROM THE INTERMEDIATE RANGE

MONITORS 12 AND 16, WAS GENERATED AS SOURCE

RANGE CHANNEL 23 WAS BEING ORIVEN IN 87-31

7/28/87

D*

1

REACTOR TRIP SIGNAL DUE TO INTERMEDIATE RANGE

MONITOR SPIKE CAUSED BY INSTRUMENT TECHNICIAN

MOVING NUCLEAR INSTRUMENT CABLES UNDER THE

REACTOR VESSEL

87-32

8/11/87

B*

4

ALL FOUR TURBINE IST STAGE PRESSURE BYPASS

SWITCHES FAIL TO MEET TECHNICAL SPECIFICATIONS

SETPOINT REQUIREMENTS

87-33

8/12/87

A

4

OURING SHUTDOWN, INAD/ERTENT ACTUATION OF "A"

LPCI SUBSYSTEM DUE TO TEST SIGNAL INJECTION

87-34

8/14/87

A

1

REACTOR TRIP OURING STARTUP ON INTERMEDIATE

RANGE HIGH FLUX DURING WITH0RAWAL OF CONTROL ROD 26-31

87-35

8/21/87

A

10

SIX FIRE DETECTION SYSTEM NOT COMPLETELY ELEC-

TRICALLY SUPERVISED AND NOT DEMONSTRATED OPER-

ABLE EACH 31-DAYS PER TECHNICAL SPECIFICATIONS

87-36

8/26/87

A*

4

REACTOR TRIP DURING AVERAGE POWER RANGE MONITOR

SURVEILLANCE TESTING

87-37

9/8/87

A*

4

MANUAL REACTOR TRIP FUNCTION SURVEILLANCE NOT

PERFORMED ON TIME

,

T-3A-3

.

_ .

_.

._ _ - -

--

- . - - _ _ _ _

,---_-

.

Table 3A

.

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

87-38

9/3/87

E*

1

REACTOR TRIP ON LOW SCRAM HEADER PRESSURE CAUSED

BY LOW SERVICE AIR HEADER PRESSURE DUE TO SER-

VICE AIR COMPRESSOR FAILURE DURING HIGH SERVICE

AIR USAGE

87-39

9/21/87

A*

4

SURVEILLANCE FOUND PAST DUE ON AUTCMATIC PRES-

SURE RELIEF AND LOW PRESSURE CORE COOLING PUMP

INTERLOCK

87-40

9/15/87

B*

10

ALL FOUR NEW (INSTALLED DURING 1987 OUTAGE)

CONDENSER LOW VACUUM TRIP PRESSURE SWITCHES

FAILED TO MEET TS SETPOINT REQUIREMENTS

87-41

10/16/57

A*

10

FAILURE TO REQUEST TECHNICAL SPECIFICATION

CHANGE FOR REMOVAL OF LOW REACTOR PRESSURE

PERMISSIVE SWITCHES FROM LOW PRESSURE INJECTION

AND CORE SPRAY PUMP START LOGIC

87-42

10/27/87

A

10

DURING REVIEW OF IE INFORMATION NOTICE 86-60,

IT WAS DETERMINED THAT NO SURVEILLANCE EXISTED

FOR TESTING THE POST ACCIDENT SAMPLING SYSTEM

PER TECHNICAL SPECIFICATION 6.13

87-43

11/16/87

E*

1

TWO HYDRAULIC SNUBBERS HAD LOW RESERVOIR FLUID

LEVELS: BENCH TESTING RESULTED IN DECLARING THEM

INOPERABLE DUE TO SLIGHTLY HIGH LOCKUP RATES

IN COMPRESSION

87-44

12/29/87

B*

4

TECHNICAL SPECIFICATION REQUIRED TESTING OF GAS

TREATMENT SYSTEM NOT FULLY SATISFIED IN THAT

NO FLOW DISTRIBUTION TEST WAS PERFORMED ACROSS

l

THE CHARC0AL ABSORBERS

-- CAUSE CODES HAVE BEEN ASSIGNED BY OR CHANGES FROM THE LICENSEE CODES BY NRC

REGION I

,

T-3A-4

-

- -

-

- -

.

s

TABLE 3B

SYNOPSIS OF LICENSEE EVENT REPORTS (LERs)

MILLSTONE 2

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

86-03-01 5/16/86

B

1

EVALUAT;0N IN RESPONSE 'O IE INFORMATION NOTICE 83-69 IDENTIFIES 20 INOPERABLE FIRE DAMPERS

86-04-01 6/1/86

A*

1

REACTOR TRIP ON REACTOR COOLANT PUMP UNDERSPEED

CAUSED BY LOSS OF POWER TO BUS 258 DUE TC IM-

PROPER OPERATION OF BREAKER CONTROL SWITCH

252-258-2

86-05

8/12/86

B

10

REACTOR TRIP ON #1 STEAM GENERATOR LOW LEVEL

AFTER LOSS OF THE "A"

FEEDWATER PUMP DUE TO LOSS

OF OIL PUMPS WHEN BUSSES 22A AND 228 (CROSS-

TIED) LOST POWER

86-06

9/3/86

B

10

REACTOR TRIP ON LOW STEAM GENERATOR LEVEL DUE

TO LOSS OF HEATER ORAINS FLOW FOLLOWING FAILURE

OF AIR FITTING TO THE HEATER ORAINS CONTROL

VALVE CLOSING VALVE

86-07

9/1/86

E*

4

SURVEILLANCE CHECK OF THE REMOTE SHUTOCWN PANEL

FOUND TECH SPEC REQUIRED STEAM GENERATOR LEVEL

TRANSMITTER LT-1113A OUT OF SERVICE

86-08-01 9/20/86

E*

4

SIX 0F 16 MAIN STEAM SAFETY VALVES FAILED THE

SIMMER TEST DUE TO SETPOINT ORIFT

86-09-01 9/29/86

A*

3

TWO UNRELATED ESF ACTUATIONS ONE OUE TO PER-

SONNEL ERROR AND THE OTHER DUE TO NOISE SPIKE

IN RAD MONITOR RM-8262A

86-10

10/6/86

A*

10

INCONSISTENCY BETWEEN THE NUMBER OF RCS PUMPS

REQUIRED TO BE OPERATING IN MODES 3, 4 AND 5

AND THE ASSUMPTIONS USED IN THE SAFETY ANALYSIS

86-11

10/4/86

A*

1

TWO CASES OF IMPROPER FIRE WATCH COVERAGE RE-

QUIRED BY TECH SPEC 3.7.10.A DURING REFUELING

86-12-01

10/9/86

E'

4

TYPE B AND C LOCAL LEAKAGE RATE LIMITS EXCEEDED

86-13

10/10/86

B*

10

SAFETY INJECTION TANK "A"

LEVEL TRANSMITTER

FOUND OUT OF SPECIFICATION TO THE LOW SIDE

.

l

T-3B-1

i

!

l

-

Table 3B

.

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

86-14

10/29/86

A*

4

TWO ACTUATIONS OF THE CONTAINMENT PURGE ISOLA-

TION SYSTEM CAUSE0 BY: 1) ELECTRONIC NOISE IN

RM 8123A, ANO. 2) TECHNICIAN ERROR

86-15-01

11/14/86

8

10

GENERAL ELECTHIC MODEL 12 OIESEL GENERATOR DIF-

FERENTIAL RELAYS NOT SEISMICALLY QUALIFIED FOR

CLASS 1E SERVICE

86-16

11/4/86

E*

7

SCHEDULED INSERVICE EXAMINATION OF STEAM GENE-

RATORS IDENTIFIED SUFFICIENT NUMBER OF TUBES

WITH FLAWS GREATER THAN 40% THROUGH-WALL

85-17

11/5/86

A*

3

DURING SHUTOOWN, LOSS OF POWER EVENT INITIATION

BY TESTMAN CAUSING A PERCEIVED MAIN GENERATOR

GROUNO FAULT RESULTING IN OPENING OF SWITCHYARD

BREAKERS

86-18

12/10/66

B*

10

PLANNED REMOVAL OF 14 HYDRAULIC AND 7 MECHANICAL

SNUBBERS HAVING MOVEMENTS LESS THAN 1/16 INCH:

SNUBBERS WERE REPLACE 0 WITH RIGIO SUPPORTS

86-19

11,'13/86

0*

4

DilRING SHUTOOWN, OPERABILITY SURVEILLANCE OF

1.dEE RUSKIN MODEL HVD-1-173 FIRE DAMPER HAS

BEEN MISSED SINCE 1980: WERE NOT ON SP 2618G

FORM

86-20

11/29/86

A

3

DURING SHUTDOWN, TWO CASES OF LOSS OF POWER ON

LOAD CENTER 24C BEING SENSED BY AN IMPR00ERLY

INSTALLE0 BUS VOLTAGE POTENTIAL TRANSFORMER

ORAWER

86-21

12/31/86

B

1

OURING SHUTOOWN, 8 VALCOR SOLEN 0ID VALVE IN THE

REACTOR CCOLANT VENT SYSTEM WERE LEAKING BY OUE

TO SPRING FAILURES

86-2'

12/23/86

A*

3

REACTOR TRIP ON LOW STEAM GENERATOR LEVEL DUE

TO FEE 0 WATER PUMP SPEED DECREASE TO MINIMUM UPON

LOSS OF POWER ON BUS 24C, CAUSED BY IMPROPERLY

INSTALLED DRAWER

86-23

12/13/86

B

9

"C" CHARGING PUMP LRACKED BLOCK CUE TO HIGH

INTERNAL STRESS CAUSING CRACKS TO INITIATE AT

SUB-SURFACE INCLUSIONS

87-01-01

12/22/86

E*

1

FIRE DETECTION / PROTECTION SYSTEMS FOR THE "C"

REACTOR COOLING PUMP INDICATED OUT OF SERVICE

DUE TO HEAT DETECTOR FAILURE

T-3B-2

..

Table 3B

.

1

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

87-02

1/2/87

A*

3

REACTOR TRIP ON LOW STEAM GENERATOR LEVEL FOL-

LOWING LEVEL CONTROL PROBLEMS DUE TO A HOT

JUMPER ARC ON THE FIRE SUPPRESSION ALARM PANEL 87-03

1/29/87

A*

7

POST OPERATIONAL REVIEW 0F ED0Y CURRENT DATA

IDENTIFIED TWO DEFECTIVE STEAM GENERATOR TUBES

NOT REPAIRED PRIOR TO STARTUP

87-04-01 2/2/87

E*

2

00 RING SHUT 00WN, TWO CASES OF ISOLATION OF CON-

TAINMENT PURGE SYSTEM OCCURRED DUE TO AUTOMATIC

ACTUATION OF ESAS

.87-05

3/6/87

8

9

"B" CHARGING PUMP CRACKED BLOCK OUE TO HIGH IN-

TERNAL STRESS CAUSING CRACKS TO INITIATE AT

SUB-SURFACE INCLUSIONS

4

87-06

4/3/87

B*

10

FSAR TABLE ERROR RESULTED IN SERVICE WATER FLOW

THRU RBCCW HEAT EXCHANGER BEING INSUFFICIENT

,

FOR DESIGN HEAT REMOVAL

'87-07

4/16/87

E*

1

REACTOR TRIP ON TURBINE TRIP CAUSED BY GENERATOR

EXCITER FIELD BREAKER AND GENERATOR BREAKERS

!

OPENING, CAUSE UNKNOWN

87-08

6/11/87

A*

4

LATE SURVEILLANCE DUE TO SCHEDULING ERROR FOR

BATTERIES 201A&B (SURVEILLANCE 2736B-1)

87-09

9/2/87

E*

1

REACTOR TRIP ON #1 STEAM GENERATOR LOW LEVEL

DUE TO FAILURE OF FEEDWATER CONTROL VALVE

'

2-FW-51A, THE PLUG HAD SEPARATED FROM THE STEM

87-10

7/30/87

A*

10

MAIN CABLE VAULT AND RACEWAY TO CHARGING PUMPS

.

FIRE PROTECTION SUPPORTS NOT ADEQUATELY PROTECTED

i

87-11

7/23/87

E*

1

REACTOR TLIP ON #1 STEAM GENERATOR LOW LEVEL

'

DURING A DOWN-POWER EVOLUTION IN RESPONSE TO

j

DECREASING REACTOR PRESSURE CAUSED BY STUCK OPEN

j

SPRAY VALVE 2-RC-100F

87-12

11/16/87

E*

1

REACTOR TRIP ON STEAM GENERATOR #1 LOW LEVEL

FOLLOWING FAILURE OF FEEDWATER REGULATING VALVE;

OTF3R PROBLEMS WERE FAILURE OF "A" AUXILIARY

!

FEEDWATER PUMP TO START AND STOPPING OF "A" AND

"C" REACTOR COOLING PUMPS DUE TO BUS TRANSFER

,

FAILURE

i

!

T-38-3

l

-

.

Table 3B

.

LER

EVENT

CAUSE AREA

NUMBER

DATE

CODE

DESCRIPTION

87-13-01

12/19/87

A*

1

FIRE WATCH PATROL FAILED TO CONDUCT AN HOURLY

INSPECTION OF CABLE VAULT AREA THAT CONTAINS

NON-QUALIFIED CABLE TRAY ENCLOSURES

87-14

12/31/87

E*

1

SIX OF 16 MAIN STEAM SAFETY VALVES FAILED THE

SIMMER TEST DUE TO SETPOINT DRIFT

-- CAUSE CODES HAVE BEEN ASSIGNED BY OR CHANGES FROM THE LICENSEE CODES BY NRC

REGION I

t

j

l

!

'

i

,

1

I

T-3B-4

.

---

- 3

'

\\,1 , t

i,

'

i

'

1,

,\\

s

'

N.

(

';

,

'

' ',

s-

,

,,

i

\\

3,

\\

'

~

'h

\\

'

s .

q

i

s

(

,' \\

TABLE 3C

,'

T

,s

y

- .-

-

3

y

SYNOPSIS OF SECURITY EVENT REPORTS'{SERs)

[

'

,

\\A

.

'

MILLlJONESITE

'

LER

EVENT

CAUSE

,

s'

'

,

'

NUMBER

DATE

-CODE

-DESCRIPliON

\\,

s i

- --

,

<

,

86-20

8/12/S6

E*

SECURITY RLt.ATEP EVENT. Fdt ALL UNITS - LOSS OF COM-

'

PDTErt F0VER

-

s

,,

si s

,

86-21

9/11/86

E*

IEC9R;TY RELA',Ei EWr FCR UN!!'1 - LOSS OF VIT/j.

AREA GARRIER

'.

86-22-02 10/18/86

B

SELJRTTY REU ND E'.

NT FOR A

MITS - LOSS OF VITAL

AREA [4RRIER q

\\

s

-

,

86-23-01 10/23/86

B

SECURITYRELATEDEW1iTdRUNIT1-LOSSOFVITAL

J

s

.,

1

AREA BARRIER

.

s

86-24

11/14/86

A"

SECURITY RELATE 0 EVENT FOR ALL UNITS - PERSONNEL

' '

ACCESS PK0BLEF

T

.

X

86-26

11/24/86

A

SECURITY 4ELAMD EVENT FOR. W..U!.1TS - LOSS OF VITAL

AREA PARRIER

'

.

>

I.

86-30-01 12/11/86

A*

SECURITY RELATL'i EVENT FOR ALL W F: w LOSS OF PRO-

lEC.TED AHA BAi.jlER

N

s

86-3.

12/23/86

E*

SECURITY 2 ELATED EVENT FOR ALL UNITS - COMPUTER

FAILURE

-

1

87-02-01 2/6/87

B

SECURITY RELATED EVE'(T FOR' Ut(ITS 14ND 2 - ACCESS

CONTROL PROBLEM ~

\\

,

s

a

'

87-03

2/6/87

A*

SECLRITf RELATED EVENT FOR All U:41TS - ACCESS CONTROL

PROBLEM

'

87-06

3/9/87

t-

SECURITY RELA h EVENT FOR ALL UNITS - PROTECTED AREA

ACCESS CONTROL 4 0eLEM

87-09

4/6/87

E*

SECURITYRELATEDE\\itTFORALLUNITS-COMPUTER

FAILURE

L

-

t,

87-10-01 4/9/87

E'

SECURITY RELATED EVENT "OR UN!TS 1 AND 2

'COMk \\h

'

FAILURE

'

,

S7-11

5/21/87

A*

SECb91TY RELA 1ED EVENT FOR UNIT 3 - ACCEN ',CNTROL

!

FROBt N

3

,

T-3C-1

5

. _ _ _ _ _ _ _ _ _ _ _

.

'4

,

Table 3C

.

,.

,

. LER

EVENT

CAUSE

NUMBER

DATE

CODE

DESCRIPTION

S7-12

9/3/87

B*

SECURITY RELATED EVENT FOR UNIT 1 - BREACH OF VITAL

,

AREAS

87-13

9/5/87

C*

SECURITY RELATED EVENT FOR ALL UNITS - POTENTIAL

CIVIL DISTURBANCE

87-14

6/7/87

A*

SECURITY RELATED EVENT FOR UNIT 1 - BREACH OF VITAL

AREA

87-14

9/7/87

E*

SECURITY RELATED EVENT FOR ALL UNITS - COMPUTER

FAILURE

'

s

87-15

10/16/87

A*

SECURITY RELATED EVENT FOR ALL UNITS - UNESCORTED

ACCESS TO PROTECTED AREA

87-16

6/11/87

E*

SECURITY RELATED EVENT FOR ALL UNITS - COMPUTER

FAILURE

87-16

10/22/87

A*

SECURITY RELATED EVENT FOR ALL UNITS - LOST BADGE

87-18-01 6/23/87

b'

SECURITY RELATED EVENT FOR UNITS 1 AND 2 - COMPUTER

FAILURE

87-1G

11/12/37

A*

SECURITY RELATED EVENT FOR ALL UNITS - GUARD AL-

LEGEDLY NOT ALERT AT POST

-

s

,

87 ', h'

11/19/87

A*

SECURITY RELATED EVENT FOR ALL UNITS - FAILURE TO

KAINTAIN PROTECTED AREA COMPENSATING MEASURES

-

37-20

11/24/87

2?

SECURITY RELATED EVENT FOR ALL UNITS - LOST BADGE

87-21

12/2/87

D*

SECURITY RELATED EVENT FOR ALL UNITS - ALLEGED ENTRY

OF DANGEROUS WEAPON

s 87-22

12/22/87

A*

SECURITY RELATED EVENT FOR UNIT 3 - UNINTENTIONAL

UNAUTHORIZED ENTRY INTO VITAL AREA

87-25

7/24/87

C*

SECURITY RELATED EVENT FOR ALL UNITS - BCMB THREAT

87-27

8/14/37

D*

SECURITY RELATED EVENT FOR UNIT 1 - BREACH OF VITAL

AREA

,

-

-- CAUSE CODES HAVE BEEN ASSIG!MD BY OR CHANGES FROM THE LICENSEE CODES BY NRC

REGION I

T-30-2

-

_

. _ . .

_

_ _ . _

_ _ .

.

TABLE 4

SUMMARY OF FORCEO OUTAGES, UNPLANNEO TRIPS, AND POWER REDUCTIONS

MILLSTONE 1

AREA

A

B

C

D

E

X

TOTAL

PLANT OPERATIONS

1

RADIOLOGICAL CONTROLS

0

MAINTENANCE

1

SURVEILLANCE

1

EMERGENCY PREP

O

SEC/ SAFEGUARDS

0

OUTAGE MANAGEMENT

0

TRAINING INADEQUACY

1

ASSURANCE OF QUALITY

0

ENGINEERING $dPPORT

3

TOTALS:

3

4

7

SUMMARY OF FORCED OUTAGES, UNPLANNED TRIPS, AND POWER REDUCTIONS

MILLSTONE 2

AREA

A

g

C

D

E

X

TOTAL

PLANT OPERATIONS

1

RADIOLOGICAL CONTROLS

0

MAINTENANCE

2

4

SURVEILLANCE

1

EMERGENCY PREP

0

SEC/ SAFEGUARDS

0

OUTAGE MANAGEMENT

0

TRAINING INADEQUACY

0

ASSURANCE OF QUALITY

0

ENGINEERING SUPPORT

2

TOTALS:

4

2

8

CAUSE CODES

A -- PERSONNEL ERROR

B -- DESI3N, MANUFACTURING, CONSTRUCTION / INSTALLATION

,

C -- EXTERNAL CAUSE

l

0 -- DEFECTIVE PROCEDURE

i

E -- EQUIPMENT FAILURE

X -- OTHER

d

B

T-4-1

. . . - -

-

.

-

__

. - . _ - _

-

.-.

-.

. . _ , .

..

_

.

TABLE 4A

SYNOPSIS OF FORCED OUTAGES, UNPLANNED TRIPS, AND POWER REDUCTIONS

MILLSTONE 1

POWER

LER

CAUSE

DATE

LEVEL DURATION DESCRIPTION

NUMBER

& AREA *

6/19/86 1004

POWER REDUCTION TO REPAIR STEAM

REPAIR LEAKS

--

LEAK IN "B"

SHUTDOWN COOLING HEAT

(N0 AREA

EXCHANGER

ASSIGNED)

POWER REDUCTION TO REPAIR CONDEN-

6/28/86 100%

REPAIR LEAKS

--

SER TUBE LEAKS

(ENGINEERING

SUPPORT)

7/16/86 1004

POWER REDUCTION FOR CONTROL ROD

ADJUSTMENT &

--

PATTERN ADJUSTMENT AND TO REPAIR

REPAIR LEAKS

CONDENSER TUBE LEAKS

(ENGINEERING

SUPPORT)

10/9/86 100%

POWER REDUCTION TO REPAIR CON-

REPAIR LEAKS

--

DENSER TUBE LEAKS

(ENGINEERING

SUPPORT)

11/30/86 100%

15 DAYS REACTOR TRIP ON GENERATOR TRIP

86-27

EQUIPMENT

CAUSED BY GENERATOR LOCK-0UT DUE TO

FAILURE (NO

PHASE-TO-GROUND FAULT OF THE MAIN

AREA ASSIGNED)

TRANSFORMER

3/22/87

S0%

27 HRS

REACTOR TRIP AND ISOLATION ON LOW

87-07

TRAINING

MAIN STEAM LINE PRESSURE DUE TO

INADEQUACY

PRESSURE OSCILLATIONS CAUSED BY

CONTROL PROBLEMS WITH THE EPR/MPR

4/1S/87 100%

POWER REDUCTION TO REPAIR STEAM

REPAIR LEAKS

--

LEAKS IN HEATER BAY

(NO AREA

ASSIGNED)

8/14/87

0%

REACTOR TRIP DURING STARTUP ON

87-34

OPERATOR

--

INTERMEDIATE RANGE HIGH FLUX DURING

ERROR

WITHDRAWAL OF HIGH WORTH CONTROL

(OPERATIONS)

ROD 26-31

8/26/87 100%

21 HRS

REACTOR TRIP DURING AVERAGE POWER

87-36

TESTING ERROR

RANGE MONITOR SURVEILLANCE TESTING

(SURVEILLANCE)

T-4A-1

,

i

immm

m

m- i

_

__-

.

Table 4A

.

POWER

LER

CAUSE

DATE

LEVEL OURATION DESCRIPTION

NUMBER

& AREA *

9/3/87

100%

44 HRS

REACTOR TRIP ON LOW SCRAM HEADER

87-38

EQUIPMENT

PRESSURE CAUSED BY LOW SERVICE AIR

FAILURE

HEADER PRESSURE OUE TO SERVICE AIR

(MAINTENANCE)

COMPRESSOR FAILURE DURING HIGH

SERVICE AIR USAGE

11/14/87 100*4

64 HRS

REACTOR SHUTDOWN TO INVESTIGATE AND

REPAIR LEAK

--

REPAIR IC-1 PACKING INSIDE ORYWELL

(N0 AREA

ASSIGNED)

-- CAUSE AND AREA CODES HAVE BEEN ASSIGNED BY NRC REGION I

T-4A-2

_ . _ . _ _ _ _ .

_ _ _ _ _ _ _ _

_ . - . _ _ .

-

%

.

TABLE 48

SYNOPSIS OF FORCED OUTAGES, UNPLANNED TRIPS, AND POWER REDUCTIONS

MILLSTONE 2

POWER

LER

CAUSE

DATE

LEVEL DURATION DESCRIPTION

NUMBER

& AREA *

6/1/86

60%

13 HRS

REACTOR TRIP ON REACTOR COOLANT

86-04-01 PERSONNEL

PUMP UNDERSPEED CAUSED BY LOSS OF

ERROR BY THE

POWER TO BUS 25B DUE TO IMPROPER

OPERATIONS

OPERATION OF BREAKER CONTROL

STAFF

SWITCH 252-258-2

8/12/S6

95%

112 HRS REACTOR TRIP ON #1 STEAM GENERATOR 86-05

PERSONNEL

GENERATOR LOW LEVEL AFTER LOSS OF

ERROR BY

THE "A"

FEEDWATER PUMP DUE TO LOSS

ENGINEERING

OF OIL PUMPS WHEN BUSES 22A AND 22B

SUPPORT

(CROSS-TIEO) LOST POWER

9/3/86

100%

26 HRS

REACTOR TRIP ON LOW STEAM GENERA-

86-06

DESIGN DE-

TOR LEVEL DUE TO LOSS OF HEATER

FICIENCY BY

DRAINS FLOW FOLLOWING FAILURE OF

ENGINEERING

AIR FITTING TO THE HEATER ORAINS

SUPPORT

CONTROL VALVE CLOSING VALVE

12/23/86 50%

20 HRS

REACTOR TRIP ON LOW STEAM GENERA-

86-22

PERSONNEL

TOR LEVEL DUE TO FEECWATER PUMP

ERROR BY

SPEED DECREASE TO MINIMUM UPON LOSS

MAINTENANCE

OF POWER ON BUS 24C, CAUSED BY IM-

PROPERLY INSTALLED CRAWER

1/2/87

100%

21 HRS

REACTOR TRIP ON LOW STEAM GENERA-

87-02

PERSONNEL

TOR LEVEL FOLLOWING LEVEL CONTROL

ERROR BY AN

PROELEMS DUE TO A HOT JUMPER ARC GN

ELECTRICIAN

THE FIRE SUPPRESSION ALARM PANEL

(MAINTENANCE)

'

1/29/87 100%

18 DAYS CONTROLLEO SHUTDOWN FOLLOWING IN-

STEAM

--

DICATIONS OF A STEAM CENERATOR TUBE

GENERATOR

LEAK IN THE "A"

GENERATOR

TUSE LEAK

(SURVEILLANCE)

3/24/87 100%

0 HRS

REACTOR POWER LEVEL WAS REOUCED TO

STEAM LEAK

--

80'; TO REPAIR A STEAM LEAK ON THE

REPAIR (N0

"B"

FEEDWATER PUMP

AREA ASSIGNED)

T-48-1

.

o

Table 4B

POWER

LER

CAUSE

DATE

LEVEL DURATION DESCRIPTION

NUMBER

& AREA *

4/16/87 1004

20 HRS

REACTOR TRIP ON TURBINE TRIP

87-07

EQUIPMENT

CAUSED BY GENERATOR EXCITER FIELD

FAILURE (Nr

BREAKER AND GENERATOR BREAKERS

AREA ASSIGNED)

OPENING, CAUSE UNKNOWN

7/23/87 100%

21 HRS

REACTOR TRIP ON STEAM GENERATOR

RANDOM EQUIP-

--

LOW LEVEL DURING DOWN-POWER IN RE-

MENT FAILURE

SPONSE TO DECREASING PRIMARY PRES-

(NO AREAS

SURE CAUSED BY A PARTIALLY (1/3

ASSIGNED)

OPEN) STUCK OPEN SPRAY VALVE

9/2/87

91%

34 HRS

REACTOR TRIP ON #1 STEAM GENERATOR 87-09

EQUIPMENT

LOW LEVEL DUE TO FAILURE OF FEED-

FAILURE (N0

WATER CONTROL VALVE #2-FW-51A, THE

AREA ASSIGNED)

PLUG HAD SEPARATED FROM THE STEM

11/16/87 1004

26 HRS

REACTOR TRIP ON STEAM GENERATOR #1 87-12

EQUIPMENT

LOW LEVEL DUE TO LEVEL TRANSIENT

FAILURE (NO

CAUSED BY MALFUNCTION OF THE VALVE

AREA ASSIGNED)

POSITIONER FOP FEE 0 WATER REGULATING

VALVE #2-FW-51 A

,

-- CAUSE AND AREA CODES HAVE BEEN ASSIGNED BY NRC REGION I

l

T-4B-2

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