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NUCLEAR REGULATORY COMMisslON
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2 5 JAN '1978 -
9 MEMORANDUM FOR:
E. L.' Jordan, XOOS, IE:HQ FROM:
B. H. Grier, Director, RI
SUBJECT:
CONGRESSIONAL INVESTIGATOR'S REPORT ON MILLSTONE-POINT I 0FF-GAS SYSTEM EXPLOSIONS ON DECEMBER 13, 1977
Reference:
~ January 4,1978 merao from D. Cook, Chief Investigator to the Honorable Leo J. Ryan, Chairman, Environment, Energy, and Natural Resources Subccmmittee of the i
Committee on Government Operations, House of-Repre-sentatives, Congress of the United States The Enclosure.1 comments are provided on the above referenced memorandum.
Many of the comments involve relatively minor inaccuracies which should-be expected in a report which involved about one day on site by the author.
But, we do have major disagreements with the investigator's memorandum, and we regret that we were not provided the opportunity to see it or make our comments before its public dissemination.
Our most significant concern is about the assertion that NRC regulatory l
actions 'are ineffective. We believe that regulatory actions are effective in general and that they have been effective with this licensee.
Non-i compliances at Millstone Unit 1 numbered 34 in 1976 and 20 in 1977.
(The enforcement history for 1975 through 1977 is provided as Enclosure
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i 2 to this memorandum.)
There have been substantive improvements in facility quality assurance, management, and training.
This has occurred because of licensee responsiveness to NRC regulation, including inspection, management meetings, and civil penalties.
A second major concern is over the statement that "Griswold became the first victim of a civilian nuclear power plant accident ever to be
- hospitalized as a result of his radioactive exposure." The hospitaliza-tion in this case was for observation for the concussion sustained, not i.
for radioactive exposure.
Decontamination was acccmplished within a rew hours. Maximum skin dosage received was about 325 mrem.
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8301100185 821207 PDR FOIA HIATT82-545 PDR
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f g # MN E78 E. L. Jordan 2
Our third concern is for the investigator's cc=ents on facility security.
These were based upon observations and opinion, not upon testing of security measures.
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g,B yce Fr. Grier Director
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Enclosures:
1.
Corrrents on Investigator's Report 2.
1975-1977 Enforcement History for Millstone I cc:
R. Fortuna bcc:
E. J. Erunner W. G. Martin P. R. t,'e l s o n E. C. McCabe K. Abraham J. T. Shedlosky i.
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1 2 5 JAN 1973 N'oted-Errors and Corrective Comments 1.
Page 2, date and time entry.
12/13/77, 1120 hours0.013 days <br />0.311 hours <br />0.00185 weeks <br />4.2616e-4 months <br /> Hot Shutdown was not planned or crdered prior to 13CO.
2.
Page 3, date and time entry.
This item is not quite in perspective.
The Emergency Plan pre-
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scribes routes for egress, and it is necessary that it do so.
If serious blast or radiation hazard existed along a prescribed route, that route should have been modified. -Such a condition did not exist in this case.
The contamination received by uninjured personnel was minor, and the action taken to attend the' injured individual and account for other personnel was valid.
Those concerns were more important than the contamination potential.
3.
Page 3 and 4, 1st paragraph under "Investication".
Planned, approved construction was being performed in the vicinity of the instrument lines for the existing Off Gas System.
A welder inadvertently made an arc strike on this instrument line, reaching the auto-ignition temperature of the explosive hydrogen-oxygen mixture inside the line.
4.
Page 4, 4th par 3 graph "According to Kottan..
NRC Region I personnel do not recall making this statement.
The injured individual was not hospitalized because of his radia-tion exposure.
Decontamination was achieved within a few hours.
Hospitalization was required because of the concussion sustained.
5.
Page 5, 1st paragraph The site boundary exposure of 1 mrem may be compared to a coast to coast aircraft flight exposure of 3 mrem.
These exposures are far below federal limits and do not csuse detectable physical change.
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Page 5, 4th paragraph.
The inspection of Shediosky and Kottan was the 33rd (not 34th) of
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the current year.
One civil penalty.was issued during the time paric' of review by Mr..Ccok.
Two civil' penalties have been issued to t 's facility (on July 18,1975. and January 21,1977).
7.
Page 5, 5th paragrapn and Page 11, 6th paragraph.
On December 16, 1977, officials of Connecticut were informed, with the congressional investigator present, that a resident inspector would be stationed at the Millstone site during the summer of 1978 if budgetary approval is received for the resident inspector program.
8.
Pages 6, 7 and 8, Enforcement-Data.
The method of tabulation used causes a discrepancy between the number of nonccmpliances identified by the investigator and those contained in the NRC enforcement history.
NRC data identifies, for the data provided the investigator, 30 noncompliances in 1975, 34 in 1976, and 20 in 1977.
(Ten 1977 ncncompliances were not provided to the investigator because the reports have not been issued.) A breakdown of the enforcement history is provided below.
Violations Infractions Deficiencies Deviations 1975 0
15 15 3
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1975 1
18 15 0
1977 (issued 0
5 5
1 reports) 1977 (not yet 0
8 2
0 issued)
It is not correct to state (page 8) that the plant was " cited more than half of the time it was inspected." The author's data en page 6 shows that the plant was cited during 35 of the 88 inspections in the survey.
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o continued 3
@3 9.
Page 8, last paragraph.
NRC Region I personnel do not recall using the word " notorious" to describe Offgas explosions at Boiling Water Reactors.
It is correct to state that the number of such explosions is significant.
10.
Page 9, last paragraph.
This guardhouse and access road are outside the protected area and only provide access to a restricted parking area in the owner-controlled area.
11.
Page 10, 4th paragraph.
The inner perimeter guardhouse in continuously manned by armed guards who observe the exit and who are in a position to observe and prevent any attempt to gain unauthorized access through the
" egress portal."
12.
Page 10, 5th paragraph.
Entrance and egress through the door is controlled by a full time security guard.
This guard was attending the door when Messrs.
Shedlosky and Cook went to the stack explosion site and when they returned.
The security guard at this station is frequently checked by inspec-tors.
No violations have been noted.
13.
Page 11, 2nd and 3rd paragraphs.
This guardhouse is an alternate access control point for cor,struc-tion / contractor personnel and warehouse feliveries and does not provide access to operaticnal or vital areas in Units I and II.
Additional access control stations are manned by security personnel.
14.
Page 11, 4th paragraph.
This licensee has implemented a security program in accordance with NRC regulatory requirements.
Major improvements are planned in accordance with amended changes required by 10 CFR 73.55.
The majority of these changes are under review by NRR.
Our inspections have identified items of noncompliance and problem areas which have been adequately corrected.
The security progam is regularly reviewed and inspected.
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o Enclosure l continued 4
15.
Page 12, last paragraph.
The memorandum states:
"Despite a long history of violations by the licensee of Millstone, regulatory actions by the NRC are inef-fective.
There have been no reforms; the NRC merely inspects, finds a violation, and makes a note of it."
This statement con-tains substantial errors.
Each violation must be responded to by the licensee.
Correction of each violation is monitored by the NRC.
NRC overview of facility status has been mai c ined.
Esca-lated enforcement action has been taken when considered proper.
Meetings with licensee management have been conducted to review facility status and areas where improvements are considered to be needed.
The quality assurance program has been substantially upgraded.
There has been a substantial decrease in the number of violations detected during the last year.
A modification improving the Offgas system is being made.
No harm has been caused to the public by incidents which have occurred at Millstone Unit One, and we consider facility safety to be adequate and improving.
16.
Page 13, 1st paragraph.
The report states:
"The repeated violations, spanning several years in the case of this report, have never prcmpted the NRC to get tough on the violators, and require effective refcrms on the part of Northeast Utilities." We disagree with this conclusion.
The inspection data provided the regulatory investigator shows, we feel, that our regulatory program is a tough one which results in correction of inadequacies which have potential for development of unsatisfactory conditions in addition to the correcting of unsatis-factory conditions detected.
The impositicn of two civil penalties also reflects a proper enforcement posture involving more stringent measures when normal enforcement action is considered insufficient.
Page 13, 2nd paragraph.
The report states:
"The NRC should be required to demand adherence to their cwn regulations, and past failure to do so is derelict."
It is our position that we do require adherence to NRC regulations, and that we have done so in the past.
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..o o continued 5
dAll 7978 Page 13, 3rd paragraph.
The report states:."The NRC shoald be encouraged to carefully weigh the advisability of stationing inspection personnel in localities where there is a heavy concentration of nuclear power plants.
Millstone is more than 200 miles frcm the NRC's regional offices at King of Prussia, and the nine hour response time of the NRC health physics specialist frcm Pennsylvania is, in my view, un-acceptable." The resident inspector program has been proposed and is awaiting budgetary approval.
Connecticut officials were noti-fied, with the investigator present,.of this on December 16, 1977.
It is, however, true that the NRC regulatory-role does not require more prcmpt NRC presence on site because our function in such cases is one of evaluation and regulatica, and not one of emargency response.
Page 13, Summary Paragraph.
The paragraph states:
"Of far greater concern is the failure of the licensee to anticipate that it had a larger problem thca indi-cated folicwing the firs explosion..." This conclusion involves an unachievable criterion, that of anticipating problems greater than those indicated.
There must be some indication of a diffi-culty for it to be perceived.
In this case, the potential for buildup of explosive gases was recognized, and action was taken to prevent such a buildup (restoration of icop seals).
That action proved inadequate, with the apparent cause being faulty refilling of loop seals.
The licensee's corrective actions do prevent recur-rence of buildup of explosive gases in the confined space at the base of the stack.
P, age 13, Summary Paragraph.
The report states:
"The poor performance of the plant during required inspections and the obvious laxity of physical security measures is indicative of a general failure by the utility to accomplish the exacting standards required for continued operation of nuclear power plants." We do not consider this plant to be a poor performer during inspections.
It has been acceptable and improving, and the recent noncompliance history is cne indicator which confirms that improvement.
The security conclusions by the
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. continued 6
25 Jay ;g79 investigator are not based upon functional testing of facility security.
Security at Millstone meets established requirements when the corrective actions taken on inspection findings are considered.
Page 13, Summary Paragraph.
The report states:
"Unless there are scme rather sweeping revisions of the past and current practices at plants such as Millstone, a future nuclear accident could have far more serious censequences.
To this, the statement of the Millstone guard that 'we were lucky' could have a hollow ring indeed."
It is our position that practices
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at Millstone Unit One have substantially improved over the years, and that continued regular licensee and NRC review and evaluation will result in continued improvement.
It is also our position that the quoted statement by the Millstone guard falls in the category of gossip and is not an evaluation from a source competent in nuclear engineering and knowledgeable about all the circumstances of this event.
Reliance on such speculative cccment is improper.
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5 JAll 1978 ENCLOSURE 2 MILLSTONE UNIT ONE ENFORCEMENT HISTORY 1975 NONCCMPLIANCES 1.
75-02 Failure to retain HEPA filter test records.
2.
75-04 Contrary to Technical Specification 6.4. A.7, control room alarm book for operator action on malfunctions / alarms was implemented without required review / approval.
3.
75-06 Contrary to Technical Specification 3.8.C.4, the licensee released radioactive material without meeting the requirements of Technical Specification 3.8.C.2 & 3 and failed to follow the procedures re-quired by Technical Specification 4.8.E.
4.
75-06 Contrary to Technical Specification 3.8.C.1, the licensee failed to continuously monitor liquid effluents on March 27 & 30, 1975.
5.
75-07 A.
Contrary to 10 CFR 50, Appendix B, Criterion I, and the Millstone Unit 1 Quality Assurance Plan, Section F.4.1.2, the quality assurance function of verifying by checking and inspection, that activities affecting the safety-related functions at the plant have been correctly perfon1ed, had not been implemented in that: 1.
Only limited pro-cedures to implement the QC coordinator's function of checking, veri-fying and inspecting quality related activities and had been issued; and further the QC coordinator was not performing this required function.
2.
No required independent inspection was being performed.
6.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion VI, the Unit 1 QA Plan, Section F.4.6 and/or Section 6.4.9 and Section 6.3 1 inadequate control was identified as follows: (1) The latest revision of the iodine determination procedure was not available to technicians per-forming the analysis.
(Corrected during the inspection) (2) Engineering
2 25 JAN 1978.
drawing no.' MPL-1500-729E592 sheet 1 reflected revision 8 in the corporate office and revision 9 in the site file.
(3) The drawing summary booklet was not maintained to show current-drawings and revisions.
(4) Station and standing orders were not reviewed by a r
committee appointed by' the station superintendent or PORC as rr.uired by Admin.. Control Procedure 107.'
1 7.
75-07 i
C.
Contrary to 10 CFR 50, Appendix B, Criterion XII, and the Unit l Quality Assurance Plan, Section-F-4.12, the following examples of I
-failure to calibrate and/or failure to apply calibration controls were identified:
(1) Failure to calibrate and/or apply calibration controls to -the following safety-related Unit 1 instruments: (a)
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SQRT's 250-9A, 9B, SC and 9D; (B) TS-ll50; (c) LT-1623.
(2) Failure c
to calibrate / standardize the curve / instrument used for determination of primary coolant chloride ion concentration.
l 8.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion Vi the Unit 1 QA Plan, Section F.4.5 and/or TS 6.4. A, Procedures were not followed as follows:
- 1. Contrary to station order QA-5.05, repair of a conduct-ivity cell circuit was made without required job order.
Improperly wired cell resulted in 2 unmonitored radioactive water releases.
- 2. Contrary to station order QA12.-1, usage of instrument QA260 during a safety-related surveillance test was not logged on instrument custody control card.
- 3. Contrary to Admin. Control procedure 103.9, the times for obtaining authorization for startup were not logged in Control Operator's Log on 750314.
- 4. Contrary to Admin.
Control Procedure 103, PORC review and station Supt.
Approval were 1 ---
not completed for iterim changes to procedures 606.12 & 606.23.
9.
75-07.
Contrary to 10 CFR 55, Appendix A, Item 4A; 10 CFR 50.54 (I-1); and the Millstone Point Unit 1 operater requalification program, fourteon (14) of the twenty-seven (27) eligible lice 6 sed operators failed to 1
complete the required annual written examination by December 17, 1974.
Although corrective actions were completed and verified prior to the end of this inspection, an additional response is required concerning actions taken to prevent recurrence.
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2 5 J4n g79 10.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion XVIII, and the North-east Utilities Qaulity Assurance Manual, paragraph 18.5.3, defici-encies identified during an audit conducted January 28, 1975, had not been submitted to NUSCO quality assurance nor was corpcrate management cognizant of' procurement document control findings.
11.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion X, and the Unit 1 Quality Assurance Plan, Section F.4.10.2, there was no installation inspection plan for job order 40433.
t 12.
75-07 Contrary to 10 CFR 50, Appendix B,' Criterion IX, and Unit 1 Ouality i
Assurance Plan, Seciton F.4.9.2, It could not be determined that qualified personnel were used to perform the NDE on job order-50433 and the welding on job order 54087.
13.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion VIII, and the Unit 1 Quality Assurance Plan, Section F.4.8, material issued on job orders 503.:5, 504087 was not controlled in accordance with pro-cedures aJd it could not be determined that the correct material was used to perform the maintenance.-
14.
75-07 Contrary to 10 CFR 50, Appendix B, Criterion XVI, the Unit 1 Quality-Assurance Plan, Section F.4.16, and QA station order 18.01, there has not been effective action taken to correct the inadequacies in i
completing job orders which were identified by the licensee in audit report 74-6 dated June 25, 1974.
15.
75-11 Contrary to 10 CFR 50, Appendix 8, Criterion V, instructions, pro-cedures, and drawings, and Technical Specifications 6.4.A., the following examples of failure to adhere to procedures were identified which related to condition on May 24, 1975 whereby ccmpliance with
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4 25 Jag ag7g Technical Specification 3.7.A.5, "0xygen Concentration" was not de-monstrated by available instrumentation:
(1) Procedure No. 103.1, Revision 0 dated. February 1,1973, which requires. shift supervisor recognition and prompt informing to high supervision of any abnormal plant condition.and such notification was not provided; (2) Procedure No. OP311, Revision 2 dated March 1,1973, which requires valves lACS and 1AC11 to be open whereas normal operating practice is to.
close 1ACS and 1ACll and subject valves were closed.
e 16.
75-11 Centrary to Technical Specification 6.2. A, which requires that any abnormal occurrence shall be reviewed by the plant operations review committe (PORC). Abnormal occurrence 75-4 which occurred on January 29, 1975 had not been reviewed by PORC as of July 1, 1975.
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17.
75-11 Contrary to 10 CFR 50, Appendix B, Criterion VI, " Document Control" which establishes controls for the issuance of documents and QA Station Order 5.03, Revision 2, Section 5.5 -dated March 5,1975, which states in part, " Authorized Copy Holder...shall destroy any out dated or superseded documents in their possession"; control room operating procedures (controlled copy No. 4, did contain on-July 1,1975, operating procedures 603.3.1 Revision dated February 12, 1975 including an incoming change dated February 18,1975 both 4
of which had been superseded by operating procedure 603.3.1, Revision 2 dated February 28, 1975.
18.
75-14 Contrary to 10 CFR 50, Appendix B, Criterion V, and Administrative 1
Procedure No.103, Revision 0 dated February 1,1973, the following examples of failure to follow procedure with respect to required log entries and minimum log requirements were identified:
(1) required entry in the control operator's log at the end of the shift and signed by the control room operators on June 13, 28, 29, 1975 and August 1-4, 1975 was missing; (2) required entry in the control operator's log containing shift, date and operator desig-l nation for one shift on July 23, 1975 was missing; (3) required signature in the shift supervisors log for the one shift on August 5,1975 was missing; (4) required entry in the control operator's log concerning time of obtaining permission for a shutdown on July 27, 1975 was missing.
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75-14 Contrary to Technical Specification 4.10.'A, " Refueling Interlocks" which requires in'part, that "... Prior to'any fuel handling, with the head off the reactor vessel, the refueling interlocks shall be functionally tested." A jumper was' installed'in control room panel 928 dated September 5, 1973 remaining in effect during the 1974 re-fueling outage which bypassed the refueling interlock, (reference Technical Specification 3.10.A, that would be generated if the service platform JIB crane were loaded to handle core or reactor vessel components, and functional testing of.the associated inter-lock was not performed.
20.
75-16
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Contrary to 10 CFR 50, Appendix B, Criterion 16 and Paragraph 2.1.16 of Appendix 1 in document, ' Rad Waste Modification,' which was substitued pursuant to 10 CFR 50.59, NUSCO OA did not take corrective action on a significant audit finding.
(Noncompliance was later withdrawn) 21.
75-16 Contrary to 10 CFR 50, Appendix B, Criterion 16 and Paragraph 2.1.18 of Appendix 1 in document, ' Rad Waste Modification,' NUSCO OA did not perform site audits from September 1975 to presen+
(Noncompliance was later withdrawn) i-22.
75-16 Contrary to 10 CFR 50, Appendix B, Criterinn 8, Paragraph 2.1.8 of Appendix 1 in document, ' Rad Waste Modification,' the licensee did not maintain the appropriate identification of designated safety related pipe in storage.
(Nonccmpliance was later withdrawn) t 23.
75-20 Contrary to the requirement of 10 CFR 20.201(B), surveys'were not made to evaluate the concentrations of airborne radioactive material, to which individuals were exposed in the refueling area on October 1, lo75 and under the reactor vessel head on October 15, 1975.
Subsequent whole. body counts showed that two individuals working in the refueling area, on October 1, received lung burdens about 1 and 3 times the amount standard man would have received if exposed to 10 CFR 20.103 airborne radioactive concentration lim'ts.
It is estimated that long term dose commitments to their lungs resulting from these burdens are about 0.3 and 0.6 rem.
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6 d#8 I978 24.
75 Contrary to Technical Specification ~ Section 6.4.B which requires
' adherence to radiation control procedures and standards, the following were allowed to occur:
.l.
an individual entered'the drained dryer-separator pool on August 29, 1975, an area not authorized on the working RWP.
'2. A contractor commenced grinding at locations in the drywell on October 14, 1975 that had not been surveyed and approved'as required-by the RWP.
Subsequent evaluations indicated
, that regulatory limits were not exceeded.
4 25.
75-20 Contrary to the requirements of 10 CFR 20.203(C)(III), in the ab-sence of specified control devices or positive control of each entry, the access gate to the condensate demineralizer room, a high radiation area, in which radiation levels in excess of one roentgen perhourexistedwasnotlockedonOctqber 14, 1975.
26.
75-20 Contrary to ETS 5.5.3 ecological surveillance procedures were not reviewed prior to implementation.
27.
75-22 Smoking in the cable vault:
There was evidence that cigarettes had been smoked in the cable vault.
This was contrary to the licensea's procedure for. work practices in the cable vault and contrary to 10 CFR 50, Appendix B, Criterion V.
28.
75-23 Contrary to Technical Specification Section 6.11, personnel leaving a controlled area did not monitor for personnel contamination prior to entry into a clean area as required by health physics procedure HPP-919/2919.
29.
75-25 Contrary to Technical Specification Section 4.9.B and to operations procedures 610.1 and 610.2, certain auxiliary electrical systems measurements were not made and recorded as required.
30.
75-25 Contrary to Technical Specification 6.5.3.6, the nuclear review board's meeting, number 21, November 19, 1975, was not properly constituted in that quorum requirements were not met.
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25 Jan 1979 1975 DEVIATIONS 1.
75-02 '
Failure to provide test. connections for off-gas and radwaste building exhaust filters, and failure to conduct filter effective-ness checks.
'2.
'75-22 Deviations frcm ANSI standard N45.2.3-1973:
The licensee's pro-cedure for housekeeping activities at the plant commits to a program based on the requirements of ANSI standard N45.2.3-1973.
Contrary to this standard, there were:
(A) temporary, flanmable penetration-sealing forms still emplaced.
(3) flammable material -accumlated in proximity to open cable trays.
3.
75-22 Response to IE Bulletin 75-04A:
The licensee had committed to pre-pare a procedure specification. addressing the use and control of combustible material and ignition sources, as a response to Inspec-tion and Enforcement Bulletin 75-04A.
The procedure had not been prepared.
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'1976'Noncemoliances
- 11.
- 76-01 Contrary.to Regulatory' Guide 5.20, Section C, Paragraph (c) Physical Capabilities (1) and (2), and the. Accepted Physical Security Plan, i
Section V - Personnel Selection, one guard is not a high school
. graduate'oF equivalent, and the preemployment physical exams do not_
document hearing and sight tests. for all' the guards, 1
'2. 01 Contrary to the. Accepted Physical Security Plan,Section V - Personnel s
-Selection, onefguard was not given the Wonderlic psychological
- exam, two guards over 45 years of age were not given physical's prior, to employment.
3.
76-02
' Contrary to Technical Specification 6.8.1 and Operating Procedure No. 304^, Pavision 6, dated December 30, 1975, Standby Liquid Control System Drain' Valve No. 31, was observed on February 9,1976 not lodked as' required.
4.
'76-52 Contrary to Technical Specification 3.8. A.1, which requires that the gross activity frcm the stack shhll be continuously monitored and recorded and that at least one stack gas monitoring system shall be operable at all times, on August 23, and 26, 1975, a stack gas sample pump tripped and the alternate pump was not inservice for intervals of 10 and five minutes respectively.
Further, these failures were not reported pursuant to Technical Specification 6.6.B.l.
5.
76-04 10 CFR 20.201(b), " Surveys." Contrary to this requirement, surveys were not adequate to assure that individuals working in the restric-t tad area during September, 1975 were prevented frcm being exposed
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in excess of the provision of 10 CFR 20.101.
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2 25 Jan 797g 6.
76-04:
10 CFR 20.101(b), " Exposure' of Individuals to Radiation.irr Re-stricted Areas." Contrary to this requirement, individuals working.
in the restricted area, received whole body exposures in excess of
-3 rem. 'Three individuals received excessive exposures during the third quarter of 1975 and three individuals received excess exposures during the fourth quarter of 1975.
7.
76-05 Co,'trary to Technical Specification 6.8.1, the following examples of ',-ailure to establish and implement procedures were identified:
1 The procedural steps established to detect isolation condenser tube leakage during reactor operation were not implemented.
2.
The material used to fabricate plugs for the' isolation condenser tubes was not controlled in accordance with Station Order'No. 0A 8.01, " Identification and Control of Material, Equipment.and Parts."
3.
The welding procedure provided to weld the tube plugs in the isolation condenser, " Detailed Welding Procedure DP-012," is in-correctly specified and impractical to perform.
8.
76-06 10 CFR 50.54(I-1) states in part:
...The licensee shall not, e>. cept as specifically authorized by the Commission, make a change in an approved operator requalificati time allotted for the orogram, or fre,on program by which-the scope, quency in conducting different parts of the progrr
's<3 creased.
Section V.A of the approved Unit 1 Requalifi" ti. P 3 gram for licensed personnel states in part:
"A tcc -
7 to 80% for a particular category (on the annual exam) w v.e the ~ individual to attend that portion of the lecture t/ies iv-which the score was obtained. ' Contrary to the above, of the 19 individuals obtaining a score of less than 80%
on one or more categories of the 1974 annual exam, none attended that portion of the lecture series for which the score was obtained.
9.
76-06 Section 6.8.1 of Technical Specifications states:
" Written pro-cedures shall be established, implemented and maintained." Pro-cedure 1/2-HP-8.04 states:
...All female employees working in
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s orffrequentingaayportionofa'restrictedareashallhavethe.,5 s
information prov.ided in the Appendix to RG 8.13 ' presented,to them
,e both oral.ly and in written forp.," ' Contrary'to the above,17' feYdle employees l had' no't tad theQequjYed RG 8.15 trainin'g? 1'0weverh -
since they' received theJrequired7 training prior to the end of[t k -ig inspection, no response,is : required.
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76-G7
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The Yicens'ee'sE pre-emplo)Mdtscreeningoftheguardforcewasnot completely in accordanca with the accepted physical security plan.
L ll.
76-07 e
The licensee did not maintain the required control procddures for',
keys and key cards issued to operating personnel, q.
12.
76-07
' The licensee did not maintain the required. records for control of key cards issued to Hartford Electric Light' Company personnel.
13~,76-08 10'CFR 70.51(c),
ments," fequires[" Material Balance, Inventory, and Records Requi,re-
"Each licensee whu is authorized to possess at any one time special nuclear material in a quantity exceeding one s
effective kilogram of special nuclear material shall establish, maintain and follow written material control and accounting pro-cedures which are sufficient to enable the licensee to account f,or the special nuclear mattr'al in his passession kder license."'
Contrary to the a bove, the written material cont lcbl and accounting T
4 ptocedures, as e;tablished in Reactor Engineerfng7rocedure No.
1001/21001, centain' procedural requirements which are not' currently being followid by plant personnel.
l 14.
76-08
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' ~10 CFR 70.51(b), "M$Q rial Balance, Inventory, and Records Require' ments," requires "Each licensee shall keep records showing the r5ceipt, inventory (including location), disposal, acquisition,
. import, export, and transfer of all special nuclear material ir.' his
, possession regardless of its origin or method of acquisition."
Contrary to the above, during the period covered by this inspection 2
the< licensee did not maintain. on a current basis the "ENM, Inventory Account" and " Summary,of Fuel" L' edger located at the reactor site.
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4 25 3 9 3979 15.
76-09 Technical Specification 6.8.2 requires that changes to written procedures be reviewed by the PORC and approved by the Plant
~ Superintendent prior to their implementation.
Contrary to the above, a change was implemented which affected the acceptance criteria of Maintenance Procedure ICT-1, Revision 0, prior to the required review and approval of the change.
flamely, the Mainten-ance Supervisor changed the tube inside DIA tooling tolerance to-
.015 inches from.005 inches for the tubes installed during the retubing of the isolation condenser.
Subsequent to the identifi-cation of the noncompliance and prior to the inspector leaving the site, the procedure change was reviewed by the PORC and approved by the Plant Superintendent; the Maintenance Supervisor was informed
~-
of the procedural requirements for procedure changes.
16.
76-15 Technical Specification 6.5.3.7.E raquires that the fluclear Review Board (flRB) review all violations of Technical Specifications.
Contrary to the above, flRS meeting minutes did not reflect that the NRB had reviewed violations of Technical Specifications and the Code of Federal Regulations identified in USflRC Office of Inspec-tion and Enforcement Inspection Reports dated December 18, 1975 (75-20), December 12.1975(75-22), and January 20, 1976 (75-25),
17.
75-15 10 CFR 50, Appendix B, Criterion VI states in part:
... Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto which arescribe all activities affecting quality.", and that "These measures shall assure that documents, including changes,... are distributed to and used at the location where the prescribed activ-ity is performed." Contrary to the above, the following examples are given:
(1) Ten of twenty drawings had obsolete revision numbers.
(2) Two Drawings missing from file.
(3) Two drawings not worked "under revision."
(4) Controlled copy of FSAR not updated.
18.
76-15 10 CFR 50, Appendix 0. Criterion XVII, states in part that, " Audit results shall be documented and reviewed by management having responsibility in the area audited...."
The accepted Quality
5 25 Jan 1973 Assurance Plan, Section F.4.0 of the FSAR, states, "The fiortheast Utilities Quality Assurance Program...is defined in the flortheast Utilities Quality Assurance Manual...."
flEQAM, Paragraph 18.5.3.1.2, requires that a report of plant contractor and engineering service organization audits be forwarded to the NUSCO Manager of QA.
Contrary to the above, no audit reports other than computerized listings of unresolved audit findings were forwarded for onsite audits of contractors and engineering service organizations.
19.
76-15 10 CFR 50, Appendix B, Criterion V, states in part, "... Activities affecting quality shall...be accomplished in accordance with...
procedures...." 0A Station Order No. 5.05, Revision 5, dated March 8, 1976, relating to job orders, requires in part, "...The Shift Supervisor's signature which includes approval of retest requirements and authorizes commencement of work...."
Contrary to the above, Job Orders R-030-76 dated March 20, 1976 and R-032-76 dated March 24, 1976, had not been authorized by a Shift Supervisor.
20.
76-16 10 CFR 50, Appendix E, Item IV, requires that emergency plans contain, " Provisions for training of employees of the licensee who are assigned specific authority and responsibility in the event of an emergency." The licensee's Emergency Plan, Paragraph III states,
" Periodic retraining will be conducted in order to maintain personnel proficiencies."
Technical Specification 6.8.1 require; that,
"'Aritten procedures shall be implemented and maintained covering emergency plan implementation." Contrary to the above require-ments, you failed to develop and implement procedures for an emer-gency plan training program.
21.
76-16 Technical Specification 6.8.1 states, "'Aritten procedures shall be implemented and maintained covering emergency plan implementation."
OP 501-2501, Page 5, Paragraph 4.2.1.3.2 states, " Dispatch a plant equipment operator to collect information for evaluation frcm the onsite monitoring stations.
Use a clipboard provided for this purpose - Appendix 1."
OP 501-2501, Page 7, Paragraph 4.2.6.1 states, "Obtain a radiation survey meter, portable radio, and the
~
.EHclosure 2 25 JBN 1979 g
procedure / map clipboard from the Control Room - Appendix 1."
OP.
501-2501, Appendix'I, Page 1, states, "Obtain a walkie-talkie:
located in the Control Room... Maintain' constant communication with the Control Room." Contrary to the above,10P 501-2501 could not be implemented in the event of an emergency, as required due to the nonavailability of portable radios and procedure / map clipboards in the control room.
- 22. :76-18 Contrary to Sections.4 and 8, and Attachment 1 of the Accepted Site Security Plan unarmed watchmen were. assigned to posts requiring armed guards.
23.
76-21 Technical Specification 6.8.3 states, in part:
... Temporary changes to procedures...may be made, provided the change is docu-mented, reviewed by the PORC, and approved by the Plant Superin-tendent within seven days of implementation."
Contrary to the above, changes were made to operating procedures OP-202 " Plant Heat Up" on July 20, 1976 and OP-205 " Planned Shutdown to Hot Standby or Hot Shutdown" on July 16, 1976 that affected the operation of the f
facility, without subsequent approval by the Plant Superintendent.
24.
76-22 Contrary to 10 CFR 50.59, a 25 PSIG air line to the Drywell MY System was designed and installed to penetrate the containment without safety review and without the containment isolation pro-
.-~
visions required by Criterion 56 of 10 CFR 50, Appendix A.
25, 76-23 10 CFR 50, Appendix B, Criterion VI " Measures established to control issuance of documents including changes which prescribe all activi-tics affecting quality... Distribution to and used at location where act is being performed." The accepted QA Plan, Section F.4.6.2 of FSAR states a list of approved drawings and their latest applicable revisions are maintainta in a Drawing Summary Booklet.
Further and interrelated 10 CFR 50, Appendix B, Criterion XVIII states a compre-hensive system of audits shall be carried out to verify compliance j
with all aspects of QA Program.
Contrary to the above, a review u
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identified as not reflecting. latest applicable revision listing still indicated incorrect revision numbers when compared to site drawing file.
Additionally,anaudit'(internalandundated)'had fciled to disclose this continuing and uncorrected item.
.26.
76-25 Technical Specification (TS) 6.8.2 requires that written procedures and changes thereto be reviewed by the Plant _ Operation Review Committee (PORC) and_ approved by the Plant Superintendent prior _to their implementation.
Contrary to the above, Procedure ISI-0A213,
-(Revision 1, dated Octobdr 7,1976) was being utilized on October 14, 1976 to conduct volumetric examinations of welds in safety related equipment prior to its required review and approval.
27, 76-29 Millstone Nuclear Power Station Standby Order No.1-6.10. "Radwaste Shipments," Section 6.'1, Part F, requires that once a Low Specific Activity'(LSA) shipment box is loaded, it must be covered and banded prior to' loading and shipment from the site.
Contrary to this requirement, an LSA shipment box'was released from the site on o
September 30, 1976 without being banded.
28.
76-30 Contrary to Technical Specification 4.7.C.l.C, the Secondary Con-tainment Tightness Test was not performed during calm wind condi-tiens (less than 5 mph).
i 29.
76-32 I
Contrary to Operating Procedure 106, Revision 0, on November 12, 1976 nuclear instrumentation indicating that an unplanned criticality and occurred was not believed and was not proven faulty with direct comparison with other instruments or by functional testing or cali-i bration in that the Shift Supervisor dismissed the automatic reactor trip as being the result of a spurious signal.
And continued with additional control rod withdrawals.
On November 1, 1976, the Shift Supervisor did not prcmptly inform higher management of the unplanned l
criticality and autcmatic reactor trip which occurred at 4:49 a.m.
The notification was not made until 7:30 a.m. when higher manage-ment reported for the start of the day's work.
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-Enclosure 2 8
25 Jgn 1979 1
30.
76-32 Contrary? to 20.203(c)(2), on havember 12,1976, between'the hours of 12 midnight and approximately 6:00 a.m., the drywell, a-high radiation area which had existed for more than 30 days, (1) was not equipped ~with.a control device to reduce radiation levels,:(2)-was not equipped with a control' device to alarm before entry and (3) was unlocked and standing open..and positive; control was not main-tained over each individual entry.
31.
76-32 Contrary ~to Technica1' Specification Section 6.8.1, Operating Pro-ceaure OP 1408 - Set. 3.2.6, and Procedure 631.10, on November 12,.
~1976, while performing the specified shutdown margin test, Control Rod 46-19 was erroneously selected and withdrawn to a predetermined position and~ unplanned criticality and automatic reactor. trip occurred at 4:49 a.m. following withdrawal of Control Rod 46-23.-
Between 4:50 and 4:58 a.m., further shutdown margin testing was
. performed without recognition of the previous rod selection error..
Control Rod 46-23 was positioned as. specified.
Again Control Pod 46-19 was erroneously selected and withdrawn to a predetermined position and Control Rod 46-23 was then withdrawn.
32.
76-32 Technical Specification 3.3.B.3.8 requires when the reactor is in a startup or run mode below 10?. rated power, no rods shall be moved unless RWM is operable or a second operator or engineer verifies that an operator at the reactor console is following control rod
. program.
Contrary to the above, on October 12, 1976, with the reactor mode switch in startup mode and RWM bypassed, control rods were moved for shutdown margin testing without independent operator or engineer verifying that operator at reactor console was following control rod program.
- 33. i.76-33 Technical Specification 4.7.A.4.A, periodic operability tests states in part "Once each month each suppression chamber drywell vacuum breakers shall be exercised through one open and close cycle and visually inspected.
Contrary to the above, on October 20, 1976, the surveillance testing of the vacuum breaker were exempted from testing based on Plant Operations Review Committee decision
. Enclosure 2-9.
2'51.tcu 7973
..without submittal of an amendment to the Technical Specification
~ ~
requesting exemption for scheduled ~ surveillance testing during a refueling outage.
34, 76-38
- Section 3.2.1 and Table 3.2.1 of th'e ETS for Units 1 and 2 require, in part, that the environmental gamma dose at the specified loca-tions be measured on.a monthly and on a semi-annual basis.
Con-trary to this requirement, the environmental ganma dose.was not s
measured on a semi-annual basis at any of the required stations
.'during the second half of 1976.
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' Enclosure 2 2 5,I n toyg 1977' NONCOMPLIANCES lENTERED INTO FILE) 1.
77-03 Contrary to Technical' Specification 6.5.1.6(E). The 'PORC failed to' review violations of Technical Specifications identified in NRC:I
-Reports 50-245/76-15, 76-30.
2.-
77-03 Contrary 'to 10_CFR 50, Appendix B, Criterion XVIII,_ Audit-results for audits A60008 were not published within_30 days.
250 and.300
~~
days, respectively, had elapsed.
3.
77-03 Contrary to 10 CFR 50, Appendix B, Criterion XVIII, Records of audit A600023 were not retreivable.
Records we.re produced prio.r to the end of r.he inspection.
4.
77-03 Contrary to Technical Specification 6.8.2, the PORC failed to review procedures QA 5.05 and OP 501/2501.
OP 501/2501 was reviewed before the inspection ended.
5.
77-03 Contrary to 10_ CFR 50, Appendix B, Criterion XV, the licensee failed to initiate and NCR following receipt of an item which had been rejected during a supplier source inspection.
An NCR is now
. issued, no response required.
6.
77-03 Contrary to 10 CFR 50, Appendix B, Criterion VI, there was no objective evidence that the department head had reviewed drawing change requests 1977 and 14176.
7.
77-03 Contrary to 10 CFR 50, Appendix B, Criterion II, the operations QA manager failed to regularly review the status and adequacy of the audit portion of the QA program.
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77-03 Failure to barricade, post and control a high radiation area as required by Technical Specifications 6.13.1. A.
9.
77-03 Section 6.1.9 of the TP for operating License No. DPR-21 requires that written procedures be established, implemented and maintained covering the activities referenced in Appendix "A" of Reg. Guide 1.33, November 1972.
Reg. Guide 1.33 and Administrative Control Procedure ACP-QA-3.02 require procedures that cover radiation control.
Procedure HPP 915/2915, Rev. 5, dated 10/1/76, requires that known contaminated areas with greater than 100,000 DPM/CM2 loose surface contamination be surveyed for airborne contamination on a daily basis prior to issuance of a Radiation Work Permit (RWP) for work in that area.
Contrary to the above, on March 7,1977, a RWP (RWP-77-0777-0-1) was issued for work in an area with loose surface contamination greater than 100,000 DPM without a prior airborne contamination survey.
Similar occurrencas happened on January 24, 1977 (RWP-77-0273-0-1), January 25,1977 (RWP-77-0284-D-1) and January 27.(RWP-77-0338-D-1).
<10.
77-03 Contrary to T.S. table 4.2.1 from 6/14/77 to 10/27/77, this surveillance requirement, to calibrate isolation condenser isolation functions, had not been conducted within the required frequency which included a maximum allowable extension of 25 percent c' test interval.
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Enclosure'2-2 5'JAn 1973 1977 fl0tlCOMPLIANCES (NOT YET FILED) 11.
P_re-employment screening procedures -of securi ty -personnel -did not_
meet-regulatory requirements.
-12.
Requalification requirements for security personnel were not' met.
- 13.
Regulatory requirements for-designated licensee vehicles were not met.
-14.
Regul.atory' requirements for package inspection were not met,
- 15.. Required custody records for security devices were not kept.
,16.
Required maintenance records for security devices 'were not kept.
.17.
Failure to post' radiation area.
, 18.
Failure to follow radiation protection procedure.
19.
Failure to control hWh radiation area.
20.
Failure' to post high radiation ~ area.
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_1977 DEVIATIONS 1.
77-03 Contrary to the conmitment in licensee's letter to itRR dated May 3, 1976, procedure QA 18.01 did not include all requirements of AtlSI N45.2.12.
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