responds to nrc 960412 ltr re violations noted in insp

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Utilities System s,theut watie. suwa comgmy-

*"P.O. Box 2701Iartford, Cr 06141-0270

(203) 665-5000

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May 24, 1996Docket ~Nos.'50-245

50-336' )B15713

Re: 10CFR2.201

U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555 i

! Millstone Nuclear Power Station, Unit Nos. 1 and 2Reply to a Notice of Violation

NRC Combined Inspection 50-245/96-01;50-336/96-01; 50-423/96-01

! In a letter dated April 12, 1996,III the NRC Staff transmitted aNotice of Violation (NOV) relating to NRC Inspection Report Nos. ,

50-245/96-01; 50-336/96-01; and 50-423/96-01. The report |,

discusses the results of the safety inspection conducted on iFebruary 8, 1996, through March 18, 1996, at the MillstoneStation. Based on the results of the Staff's inspection, one i

violation is cited at Millstone Unit No. 1, for inadequate post- |maintenance ratesting of safety related breakers (VIO 245/96-01-02). The inspection report also requests additionalinformation regarding a previous Millstone Unit No. 1 violation, |concerning the use of self-contained breathing apparatus (SCBA) I

for control room habitability (VIO 245/95-07-01). One violationis cited at Millstone Unit No. 2, for failure to establish andimplement adequate testing procedures for Anticipated TransientsWithout Scram (ATWS) mitigating system actuating circuitry (VIO336/96-01-06).

The Staff requested that Northeast Nuclear Energy Company (NNECO) |respond within 30 days of receipt of the letter transmitting theNOV. Accordingly, Attachment 1 to this letter provides NNECO'sreply to the NOV, on behalf of Millstone Unit No. 1, pursuant tothe provisions of 10CFR2.201. Attachment 2 provides therequested information regarding control room SCBA. Attachment 3provides NNECO's response to the NOV, on behalf of Millstone UnitNo. 2, pursuant to the provisions of 10CFR2.201.

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III J. P. Durr letter to T. C. Feigenbaum, "NRC Combined ggInspection 50-245/96-01; 50-336/96-01; 50-423/96-01 andNotice of Violation," dated April 12, 1996.

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U.S Nuclear Regulatory CommissionB15713/

The following are NNECO's commitments made within this letter.All other statements are for information only.

Unit 1 - Violation A Commitments

B15713-1 Operations Department expectations regarding SeniorReactor Operator (SRO) responsibilities for work orderretest review will be reemphasized with all OperationsDepartment SROs on shift.

B15713-2 Recurring preventive maintenance (PM) work orders arebeing reviewed and upgraded to increase overall detailand include more explicit retest requirements.Recurring PM work orders with the previous format areno longer issued to the field.

B15713-3 Specific work order training will be conducted for unitpersonnel involved in work planning and execution,including the GTS coordinators. This training will be

; completed by December 15, 199G.

B15713-4 Generation Test Services (GTS) has initiated adepartment self-assessment to identify and addressissues on work order quality. This assessment will becompleted by June 30, 1996.

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Unit 1 - Additional SCBA Information Commitments

B15713-5 The original 2 hour SCBA air supply will be increasedto a 6 hour supply, using SCOTT 4.5 SCBA with 30 one-hour replacement bottles, by July 31, 1996.

B15713-6 The Technical Requirements Manual (TRM) will be revisedto delete the SCOTT IIA's, and also require the voiceamplification devices for each control room SCBA andprescription eyeglass lens inserts as necessary. TheseTRM revisions will be completed by July 15, 1996.

B15713-7 Simulator training exercises using SCBA will be'

conducted for each active shift crew during the: upcoming training cycle in June and July, 1996. The

Health Facility will be represented at the simulatorexercises, to evaluate stress-related capabilitiesassociated with prolonged use of SCBA in the controlroom.

B15713-8 Lessons learned from the simulator exercises will beused to enhance the qualification process prior to unitstartup.

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B15713-9 A new procedure will be developed to provide guidanceon the use of SCBA in the control room. Entryconditions for the new procedure will include therecommendation from Health Physics to don SCBA based onsurveys per Emergency Plan Operating Procedure 4426, ,

"On-Site Emergency Radiological Surveys," and thecontrol room ventilation system high radiation alarm.The new procedure will be developed based on datagathered during the simulator exercises, and willaddress shift turnover while using SCBA. Thisprocedure will be approved for use prior to unitstartup.

B15713-10 Emergency preparedness procedures will be revised byJune 14, 1996, to identify diverse breathing air supplysources, including offsite facilities within and

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outside the Emergency Planning Zone. The procedurerevisions will include precautions regarding thepotential for contamination of compressed air during aradiological accident.

Unit 2 - violation a commit m ts

B15713-11 I&C personnel involved in modifying procedures arebeing re-trained in the use of the Generation RecordsInformation Tracking System (GRITS) in order to be ableto access the current revision to any drawing and anyopen design change notices (DCNs).

315713-12 The Design Control Manual will be revised to betterassure that design changes are reviewed for theirimpact on Department Procedures before they are

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performed.

B15713-13 The procedure SP 2402Q, "ATWS Setpoint FunctionalTest," will be revised to adequately verify the plantdesign. This will include verifying the status of allof the contacts on the 94A/ DSS and 94B/ DSS relays anddocumenting the status of the contacts on Attachment 3of the procedure.

B15713-14 The Millstone Procedure Writer's Guide will be reviewedto assure that attachments which are for informationonly are clearly identified. Also, the Guide will bereviewed to assure that verifications are initialedwhere appropriate to document that acceptance criteriaare met.

B15713-15 The unit is currently shutdown. The procedure, SP2402Q, when revised, will be performed prior to entryinto Mode 2.

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If you have-any questions regarding information contained herein,please contact Mr. R. W. Walpole at (860) 440-2191.

Very truly yours|! NORTHEAST NUCLEAR ENERGY COMPANY

FOR: T. C. Feigenbaum,

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Executive Vice President andChief Nuclear Officer

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''BY: E. DeBarbaVice President - NuclearTechnical Services

cc: T. T. Martin, Region I AdministratorJ. W. Andersen, NRC Project Manager, Millstone Unit No. 1T. A. Easlick, Senior Resident Inspector, Millstone

Unit No. 1 |

D. G. Mcdonald, Jr. NRC Project Manager, Millstone Unit No. 2 i

P. D. Swetland, Senior Resident Inspector, Millstone UnitNo. 2

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Docket No. 50-245B15713

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Attachment 1

Millstone Nuclear Power Station, Unit No. 1i

Reply to a Notice of Violation I


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U.S. Nuclear Regulatory CommissionB15713/ Attachment No. 1/Page 1

1- Millstone Nuclear Power Station, Unit No. 1Reply to a Notice of Violation

i NRC Combined Inspection 50-245/96-01;j 50-336/96-01; 50-423/96-0111

j Restatement of Violation (Violation A): |;'

Unit 1 Technical Specification 6.8.1, " Procedures," requires thati written procedures shall be established covering the activitiesj recommended in Appendix A to Regulatory Guide (RG) 1.33, " Quality| Assurance Program Requirements (Operations) , " dated February; 1978. Section 9.a. of Appendix A to RG 1.33 states maintenance! that can affect the performance of safety-related equipmenti should be properly pre-planned and performed in accordance withI written procedures, documented instructions or drawings! appropriate to the circumstances. Procedure WC-1, " Work Control i

Process," -requires that operations review the test data againstj the acceptance criteria and sign the AWO " Accepted by OPS" line i

j to indicate acceptance of the AWO package and post maintenance |

testing. WC-1 also requires that operations review the AWO and2

i verify the specified retest is adequate for the work performed.Procedure C-WPC-3, " Post-Maintenance Testing," requires that aretest be specified if the maintenance performed is invasive or

j requires disassembly.

j Contrary to the above, on November 11, 1995 and November 26, 1995AWOs 95-06067 and 95-06136, respectively, were reviewed and4

operations signed the " Accepted by OPS" line of the AWOs.

| indicating acceptance of the AWO package and post maintenance! testing. The work performed involved disassembly of safety| related load center feeder breakers and the operations review didj identify that a retest was necessary. The equipment was returnedi to an operable status without verifying that the breaker wouldj trip electrically. These breakers subsequently failed to tripi open during unrelated system testing.(.

! This is a Severity Level IV Violation (Supplement I).

Reason for the Violations

Inadeauate Breaker Retest and Subsecuent Breaker Failures

! Automated work orders (AWOs) 6067 and 6136 were used to performj preventive maintenance (PM) on 480V load center breakers 480-12C-

13B and 480-12C-18A, respectively. These PMs were performed as{ part of a new breaker maintenance program utilizing a new! procedure, CPT1437D, " General Electric Type AK-2A-25 Air Circuitj Breaker Maintenance and Inspection."i

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Subsequent to the PMs, the two breakers failed to trip afterreceiving a load shed signal as part of testing per SP 617.1" Loss of Normal Power Relays". Investigation revealed that 480-12C-18A failed to trip because of a broken lead between thebreaker secondary disconnect and the trip circuit, and 480-12C-13B failed to trip due to a mis-aligned linkage on the breakerauxiliary switch.

The failure of breaker 480-12C-13B was caused by an inadequateprocedure. The PM procedure did not have adequate detail toguide the individual performing the PM. Consequently, theindividual performing the PM did not properly align the auxiliary!

switch to the mechanism of the circuit breaker, thus preventingit from opening upon receipt of an electric trip signal.Furthermore, the procedure did not provide sufficient guidancefor the detection of the switch mis-alignment.

The cause of the failure of breaker 480-12C-18A is unknown. Thebroken wire was not detected during the PM. Again, CPT1437D didnot have sufficient guidance for the detection of the broken,

secondary disconnect wire.

Neither breaker deficiency was detected during post-maintenancetesting. The breakers were tested per procedure PT1466, 'MP1 LowVoltage Power Circuit Breaker Test'. Although the procedure didverify the electric close and trip functions for electricallyoperated breakers following maintenance the procedure did notinclude steps to verify the proper operation of the electrical,

i trip of manually operated breakers (both breakers are manuallyoperated).,

Overall Ouality of AWOs

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The Generation Test Services (GTS) group has historically beenresponsible for creating its own AWOs at the MP1, MP2, MP3 andHaddam Neck plants. However, in a recent change at the MP2, MP3and Haddam Neck plants, preparation of GTS AWOs is now theresponsibility of the Work Planning organization. The transitionof responsibility to Work Planning for MP1 was planned to occurfollowing the current refueling outage (RFO-15). The GTS AWOs at"

MP1 were typically prepared by the Test Coordinators, who arealso assigned responsibilities unrelated to work orderpreparation. During periods of increased GTS workload, such asrefueling outages, increased demands are placed on the TestCoordinators, thereby detracting from their ability to dedicateadequate attention to AWO preparation.

Within the GTS group there were no set standards for AWOs. Thereis and has been no communication to the coordinators regarding

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!U.S. Nuclear Regulatory CommissionB15713/ Attachment No. 1/Page 3,

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| unit and regulatory expectations with respect to AWOs.Additionally, there has been no program or ongoing training to3

j keep the GTS coordinators current with AWO requirements.'

The expectations of the GTS supervisor with respect to theaccuracy, completeness and the overall acceptability of acompleted AWO packages were inadequate. I

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|Operations Denartment Accentance of Work Orders I

5 During Operations Department review of AWOs 6067 and 6136, over-reliance on documentation and acceptability of ratests was placedI

on the GTS Department. Procedure PT 1466, "MP1 Low Voltage Power ;

Circuit Breaker Test," was not reviewed in sufficient detail to j' note that manually operated breakers were tested to a lesser j

degree than electrically operated breakers. ||i corrective Steps Taken and Results Achieved:I'

; Procedure CPT1437D " General Electric Type AK-2A-25 Air Circuitj Breaker Maintenance and Inspection" has been revised to! incorporate guidance for the proper alignment of the auxiliaryi switch linkage. Additional steps were added to verify the

electric trip of manual breakers equipped with a shunt tripdevice. Breakers 480-12C-13B and 480-12C-18A were repaired viawork orders.

; The GTS supervisor's expectations regarding work order qualityi have been raised. The GTS unit supervisor periodically reviews

work orders prior to issuance to the field, to ensure theseexpectations are met.

The Work Planning organization has taken over responsibility ofGTS work orders, and a dedicated planner is assigned to GTS.

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Corrective Steps That Will Be Taken to Avoid Further violations!

Prior to work order release for work in the field, the Operations,

i Department Senior Reactor Operator (SRO) is expected and requiredto review the work order retest for completeness. This review

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! must be of sufficient detail to assure: |

} * The retest is applicable and of sufficient depth to includetesting of all worked items. i

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e Referenced procedures and/or surveillance tests are current; and all expected plant responses are detailed.

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Retests that fail to meet this criteria are not released to thefield. Work orders will be held or returned until such time asthe SRO is confident the retest is accurate and correct aswritten. This expectation will be reemphasized with allOperations Department SROs on shift.

All recurring PM work orders are being reviewed and upgraded toincrease overall detail and include more explicit retestrequirements. Recurring PM work orders with the previous formatare no longer issued to the field.

Specific work order training will be conducted for unit personnelinvolved in work planning and execution, including the GTScoordinators. This training will be completed by December 15,1996.

GTS has initiated a department self assessment to identify andaddress issues on work order quality. This assessment will becompleted by June 30, 1996.

Following the identification of these issues, Unit 1 managementinitiated a self assessment of work control activities for theentire unit. The recommendations of the unit self assessmentwill be incorporated into the current work control improvementinitiatives on Unit 1. As part of this effort, Unit 1 willtransfer the responsibility for Maintenance Services AWOs to theWork Planning organization by December 1, 1996.

Date When Full compliance Will Be Achievedt

Millstone Unit No. 1 is currently in full compliance with theadministrative controls of Technical Specification 6.8.1regarding the procedural requirements for breaker ratesting.

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Docket No. 50-245B15713

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Attachment 2

Millstone Nuclear Power Station, Unit No. 1

Reply to a Request for Additional InformationNRC Combined Inspection 50-245/96-01;

50-336/96-01; 50-423/96-01|

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U.S. Nuclear Regulatory Commission'

B15713/ Attachment 2/Page 1

Millstone Nuclear Power Station, Unit No. 1Reply to Request for Additional Information

NRC Violation 50-245/95-07-01

Restatement of NRC Concern

NU letter, dated November 7, 1984, established the engineeringbases for Unit 1 control room habitability. The licensee stated4

that radiological calculations indicated that without the control;

! room habitability modifications, control room personnel exposurewould be less than 5 rem whole body dose. Additionally, thyroidexposures would be less than the 30 rem criterion if operatorsremained on self-contained breathing apparatus (SCBA) when

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required. As a result of the review of NUREG-0737 ItemIII.D.3.4, NNECO provided additional SCBA for the control roomoperators in accordance with Staff criteria. By letter, datedJuly 1, 1985, the NRC accepted the foregoing engineering basis tosupport the issuance of amendment 103 to license DPR 21.

In NRC Inspection Report 245/95-07 a violation was issued for notestablishing measures to ensure that applicable regulatoryrequirements and design bases for Unit 1 control roomhabitability were correctly translated into specifications,procedures and instructions, in that the means for maintainingviable SCBA capability for each person in the control room werenot translated into procedures. Specifically, there were noadministrative controls in place to define or maintain controlroom operator certification for SCBA use. The lack of thesecontrol measures resulted in a lapse in SCBA qualification, by upto 30 months, for 2 of 5 Of the minimum shift complement ofcontrol room operators. The licensee reported expired SCBAqualifications on February 15, 1995, in accordance with 10 CFR50.72 (b) (1) (ii) (B) , as a condition that is outside the designbasis of the plant.

Procedure ACP 6.05, " Respiratory Protection Program," requiresthat respirator qualification, which includes SCBAs, bemaintained on an annual basis. Generally this requalificationincludes a medical certification, and a training session whichincludes practice donning and removing the SCBA. Although thereis no specific procedural requirement for personnel stresstesting, procedure NEO 2.23, " Medical Policies for RadiologicallyControlled Area Access, Respiratory Protection Users, RadiationExposure Restrictions and On-Call Emergency Workers," requiresthat an annual determination by a physician that personnel arephysically able to use the respiratory equipment. In the past,

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U.S. Nuclear Regulatory CommissionB15713/ Attachment 2/Page 2

the licensee's medical staff has required stress tests formedical certification of SCBA users.

The licensee established a minimum number of SCBA and SCBAbottles. These SCBA and spare air bottles are inspected andfunctionally tested monthly, providing adequate assurance thatthey will perform reliably when needed. There are nine SCBA kitswithin the control room. There are 25 spara air tanks in theturbine building, in proximity to the control room.

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The licensee performed a limited validation of operator SCBA use |!

in the simulator to determine if communication was possible while |

wearing a SCBA. The licensee determined that use of the plant '

paging system could not be performed adequately without thereliance on a voice amplification system. The licenseesubsequently verified that some of the control room SCBA kits had';

the necessary voice amplification equipment. When thecommunication verification was performed, it was done using a,

Scott 4.5 SCBA, which is a different model than the Scott IIAi SCBA, credited for control room habitability.t

In the licensee's June 12, 1995 response to the violation, itstated that the Unit 1 Technical Requirements Manual was updatedto state that annual medical qualification is required for allpersonnel expected to wear SCBAs per NEO 2.23, Medical Policiesfor Radiologically Controlled Area Access, Respiratory ProtectionUsers, Radiation Exposure Restrictions and On-Call Emergency

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1 Workers. The response further states that there is a two hourair supply available to the operators.

NRC Review

The inspector reviewed the licensee's actions and response to theviolation and determined that the licensee did not establish atechnical basis related to the design basis accident for whichthe control room SCBA would be needed. This would provide thebasis for the number of SCBA's, the number of bottles and any<

necessary resupply during the accident recovery phase.Additionally, it would provide a basis for procedures to copewith any shift changes needed, operator training, equipmentmanipulation, and associated activities.

This issue (VIO 245/95-07-01) remains open pending resolution ofthese inspection findings as well as further NRC assessment ofwhether these findings collectively represent an inadequatecorrective action effort in this area.

; NMECO Response

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Background

In June, 1994, the failure to maintain current SCBA qualification'

i for all licensed operators, which resulted in NRC Violation245/95-07-01, was addressed via NNECO's Plant Information Report

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(PIR) process, which pre-dates the current Adverse ConditionResolution (ACR) proc-ass. An initial operability determinationwas performed to assess the effect of the SCBA qualificationissue on control room habitability. The initial operabilitydetermination concluded there was reasonable assurance that

. habitability would be maintained, based in part on the number of"

operators with current qualifications (at the time of discovery),; and the availability and usability of the SCBA. The issue was; initially considered to be not reportable based on the

determination that control room habitability would not beadversely affected. The near term corrective action was toprovide SCBA qualification training to the appropriate members ofthe operating shift.

The apparent cause of the failure to maintain current SCBAqualifications was determined to be inadequate procedures.Although SCBA requalification was performed for fire brigademembers, there was no program element in place to requireperiodic requalification of the operating shift crew. Whene

licensed operators were removed from the fire brigade, their,

qualification was allowed to expire. The corrective action to4

prevent recurrence was therefore to establish administrativecontrols, including training requirements, for SCBA used forcontrol room habitability. A review of the design and licensing |basis for the SCBA was performed, including NNECO's response to '

NUREG-0737, Item III.D.3.4, and Integrated Safety AssessmentProgram (ISAP) topic 1.12 correspondence. During this review,NNECO concluded that the ability of the operators to don SCBA is

I part of the design basis for control room habitability.Notwithstanding the initial assessment that control roomhabitability would be maintained, NNECO reported the failure tofully meet the training requirements as a condition outside thedesign basis of the plant (LER 245/95-03-00, March 14, 1995). Asstated in the LER, the delay in reporting was attributed to alack of full understanding of the relationship between theoperator training and the design basis for control roomhabitability.

The MP1 Technical Requirements Manual (TRM) was revised toinclude the administrative controls for SCBA. The FSAR wasrevised to incorporate the NRC's approval basis for NUREG-0737,1

Item III.D.3.4 as documented in license amendment No. 103.

Design Basis for SCBA

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i The design basis for the details of SCBA use or logistical i; requirements is not tied to specific design basis radiological '

i calculations. The radiological calculations which were performed! as part of the ISAP topic 1.12 and License Amendment No. 103 werej performed solely as scoping assessments, using SCBA to provide; reasonable assurance of control room habitability. Since MP1 isj not licensed to General Design Criterion (GDC) 19, design basisj radiological calculations for control room habitability have

never been perforac.d for internal scarces. The 20 minute'

; assumption for the time to don SCBA's was based on an estimate ofi a reasonable time to obtain air sample results. The 2 hour! supply was based on an estimate of the time needed for thei emergency organization to provide additional supplies, ifj necessary. Hence, these criteria are not based on back-j calculation of requirements necessary to ensure the GDC 19 dosej criteria are met. Rather, they were developed based on practical! capabilities, and used as nominal assumptions in scoping; radiological calculations.

! Design basis accident (DBA) radiological calculations arenon-mechanistic calculations which use extremely conservativesimplifying assumptions. For example, the calculations assumethe control room is surrounded by a radioactive plume for 30consecutive days, which would preclude control room purging.Based on wind direction and wind persistence data, it is unlikelythat there would be a plume around the control room for more than i

2 hours in any day. Therefore, during an event, the need to don I

respiratory protection would be based on actual. measuredradioactivity at the time of the accident, rather than designbasis radiological calculations. Onsite health physics (HP)technicians are responsible for making a timely determination ofcontrol room activity, which is used as a basis forrecommendations regarding SCBA and potassium iodide tablets tominimize thyroid dose. The timeliness of donning SCBA's and thequantity maintained reflects response capabilities governed bythe emergency plan, and the scoping calculations described aboveestablished these as being reasonable.

The minimum number of SCBA's prescribed by the TechnicalRequirements Manual is consistent with the NRC SER for NUREG-0737item III.D.3.4, dated April 16, 1982, by providing one SCBA foreach member of the operating shift, with one additional SCBA forevery three members. The specified number of air bottles ensureda nominal two hour air supply immediately available to theoperators. This supply was judged to be sufficient based on re-supply capability using onsite and offsite sources. Since theradiological calculations cannot define the actual timerequirements for SCBA use, the on-site supply, combined with

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emergency response capability, is intended to allow for acontinuous air supply.

The original 2 hour air supply will be increased to a 6 hoursupply, using SCOTT 4.5 SCBA with 30 one-hour replacementbottles, by July 31, 1996. Six hours of air supply for each |operator will provide additional margin to allow for bottle re-supply by the emergency response organization, and to provide foran orderly change of personnel if required. The spare bottlesare stored outside the control room nearby in the Turbinebuilding elev. 348-6". This area is expected to be accessiblepost-accident. Bottles can be brought into the control room asrequired and replaced in place. Operators can continue breathing ,

during the brief period of bottle replacement, as the time framerequired would be short enough such that the incremental dose I

would be small.

The realistic interval during which the operators would have torely on SCBAs cannot be defined by radiological calculations. Itis assumed that the operators don the SCBAs as directed by HP andcontinue to wear the SCBAs as long as required. Emergencyresponse capability can provide a continuous supply of rechargedbottles and SCBAs for the relief shift (s).In summary, the basis for the number of air bottles necessary isto have sufficient supply in place to allow time for delivery ofadditional bottles and shift relief personnel. This is based onthe conservative assumption that continuous use of SCBAs may benecessary.

Training / Physical Qualificationi

In accordance with the medical policy in NEO 2.23, the NNECO ;

Health Facility conducts stress testing as part of the annualrequalification process. Consistent with ANSI Z88.6-1984,"American National Standard for Respiratory Protection-RespiratorUse-Physical Qualifications for Personnel," the stress testincludes an assessment of the physical demands of meaningful workperformed while wearing the SCBA. In February, 1995, thequalifying physician participated in a tour of the control room,during which the operators demonstrated actions to be takenduring emergency situations. The physician's observations wereused to determine the appropriate level of stress testing forSCBA qualification.

Simulator training exercises involving SCBA were deemedunnecessary based in part on a demonstration of the ability ofthe operators to communicate in SCBA using voice amplificationdevices. It is noted that the communication test was performed

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with the SCOTT 4.5 SCBA, while the TRM allows the use of eitheri the SCOTT 4.5's or SCOTT IIA's. The minimum required SCBA supply

specified by the TRM is currently met using the SCOTT 4.5's. TheTRM will be revised to delete the SCOTT IIA's as an acceptable

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alternative, and also require the voice amplification devices for4 each control room SCBA and prescription eyeglass lens inserts as'

necessary. These TRM revisions will be completed by July 15,1996.

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Simulator training exercises using SCBA will be conducted for; each active shift crew during the upcoming training cycle in June; and July, 1996. The Health Facility will be represented at the

simulator exercises, to evaluate stress-related capabilitiesassociated with prolonged use of SCBA in the contslol room.Lessons learned from the simulator exercises vi31 be used toenhance the qualification process and to develop operatingprocedures. These actions will be completed prior to unitstartup.

Operations and Emergency Preparedness Procedures

Surveillance Procudure 694.3 implements the TRM requirementsregarding periodic verification of control room SCBA inventoryand operator qualifications. A new procedure will be developedto provide guidance on the use of SCBA in the control room.Entry conditions for the new procedure will include therecommendation from Health Physics to don SCBA based on surveysper Emergency Plan Operating Procedure 4426, "On-Site EmergencyRadiological Surveys", and the control room ventilation systemhigh' radiation alarm. The new procedure will be developed basedon data gathered during the simulator exercises, and will addressshift turnover while using SCBA. This procedure will be approvedfor use prior to unit startup.

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Emergency preparedness procedures will be revised by June 14,1996, to identify diverse breathing air supply sources, includingoffsite facilities within and outside the Emergency PlanningZone. The procedure revisions will include precautions regardingthe potential for contamination of compressed air during aradiological accident. These procedure changes will facilitatetimely replenishment of breathing air to support continuous useof SCBA.

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Attachment 3

Millstone Nuclear Power Station, Unit No. 2

Reply to a Notice of Violation

NRC Combined Inspection 50-245/96-01; I

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U. S. Nuclear Regulatory CommissionB15713/ Attachment 3/Page 1

Millstone Nuclear Power Station, Unit No. 2Reply to a Notice of Violation


Restatement of Violation B

10 CFR 50.62 requires that each reactor have equipment, diversefrom the reactor trip system, that would automatically initiateaction to mitigate the consequences of an anticipated transientwithout scram (ATWS), and that this equipment be designed to

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perform its function in a reliable manner. i

The licensee's submittal in response to 10 CFR 50.62, dated |

June 27, 1988, specified that the controls and programs that |assure that the ATWS mitigating system actuating circuitry(AMSAC) performs its design function will be detailed by thespecific test procedures.

Contrary to the above, the licensee failed to adequatelyestablish and implement a test procedure to ensure that the AMSACequipment performed its function in a reliable manner. ProcedureSP 2402Q "ATWS Setpoint Functional Test," Revision 3, was

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inadequate in that it failed to reflect changes in contact Ipositions that occurred as a result of AMSAC modifications. Inaddition, on July 16, 1995, procedure SP 2402Q, Step 4.8.6.e, was |not adequately implemented in that 4 out of 12 contacts that were !

specified to check the position of the AMSAC actuation relayswere not in the required position, yet the procedure indicatedthat the acceptance criteria had been met.

This is a severity Level IV Violation (Supplement I).

Reason For Violation

The failure to adequately revise the procedure SP 2402Q, "ATWSSetpoint Functional Test", during a design change process was dueto personnel error. A significant contributing cause was aweakness in the design change process. Also, the failure toadequately perform the procedure, which was the retest for theimplementation of the design change, was due to personnel error.A significant contributing cause was a lack of clarity in theprocedure.

During July 1995, numerous modifications to the ATWS/ DiversifiedScram System (DSS) were conducted. The purpose of these4

modifications was to reduce the electromagnetic interference andradio frequency interference (EMI/RFI) generated by the ATWS/ DSS

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! U. S. Nuclear Regulatory Commission: B15713/ Attachment 3/Page 2

circuits. This " noise" was having a negative affect on severali different plant systems. One of the design change notices

(DCNs), DM2-S-0978-95, added a set of interposing relays to theControl Element Drive Mechanism (CEDM) Motor / Generator (MG)

i output contactors. The purpose of the interposing relays was toj remove the 240 VAC control signals from the rear of the control; boards. As a result of these circuit modifications, Revision 31 of the Surveillance Procedure, SP 2402Q, was prepared and Plantj Operations Review Committee (PORC) approved on July 16, 1995.

i However, the circuit diagrams used to revise this procedure did] not include the details of the DCN implemented that same day. It| did not show the interposing relays nor the revised relay contacti states for 94A/ DSS and 94B/ DSS. The DCN which modified the| original circuit design was not provided to the I&C department1 for procedure impact review. Consequently, the contact states

listed in Attachment 1 of the revised procedure were in error..

; During the performance of SP 2402Q, Revision 3, on July 16, 1995,as a retest for the modifications, the I&C Technicians did not;'

monitor all of the relay contacts for the 94A/ DSS and 94B/ DSS: relays called out in Attachment 1 of the procedure. This failurej may have been due to an ambiguity in the procedural steps; governing the measurement of the resistance across the contactse of the 94A/ DSS and 94B/ DSS relays. Step 4.8.3 of SP 2402Q,

Revision 3, states, " VERIFY, with DMM set to measure resistance,; contacts for 94A/ DSS and 94B/ DSS relays listed on Attachment 1; are in Normal State" and to " DOCUMENT relay states on Attachmentj 3." However, the Attachment 3 contains only two sign-off blocks! for step 4.8.3, one for the 94A/ DSS relay and one for the 94B/ DSSI relt.y. Neither Attachment i nor Attachment 3 contain individual! spaces to document the states of the individual, relay contacts on: the two DSS relays (94A/ DSS and 94B/ DSS). This may have led the; two technicians involved with the testing to believe that they( were supposed to be documenting proper relay operation, " Normali verses Tripped", and not the status of each of the individuali contacts on the two relays. Also, even if the contact states I' were verified to document the relay state, only the contact

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states that were listed correctly in Attachment 1 may have been |'

verified. These circumstances may have led to the conclusion,

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that the test was satisfactory.

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j U. S. Nuclear Regulatory Commission: B15713/ Attachment 3/Page 3fJ l

! Corrective Steps That Have Been Taken and Results Achieved ji

! * An operability determination, OD2-96-30, was completed basedj on the scope of testing performed on the ATWS/ DSS '

j modifications. It was determined that the ATWS/ DSS system was! operable. Part of the scope of testing did verify that the MG! Set output contactors operated as per the design.Ij * A revirw of the design and the as built condition of the

system were conducted to verify that the as built condition ofthe system did agree with the design.

! * A review of a sample of other I&C procedures was performed.This review revealed that this system, and the method used to'

.! verify the trip logic, is unique in verifying the status ofj the individual contacts on a relay. This review ensured that; there are no systemic problems with the I&C procedures.

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| * The Millstone Unit No. 2 I&C Department met to discuss thei violation and its causes to learn from the event.is

) Corrective Steps That Will Be Taken To Avoid Further violations!

| * I&C personnel involved in modifying procedures are being re-| trained in the use of the Generation Records Information ,

| Tracking System (GRITS) in order to be able to access thecurrent revision to any drawing and any open DCNs.,

!* The Design Control Manual will be revised to better assure!

j that design changes are reviewed for their impact oni Department Procedures before they are performed.

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The procedure SP 2402Q, "ATWS Setpoint Functional Test," will*

, be revised to adequately verify the plant design. This will! include verifying the status of all of the contacts on the! 94A/ DSS and 94B/ DSS relays and documenting the status of the

| contacts on the Attachment 3 of the procedure.;

! * The Millstone Procedure Writer's Guide will be reviewed to{ assure that attachments which are for information only are

clearly identified. Also, the Guide will be reviewed toassure that verifications are initialed where appropriate todocument that acceptance criteria are met.

iThe unit is currently shutdown. The procedure, SP 2402Q, when; *

revised, will be performed prior to entry into Mode 2.

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Date When Full Compliance Will Be Achieved

i Millstone Unit No. 2 will be in full compliance with 10 CFR 50.62prior to entry into Mode 2 from its current outage.

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responds to nrc 960412 ltr re violations noted in insp

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