B16486, Responds to NRC Re Violations Noted in Insp Rept 50-336/97-80 on 970317-21.Corrective Actions:Steps Taken to Assure That SSCs Required to Be Included within Scope of Maintenance Rule Program Are in Place

Responds to NRC Re Violations Noted in Insp Rept 50-336/97-80 on 970317-21.Corrective Actions:Steps Taken to Assure That SSCs Required to Be Included within Scope of Maintenance Rule Program Are in Place

ML20140C929
Person / Time
Site:	Millstone
Issue date:	06/03/1997
From:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-336-97-80, B16486, NUDOCS 9706100137
Download: ML20140C929 (5)

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' Rose Ferry lld. (ltoute 156), Waterford, cf 063M Northeast h Nuclear Energy siautoor Noacar power snition I s Northeast Nudear Energy Company

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j . P.O. Ibx 128 i Waterford, Cr Oo3M-0128 (860) 447-1791 Fax (860) 444-4277 The Northeast Utilities System June 03,1997 Docket No. 50-336 B16486 l

l Re: 10CFR2.201 l

U.S. Nuclear Regulatory Commission 1

!- Attention: Document Control Desk Washington, DC 20555 l

Millstone Nuclear Power Station, Unit No. 2 l Facility Operating License No. DPR-65 l Reply to Notice of Violation 336/97-80-01 )

Inspection 50-336/97-80 j

In a letter dated May 8,1997,W the NRC transmitted the resu!ts of their Maintenance Rule Program implementation inspection conducted at the Millstone Station on March

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17-21,1997. The NRC Inspection Report concluded that five systems at Millstone Unit )

No. 2 which should have been included as "in scope" were not within the scope of the l maintenance rule program. Three of the five systems involve emergency operating procedure actions, and two of the systems could cause scrams or loss of safety-related functions. The scophg of systems, structures and components (SSCs) was not in accordance with 10 CFR 50.65(b)(1) and (2).  ;

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Attachment 1 provides NNECO's reply to the Notice of Violation pursuant to the ,

provisions of 10CFR2.201.  !

Commitments The following are NNECO's commitments associated with this response:

l B16486-1 The remaining maintenance rule implementation activities (risk '

significance determination, performance criteria development, historical performance assessment, and development of system basis documents) for the five new systems added to the rule scope will be completed by i August 31,1997. TI l

• James T. Wiggins to Bruce D. Kenyon, "NRC Combined Inspection l

50-245/97-80; 50-336/97-80: 50-423/97-80 and Notice of Violation," dated l

May 8,1997.

9706100137 970603, 6 lllllllllll$b.lllllll PDR ADOCK 0500 0

l U.S. Nuclear Regulatory Commission l B16486\Page 2 Should you have any questions regarding this submittal, please contact Mr. Ravi Joshi i at (860) 440-2080. l NORTHEAST NUCLEAR ENERGY COMPANY Martin L. Bowling, Jr.y  !

Millstone Unit No. 2 Recovery Officer Attachments (1) cc: H. J. Miller, Region i Administrator D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 W. D. Travers, PhD, Director, Special Projects Office J. P. Durr, inspectors, Special Projects Office '

J. T. Wiggins, Director, Division of Reactor Safety

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Docket No. 50-336 B16486 i I

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Attachment 1 l

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Millstone Unit No. 2 Facility Operating License No. DPR-65 Reply to Notice of Violation 336/97-80-01 NRC Combined inspection Report 50-245/97-80, 50-336/97-80 and 50-423/97-80 June 1997 i

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U.S. Nuciser Regulatory Commission

B16486\ Attachment 1\Page 1

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! Restatement of Violation i

i 10CFR50.65(b)(1) and (2) require, in part, that the scope of the monitoring program j specified in Section (a)(1) shall include safety-related and non-safety related -

i structures, systems, and components (SSCs), as follows: (a) safety related SSCs and ,

, (2) non-safety related SSCs: (1) that are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs): or (ii) whose failure i could prevent safety related SSCs from fulfilling their safety related function: or (iii) j whose failure could cause a reactor scram or actuation of a safety related system.

! Contrary to the above, as of March 17,1997, for Unit 2 the facility failed to include the following SSCs within the scope of the maintenance rule:

! e control rod drive cooling system - used in EOPs t . containment auxiliary circulating system - used in EOPs ,

e condenser air removal exhaust system - used in EOPs l . exciter air cooler system - scram or loss of safety related function

. intake structure ventilation - scram or loss of safety related function l

l Reason for the Violation and Causes

NNECO does not dispute the notice of violation for systems that were not included in i the maintenance rule program scope. Failure to follow procedure requirements and incomplete reviews were the causes for this violation.

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) The procedure for determining systems listed in EOPs for maintenance rule scope j applicability was not followed. A step in the Integrated Maintenance Program Instruction was overlooked following a December 1996 change involving system

. reviews in EOPs.

j Prior to December 1996, the scoping instructions that were developed and utilized by

Unit 2 followed the industry guidance in NUMARC 93-01, as endorsed by Regulatory

Guide 1.160, dated June 1993. The program instruction allowed for a determination on j the significant fraction of the mitigation function for a system listed in the EOPs. The

! three systems listed in the EOPs were determined not to provide significant value, and

therefore, were not included in the maintenance rule program scope.

A revision to the Program Instruction (PI) required that all systems and sub-systems 7 that are directly identified in the main sequence of the plant's events and/or functionally oriented EOPs be in scope to the maintenance rule.

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i The exciter air cooler did not meet the scoping criteria specifically for Unit 2, but the program called for reviews of peer plant and sister units. The review of sister units i

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U.S. Nuciner R:gulatory Commission j B16486\ Attachment 1\Page 2 j missed the scram at Seabrook Station. If this scram was identified during the initial

scoping review, the Millstone Unit No. 2, exciter air cooler system would have been included in the program scope. The intake structure ventilation system was under

review to determine if the system was important for supporting safety related

! equipment, but was not included at the time of the maintenance rule inspection, i March 17-21,1997.

l j Corrective Steps that have been Taken and the Results Achieved l NNECO has taken steps to assure that SSCs required to be included within the scope j of the maintenance rule program are in place. Our actions to date include:

! Systems identified in the notice of violation have been added to the list of systems in I

{ the maintenance rule scope.

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A detailed review, involving a second person review, was conducted of the emergency j operating procedures (EOPs) to ensure all systems and sub-systems are incleded within the maintenance rule scope. No additional systems were identified.

, Sister unit peer plants have been re-reviewed to identify events that could occur at i

Millstone Unit No. 2, and . result in scrams or loss of safety function. There were no additional events identified that would require additional systems to be added to the l maintenance rule scope.

j A review was conducted of other systems to determine if incomplete engineering l evaluations for maintenance rule program scope applicability existed. The review l identified that one system (Non-Radwaste Ventiltttion) had been under evaluation at  ;

l the time. The engineering evaluation of the Non-Radwaste ventilation system has  !

been completed and the results determined that the system does not meet the scoping  :

criteria for inclusion in the maintenance rule program, Corrective Steps that will be Taken  !

The remaining maintenance rule implementation activities (risk significance '

determination, performance criteria development, historical performance assessment, and development of system basis documents) for the five new systems added to the rule scope will be completed by August 31,1997.

NNECO is currently in full compliance with system scoping in accordance with 10 CFR 50.65(b)(1) and (2).