B16731, Responds to NRC Re Violations Noted in Insp Repts 50-245/97-02,50-336/97-02 & 50-423/97-02 on 970311-0519. Corrective Actions:Initiated Design Change MI-97009.Listed Commitments to Be Completed by Startup of Refueling Outage

Responds to NRC Re Violations Noted in Insp Repts 50-245/97-02,50-336/97-02 & 50-423/97-02 on 970311-0519. Corrective Actions:Initiated Design Change MI-97009.Listed Commitments to Be Completed by Startup of Refueling Outage

ML20198T516
Person / Time
Site:	Millstone
Issue date:	11/10/1997
From:	Mcelwain J NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-245-97-02, 50-245-97-2, 50-336-97-02, 50-336-97-2, 50-423-97-02, 50-423-97-2, B16731, NUDOCS 9711170019
Download: ML20198T516 (7)

Text

- - --

'w gggg Ib.pn I crry 101. (lhmir IN>), Weierfistti, UI' Ot>We Nuclear Energy u.u,n, w, us, r ..c, sisia.n Nrtheut Niu kar limy Deig any

+

P.O. Na 128 i

Waterfur ti, CF(WLO12A (8t:0) 447-1791 l'an (8t:0) 444 4277

'Ihc brthreat Utihue. Sysicin November 10,1997 Docket No. 50-245 B16731 Re: 10CFR2.201 U.S. Nuclear Reguintory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No.1 Reply to Notice of Violation 50 245/97-02-01 Containtnent isolation Valves Configuration Centrol Inspection 50-245/97-02: 50-336/97-02: 50-423/97-02 in a letter dated June 24,1997,W the NRC transmitted the results of an inspection conducted at the Millstone Station from March 11,1997, through May 19,1997, The NRC Inspection Report concluded that certain of our activities at Millstone Unit No.1 appeared to be in violation of NRC requirements.

While investigating inadequate Appendix J testing of certain feedwater system check valves, it was determined that Northeast Nuclear Energy Company (NNECO) did not implement applicable regulatory requirements and correctly translate design basis information into drawings and procedures for certain containment isolation valves.

On July 29,1997,* NNECO replied to the Notice of Violation on this subject. Further review of the issue and the response indicate that the response should be revised to clearly state what corrective actions have been initiated, completed, or planned to address root cause issues. This letter and Attachment 1 provides a more detailed description of our corrective actions.

I D 5 ,

h M W. D. Lanning letter to Bruce D. Kenyon, 'NRC COMBINED INSPECTION REPORT 50 245/97 02; 50-336/97-02; 50-423/97-02 and NOTICE OF VIOL.ATION," dated June 24,1997.

• J. P. McElwain letter to U.S. Nucleet Regulatory Commission, "NOV Response 97-02-01 Containment isolation Valves Configuration Control," dated July 29,1997.

30423-6 litV 13 95

U.S. Nuclear Regulatory Commission B16731\Page 2 Commitments The following are NNECO's commitments within this letter. This list of commitments will be completed prior to startup from refueling outage 15.

B16731 1 Complete Design Change Notice P:,1100-0805 97 to remove the bottom drain lines that are incorrectiv .:.vwn on piping drawings associated with 1-FW 10NB, and to incorporate manual isolation valves,1-FW 107NB onto piping line drawings.

B167312 NNECO will develop a new proceduru to replace the current Locked Valve List procedure.

B16731-3 Complete Design Chango M197009 to add bottom drain capability to 1-FW-10ND which will allow proper draining for local leak rate testing.

B16731-4 Revise Updated Final Safety Analysis Report to include corrected figure 6.2 15.

B167315 Audit locked valves to ensure that proscribed critoria have been used for valves that are physically locked and are indicated as such on system drawings, Locked Valvo Instruction, system valvo lineup, and operating procedures and survoillances that operato those valves.

Please contact Mr. P. J. Minor at (860) 440-2005 should you have any questions regarding this submittal.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Ybi _

Obbn P. McElw'ain Millstone Unit No.1 Recovery Officer Attachments (1) cc- H. J. Miller, Region 1 Administrator W. D. Travers, Ph.D., Director, Special Projects Office W. D. Lanning, Deputy Director of Licensing, Special Projects Office S. Dombok, NRC Project Manager, Millstone Unit No.1 T. A. Eastick, Senior Resident inspector, Millstone Unit No.1

l f'

Docket No. 50 245

B16731  ;

t i

?

b i

Attachment 1 t

Millstone Nuclear Power Station, Unit No.1  ;

Reply to Notice of Violation 50-245/97-02-01 Containment Isolation Valves Configuration Control j insoection 50-245/97-02: 50-336/97-02: 50-423/97-02 i

i November 1997 i

U.S. Nuclear Regulatory Commission B16731\ Attachment 1\Page 1 Restatement of Violation 10 CFR 50, Appendix B, Criterion 111, Design Control, requires measures to be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, since commencement of operations at Unit 1, applicable regulatory requirements and the design basis were not correctly translated into drawings and procedures in that:

(1) Updated Final Safety Analysis Report Figure 6.2-15 and plant drawings 25202 20290 and 25202 20002 incorrectly showod a bottom drain conellon on feedwater system piping downstream of check valvos 1-FW-10A and 1-FW 10B; (2) branch lines containing manual isolation valvos 1-FW 107A and 1-FW-1070 located downstream of check valves 1-FW-9A and 1-FW-90 were not shown on drawings 25202-29119,25202-20290,25202 20002, or 25202-29013, and (3) valves 1-FW-107A and 1-FW-1070 were not included in Operations Instruction 1-OPS-10.11, " Locked Valve List," and the valves were not locked in the closed position as required.

This is a Severity 1 evel IV violation (Supplement I) for Docket No. 50-245 Reason for the Violation General The origins of this violation occurred from two historical design change requests (PDCR 1-75-80, PDCR 1-52-74) and an Operating Instruction. To understand causes of these problems a historical0 perspective is nooded. Millstone Unit No.1's Adverse Condition Report (ACR) 7007 identifies applicable analogous and historical reasons for this violation. The following are excerpts from ACR 7007 which describe the general reasons for this violation:

"Most of the engincors and managers contacted during this analysis (individuals who should be well versed in design control roquirements) have not read Title 10 of the Code of Federal Regulations, Regulatory Guides, or ANSI Standards pertinent to design control, There is a general lack of understanding and appreciation of the relationship and implications between 10CFR50, design bases (50.2), licensing bases, industry codes, and NU's administrative programs controlling configuration and design.' *, , , The overall UFSAR change mechanism processes are not integrated and create the potential for omissions and conflicts. The organization needs to acquire a balanced parspective and appreciation for safety as both process and objective." "This root cause analysis found that line managers use a limited set of tracking and trending

") ACR 7007, Event Response Team Report, February 22,1996.

U.S. Nuclear Regulatory Commission B16731\ Attachment 1\Page 2 tools. .Line managers do not use routine performance measurement tools with defined huccess critoria. There are few objective measures indicating the relative or actual status of overall or specific performance. ....Therefore, it is not possible to measure performance to the success criteria of a UFSAR that accurately describes the facility and its procedures.'

Specific Inforroat!On item No.1 A previous rnodification (PDCR 1-75 80) to change out the feedwater check valves 1-FW-10A/B resulted in the physical removal of the piping containing the drain connections. The drains were nec 'ed to ensure proper drainage of the check valves prior to Appendix J localleak rate t .ng (t.LRT). Upon installation of the replacement check valves, the drain lines were not re-installed. Not all of the design drawings were revised subsequently to reflect the new piping configuration. Operations Critical and Nuclear Boiler drawings were corrected to show no bottom drain connections downstream of the feedwater check valves inside the drywell. However, reactor building feedwater system line drawings, main steam feedwater piping sections, and pipe fabrication sketches still show the bottom drain connection.

Item No. 2 Inspection revealed that downstream of valves 1-FW-107A/B, tubing was installed which lead to a reducer, an instrument root valve and more tubing. This arrangement was not shown on certain system drawings, but was shown (manually added) on the feedwater and condensate drawings mainteined in the Control Room. The installed configurations were two remote sample points associated with a temporary sodium injection method (PDCR 1-52 74) utilized for calibrating the feedwater flow instruments.

Radioactive sodium was injected at a known rate upstream of the flow instrumentation and samples were taken downstream. The installed configurations are the downstream sample points, item No. 3 The need to lock close 1-FW-107A/B had been identified by Millstone Unit No.1 Technical Support and documented in an internal memorandum, MP1-TS-96-050, dated February 15,1996. This requirement was incompletely incorporated, in that the system valve lineup was modified to reflect the requirement to lock the valves.

However, the Locked Valve Operations Department Instruction was not updated, and the va' Ts were not physically locked at that time. The valve lineup has not been peric,r; since this modification. Performance of the lineup would have uncovered this dit pancy, in late 1996, the disparity between the valve lineup and the Locked Valve Instruction was identified by Millstone Unit No.1 Operations personnel following a containment

l U.S. Nuclear Regul: tory Commission -  ;

B16731\ Attachment 1\Page 3 isolation and- testing program review 'and a _ draft revision of the instruction was hropared, but was not approved at the time of the violation. -

~

Finally, this same issue' was also independently- identified by NNECO during .

-10 CFR 50.54(f) system walkdowns. Actions to resolve these discrepancies had not l been scheduled at the time of the violation.

Manual valves 1-FW-107NB were not locked in the closed position as required by ANSI 56.8, Section 3.33, because credit was taken for the bcking of the steam tunnel door .which restricted access to the valves. Thus the Operations Department -

instruction for

• Locked -Valve L!st" and NUREG-0824, Integrated Plant Safety-3 Assessment Report, section 4.20, Topic VI-4, " Containment isolation System," did not include these valves.

l Corrective Steps That Have Been Taken and Results Achieved, and

- Corrective Actions That Will Be Taken As part of the 10 CFR 50.54(f) sffort important systems have been walked down and reviewed to~ identify any discrepancies between tho plant configuration and design

! documents. Correcve Action Plans have been developed for discrepancies that are considered significant. Discrepancies identified which are significant items will be resolved prbar to startup from refueling outage 15 'which is a previous commitment).

In a letter dated May 29,1997," NNECO committed to describe the actions it is taking to ensure that future operation will be conducted in accordance with the terms and conditions of the operating license, the Commission's regulations, and the Final Safety Analysis Report. This information wou'd be forwarded to the NRC no later than 14 days prior to the Commission meeti",g for Millstone Unit No.1 restart. With regard to the specific issues in this notice of violation the following actions have been or are

, baing taken:

Item No.1 -

Design Change M1-97009 has been initiated to add bottom drain capability to check _

valves 1-FW-10NB to accomplish complete draining prior to performing the Appendix J LLRT. The new drain connections will be an integral part of the check valves. The

, valve modifications will be completed prior to startup from refueling outage 15.

Design Change Notice DM1-00-0805-97 has been initiated to remove the incorrectly shown drain lines from piping drawings 25202-20290, 25202-20002, and 25202-29103.

These revisions will be made prior to startup from refueling outage 15.

I ltem No. 2 L

f

• : N. S. Cams letter to.U.S. Nuclear Regulatory Commission, " Initial Information Submittal Regardmg PRC 10CFRSO.54(f) Information Request," May 29,1997.

_ _ I

. s

- U.S. Nuclear R*0ul tory Commission' -

816731\ Attachment 1\Page 4  ;

The. tubing has been removed, i

A condition report (CR Mi-97-1694) was issued to document (in part) the c' onfguration downstream of valves 1-FW-107NB Corrective actions are

e - Issue a DCN to reconcue branch line arrangements to the requirements of drawings 25202-29124, Sheets 37 and 37A.

• Generate ' design change request to remove drain connection from applicable feedwater piping drawings. l

• Revise P&lD 25202-26013, sheet 11, to show valves 1-FW-107NB locked closed.

< e Develop procedural requirements to ensure locked valve list, system valve list, and

- P&lD are revised concurrently.

Et!ILH0J Valves 1-FW-107NB have been locked in the field, and the revision of the Locked Valve instruction has been reviewed and approved.

During the process of developing a new procedure to replace the current Locked Valve List procedure, a benchmar*.r procedure / process will be sought from leading nuclear utilities who have had success in controllir g valve configurations. Specifically, criteria for locked valves and processes need to be established that ensures that all aspects of adding or deleting valves from the program are handled appropriately, These aspects

-include ensuring that the system piping and _ instrument drawings, the system valve lineup, as well as any applicable Updated Final Safety Analysis Report (UFSAR) drawings, including UFSAR figure 6.2-15, are updated.

in addition, an audit'of Millstone Unit No.1 locked valves will be conducted. This audit will ensure that all valves meeting the prescribed criteria are physica"y locked, and R indicated as such on the system drawings,_ Locked' Valve Instruction, system valve j lineup, and operating procedures and surveillances which operate these valves. The actions are scheduled to be completed prior to startup from refueling outage 15.

! Date When Full Compliance Will Be Achieved Planned corrective actions will be completed prior to startup from refueling outage.15.

. lThe completion of these corrective actions will restore the unit to full compliance with respect to the plant drawings and Appendix J testing of 1-FW-10NB. j 1

l

, i e

k r - . w-r,, , . , - , , .v. --w~2,7.---,--,mm,,, - .,,, _e-, -- . - + - , -