IR 05000245/1996013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-245/96-13 on 961112-22

ML20138A084
Person / Time
Site:	Millstone
Issue date:	04/18/1997
From:	Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9704250223
Download: ML20138A084 (3)

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April 18, 1997 Mr. Bruce !

President and Chief Executive Officer

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Northeast Nuclear Energy Company

. c/o Terry Harpster j P.O. Box 128 Waterford, Connecticut 06385-0128

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SUBJECT: NRC INSPECTION REPORT NO. 50-245/96-13 (REPLY)

Dear Mr. Kenyon:

j This refers to year March 26,1997 correspondence, in response to our letter, dated on  ;

! February 3,1997 Your response addressed the Notice of Violation, identified in the ~

. subject inspection report, which involved failure to establish and implement procedures i required by Section 6.8 of the Technical Specification to verify ventilation system j performance as described in: (1) Section 9.4.6 of the Unit 1 UFSAR (maintaining at about l -0.1" of water for the Turbine Building Area Ventilation Differential Pressure); (2) Section

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9.4.8 of the Unit 1 UFSAR (maintaining at about -0.25" of wqter for the Steam Tunnel i Ventilation System); and (3) Sections 9.4.4 and 9.4.5 of UFSAR of the Unit 1 (air supply

] 10,900 scfm to the Radwaste Building and 3,350 scfm to the Radwaste Storage Building). l We have reviewed your assessment and planned corrective actions, which include: (1)

developing test procedures for the turbine building, radwaste building, and radwaste

storage building ventilation systems; (2) validating the UFSAR design for the turbine

building, radwaste building, and radwaste storage building ventilation systems; and (3)

l installing a pressure gauge outside of the steam tunnel to allow logging of the steam tunnel ventilation negative pressure. We understand that the conective measures identified in

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your response will be ccmpleted before restarting the unit. Accordingly, we consider the l actions you have taken or planned to be acceptable and will review the effectivenesr, of  ;

these actions in a future inspection.

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We appreciate your cooperation.

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Sincerely, j

John R. White, Chief Radiation Safety Branch Division of Reactor Safety Docket No. 50-245 i

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! Mr. Bruce ! l

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i N. S. Carns, Senior Vice President and Chief Nuclear Officer

P. Loftus, Director - Regulatory Affairs for Millstone Station j J. McElwain, Unit 1 Recovery Officer

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j- D. M. Goebel, Vice President, Nuclear Oversight

J. K. Thayer, Recovery Officer, Nuclear Engineering and Support i P. D. Hinnenkamp, Director, Unit Operations

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F. C. Rothen, Vice President Work Services j J. StanziewL , Training Recovery Manager  ;

i R. Johannes, Director - Nuclear Training i L. M. Cuoco, Esquire j J. R. Egan, Esquire i j

i V. Juliano, Waterford Library Department of Public Utility Control j

{ S. B. Comley, We The Peopie  ;

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State of Connecticut SLO Designee )

D. Katz, Citizens Awareness Network (CAN) l R. Bassilakis, CAN J i J. M. Block, Attorney, CAN i S. P. Luxton, Citizens Regulatory Commission (CRC)

i Representative Terry Concannon j E. Woollacott, Co-Chairman, NEAT.-

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Mr. Bruce Distribution:

Region i Docket Room (with concurrences)  ;

W. Lanning, Deputy Director of Inspections, SPO, Rl M. Kalamon, SPO, RI NRC Resident inspector Nuclear Safety Information Center (NSIC) j PUBLIC D. Screnci, PAO (2) l N. Sheehan, Field-Public Affairs Officer, RI J. Anderson, PM, SPO, NRR W. Dean, OEDO P. McKee, Director, Deputy Director of Licensing, SPO, NRR G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR L. Plisco, Chief, bEO, NRR l

S. Dembek, PM, SPO, NRR I D. Mcdonald, SPM, SPO, NRR i

M. Callahan, OCA '

R. Correia, NRR R. Frahm, Jr., NRR  ;

Inspection Program Branch (IPAS)

DRS File J. Jang, RI DOCUMENT NAME: G:\RSB\JANG\MS9613. REP Ta receive a copy of this document, indicate in the bom*C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure *N' = No copy 0FFICE Rl/DRS R1h l / l l l NAME JJANG JW/J/E)

DATE 04/14/97 F4/ 6 /97 04/ /97 04/ /97 04/ /97

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0FFICIAL RECORD COPY 2

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Hope Ferry Rd. (Houte 156). Waterford. CF 06385 Northeast

$ fj)f NuclearEnergy .,,,,, sg,,, p ,, g,,g, Northeast Nuclear Energy Coinpany

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P.O. Box 128

• Waterford, CT 06385-0128

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(860) 447-1791 Fax (860) 444-4277 The Northeast Utilities System l

MAR 2 61997 Docket No. 50-245

l B16307 l Re: 10CFR2.201 l

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U.S. Nuclear Regulatory Commission j

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Attention: Document Control Desk l

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Washington, DC 20555 j Millstone Nuclear Power Station, Unit No.1 i Reply to Notice of Violation 50-245/96-13-01 I Procedures involving Ventilation Systems Inspection 50-245/96-13: 50-336/96-13: 50-423/96-13 in a letter dated February 3,1997,0) the NRC transmitted the results of an inspection  ;

conducted at the Millstone Station from November 12,1996 through November 22,1996. '

The NRC Inspection Report concluded that certain of our activities at Millstone Unit No.1 appeared to be in violation of NRC requirements.

It was determined that Northeast Nuclear Energy Company (NNECO) did not establish and implement procedures as required by Technical Specification 6.8 to verify ventilation system performance relative to air balance, as described in the Unit 1 UFSAR for the following areas: radwaste building, radwaste storage building, turbine building, and steam tunnel.

On behalf of Millstone Unit No.1, Attachment 1 provides NNECO's reply to the Notice of l Violation. '

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John R. White letter to Bruce D. Kenyon, "NRC Combined inspection Report 50-245/96-13; 50-336/96-13; 50-423/96-13; and Notice of Violation," dated February 3,1997.

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U.S. Nucletr Regulatory Commission

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

B16307-1 NNECO will validate the UFSAR design for the turbine building, radwaste

building, and radwaste storage building ventilation systems prior to reactor ]

restatt. 1

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B16307-2 NNECO will establish procedures or processes to ensure the turbinc

building, radwaste building, and radwaste storage building ventilation i

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systems are operated in accordance with the UFSAR prior to reactor restart.

B16307-3 NNECO will install a pressure gauge outside of the steam tunnel to allow logging of the steam tunnel ventilation negative pressure during reactor operation prior to reactor restart.

On March 12, 1997, Mr. R. Walpole requested on behalf of Millstone Unit No.1, an extension to respond to the Notice of Violation until March 26,1997. This request was granted by Mr. J. Durr. Please contact Mr. R. Walpole at (860) 440-2191 should you have any questions regarding this submittal.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY VAi '

phn P. McEldain " ~

Millstore Unit No.1 Recovery Officer Attachments (1)

cc: H. J. Miller, Region i Adminis'rator Dr. W. D. Travers, Director, Special Projects Office W. D. Lanning, Director, Millstone Assessment Team S. Dembek, NRC Project Manager, Millstone Unit No.1 T. A. Eastick, Senior Resident inspectcr, Millstone Unit No.1

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Docket No. 50-245 B16307 l

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Attachment 1 l Millstone Unit No.1 Reply to Notice of Violation 50-245/96-13-01 i l

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March 1997

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U.S. Nuciar Regulatory Commission

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B16307\ Attachment 1\Page 1 Restatement of Violation Section 6.8 of the Unit 1 Technical Specification (TS) requires, in part, that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33 (RG 1.33), February 1978.

Appendix A of the RG 1.33, " Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," describes typical procedures for the control of radioactivity, including procedures involving ventilation systems relative to limiting personnel exposure and releases to the environment. >

Section 9.4.6 of the UFSAR, " Turbine Building Area Ventilation Differential Pressure,"

states that the area should be maintained at a negative pressure (about 0.1" of water)

to avoid any release of potentially contaminated air through turbine building vents or doors. Section 9.4.8 of the UFSAR, " Steam Tunnel Ventilation Systerr,, indicates that differential pressure should be maintained at a negative pressure (about 0.25" of water) ,

to ensure that there will be no inadvertent ground level release. Sections 9.4.4 and 9.4.5 of the UFSAR describe the design basis relative to ventilation air supply, including 10,900 scfm to the Radwaste Building Ventilation and 3,350 scfm to the Radwaste Storage Buildings.

Contrary to the Section 6.8 TS requkements, as of November 22,1996, the licensee

. failed to establish and implement procedures to verify that: (1) the design basis relative j

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to air balance affecting the turbine building area ventilation system and the steam tunnel ventilation system was maintained at a negative pressure, as described by the UFSAR; and (2) the design basis relative to ventilation air supply involving the l Radwaste and Radwaste Storage Buildings was maintained as described by the UFSAR.

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

Reason for the Violation Northeast Nuclear Energy Company (NNECO) agrees that the operation of the steam tunnel ventilation system is not currently monitored and represents a violation of the facility license. The steam tunnel ventilation system is required by the safety analysis to maintain a 0.25 inch negative pressure prior to operation of the Standby Gas Treatment System (SGTS) during a Design Basis Accident. The description of the steam tunnel ventilation system in the UFSAR, section 9.4.8, requires the system to maintain a slightly negative pressure of -0.25 inches of water when compared to the outside atmosphere. The requirement to monitor the negative pressure in the steam tunnel '

during steam tunnel ventilation system operation is not currently performed since no instrumentation exists in the current facility design to perform this surveillance.

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U.S. Nuclxr Regulatory Commission l

, B16307\ Attachment 1\Page 2

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For the remaining three systems contained in the violation, NNECO agrees that the UFSAR contains information for which procedures or processes should be developed to ensure compliance. The scope of design requirements for these systems will be validated during the 10CFR50.54(f) review process.

The turbine building, radwaste building, and the radwaste storage building ventilation

systems provide air that is filtered and heated to maintain an adeauate working environment in each building. In add tkm. esun system is arranged to provide supply i air flow to the clean areas of the building and exhaust air from any potentially contaminated areas of the building to limit the potential spread of airborne j contamination. These systems function to support the radiological controls program for i the facility and to maintain building habitability. They do not have a safety function, and i the negative pressure in these areas do not support a safety system such as the Standby Gas Treatment System. This position is consistent with "SEP Topic IX-5, i Ventilation Systems Millstone Nuclear Power Station Unit 1," dated September 14, l 1982, which concludes that

* :adwaste building and the radwaste storage building l

ventilation systems are not essential. In addition, the only safety related HVAC '

equipment in the turbine building is the recirculation coolers servicing the condensate and feedwater pump areas.

Cause:

The cause of the violation for the turbine building, radwaste building, and the radwaste i storage building ventilation systems is failure to ensure procedures and processes exist !

to operate the facility in accordance with the UFSAR.  ;

The cause of the violation for the steam tunnel ventilation system is failure to identify ,

the safety analysis assumption of zero draw down time when operation of the SGTS is 1 required to support secondary containment. The steam tunnel ventilation system safety i function is to isolate when the SGTS system initiates. NNECO did not identify that the operation of this system supports an initial condition of zero draw down time for the secondary containment during an accident condition.

Contributing Factors:

The current Technical Specifications for Millstone Unit No.1 require surveillance of the secondary containment integrity of the steam tunnel in conjunction with the reactor building by operating the SGTS. The additional surveillance requirement for monitoring secondary containment pressure during reactor power operation included in the General Electric Standard Technical Specifications is not part of the current Technical Specificationsfor Millstone Unit No.1.

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j , B16307\ Attachment 1\Page 3

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j f Corrective Steps That Have Been Taken and Results Achieved i l To ensure compliance with the negative pressure requirement during RFO 15 refueling i' operations, the steam tunnel will not be isolated from the reactor building since their is no e potential for a HELB event. Therefore, the steam tunnel pressure is monitored as part of

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the reactor building pressure. NNECO is in full compliance with the steam tunnel HELB

doors open.

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, Corrective Actions That Will Be Taken

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.NNECO has initiated a design modification package to install a permanent local differential pressure gauge for the steam tunnel. The gauge will be accessible during

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reactor power operation. When the steam tunnel is isolated from the reactor building by j i the HELB doors, the gauge will allow logging of the negative pressure in the steam 1 I tunnel 1 i l

. The design modification package to install the local gauge for the steam tunnel

! pressure will be completed prior to reactor restart. The modification package will l include' revision of an operator log to record the steam tunnel pressure during i operation. The Technical Requirements Manual will be revised to specify the steam-l tunnel differential pressure in addition to the reactor building pressure. The minimum _

pressure limit for the local gauge will ensure that the pressure in the steam tunnel is at  !

l least -0.25 inches of water during reactor power operation.

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! The current design description of the turbine building and the radwaste facilities

!' ventilation systems in the UFSAR has not been validated. NNECO will validate the j design of these systems during the 10CFR50.54(f) review process. Additionally, the

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design for the radwaste building will be' modified as part of the Radwaste Remediation project. The performance of these three systems will be verifbd and maintained by  !

procedures or processes to ensure that these systems are operated in accordance with  ;

the UFSAR. l

Date When Full Compliance Will Be Achieved l NNECO is currently in compliance based on monitoring of the reactor building pressure j which is common to the. steam tunnel pressure. NNECO will be in compliance for i reactor power operation prior to reactor restart. l i

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