IR 05000336/1997080

Ack Receipt of 970603 & 06 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-336/97-80 & 50-423/97-80

ML20141E030
Person / Time
Site:	Millstone
Issue date:	06/19/1997
From:	Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
50-336-97-80, 50-423-97-80, NUDOCS 9706300192
Download: ML20141E030 (3)

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[pmcgd'o UNITED STATES eN. .'l NUCLEAR REGUL ATORY COMMISSION j* ,, L. t. REGION I

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JUNE 19, 1997 Mr. Bruce President and Chief Executive Officer Northeast Nuclear Energy Company J P. O. Box 128 Waterford, Connecticut 06335-0128 SUBJECT: COMBINED INSPECTION NOS. 50-336/97-80 AND 50-423/97-80 (REPLY)

Dear Mr. Kenyon:

This letter refers to your June 3,1997 and June 6,1997 correspondence related to Unit 2 and Unit 3, respectively, in response to our May 8,1997 letter, which documented the findings of our maintenance rule baseline inspection.

Thank you for informing us of the corrective and preventive actions documented in your letter related to the violations issued for scoping aspects of the maintenance rule programs.

These actions will be examined during a future inspection of your licensed program.

Further, we noted your clarifications related to the specific systems involved at Unit 3 and do not disagree with your positions.

We appreciate your cooperation.

Sincerely,

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Glenn W. Meyer, Chief pD N Operating Licensing and H t. mn Performance Branch Division of Reactor Safety Docket No. 50-336; 50-423 \

NBC fil.E CENrfB COPY 9706300192 970619

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l-Mr. Bruce cc:

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

M. Bowling, Jr., Unit 2 Recovery Officer

! M. H. Brothers, Vice President - Millstone, Unit 3 D. M. Goebel, Vice President, Nuclear Oversight J. K. Thayer, Recovery Officer, Nuclear Engineering and Support l P. D. Hinnenkamp, Director, Unit Operations F. C. Rothen, Vice Presioent, Work Services J. Stankiewicz, Training Recovery Manager l . R. Johannes,' Director - Nuclear Training L. M. Cuoco, Esquire -

J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control S. B. Comley, We The People 1 l State of Connecticut SLO Designee l l D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN J. M. Block, Attorney, CAN S. P. Luxton, Citizens Regulatory Commission (CRC)

l Representative T. Concannon E. Woollacott, Co-Chairman, NEAC l

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Mr. Bruce !

Distribution:  ;

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Region i Docket Room (with coov of concurrences)

Nuclear Safety information Center (NSIC)

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NRC ResidentInspect6T

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M. Kalamon, SPO, Rt -

W. Lanning, Deputy Director of Inspections, SPO, Ri D. Screnci, PAO W. Travers, Director, SPO, NRR l J. Andersen, PM, SPO, NRR  !

M. Caliahan, OCA R. Correia, NRR W. Dean, OEDO S. Dembek, PM, SPO, NRR G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR D. Mcdonald, PM, SPO, NRR P. McKee, Deputy Director of Licensing, SPO, NRR L. Plisco, Chief, SPO, NRR S. Reynolds, Technical Assistant, SPO, NRR Inspection Program Branch (IPAS)

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The Nortlwa<.: l'tthi,* *v*iern June 03,1997 Docket No 50-336 B16486 Re: 10CFR2.201 U.S. Nuclear Regulatory Commission Attention: Document Control Desk

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Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Facility Operating License No. DPR-65 Reply to Notice of Violation 336/97-80-01 I,1soection 50-336/97-80 in a letter dated May 8,1997,W the NRC transmitted the results of their Maintenance Rule Program implementation inspection conducted at the Millstone Station on March 3 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 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 scoping of systems, structures and components (SSCs) was not in accordance with 10 CFR 50.65(b)(1) and (2). )

Athchment 1 provides NNECO's reply to the Notice of Violation pursuant to the l provisions of 10CFR2.201. l l

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

B16486-1 The remaining maintenance rule implementation activities (rick 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.

W James T. Wigg5s to Bruce D. Kenyon, *NRC Combined inspection 50-245/97-80; 50-336/97-80;'50-423/97-80 and Notice of Violation," dated May 8 1997.

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U.S. Nuclear Regulatory Commission B16486\Page 2 Should you have any questions regarding this submittal, please contact Mr. Ravi Joshi at (860) 440-2080.

NORTHEAST NUCLEAR ENERGY COMPANY JV eh 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

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I Attachment 1 ,

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

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June 1997

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U.S. Nuclear Regulatory Commission B16486\ Attachment 1\Page 1 Restatement of Violation

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10CFR50.65(b)(1) and (2) require, in part, that the scope of the monitoring program specified in Section (a)(1) shall include safety-related and non-safety related 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 could prevent safety related SSCs from fulfilling their safety related function: or (iii)

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 e containment auxiliary circulating system - used in EOPs e condenser air removal exhaust system - used in EOPs e exciter air cooler system - scram or loss of safety related function

e intake structure ventilation - scram or loss of safety related function Reason for the Violation and Causes l

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

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

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 the significant fraction of the mitigation function for a system listed in the EOPs. The l 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 that are directly identified in the main sequence of the plant's events and/or functionally

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oriented EOPs be in scope to the maintenance rule.

l 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 l

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U.S. Nuclear Regulatory Commission B16466\ Attachment 1\Page 2 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, March 17-21,1997.

l Corrective Steps that have been Taken and the Results Achieved )

NNECO has taken steps to assure that SSCs required to be included within the scope 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 bystems in the maintenance rule scope.

A detailed review, involving a second person review, was conducted of the emergency operating procedures (EOPs) to ensure all systems and sub-systems are included 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 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 maintenance rule scope. l A review was conducted of other systems to determine if incomplete engineering evaluations for maintenance rule program scope applicability existed. The review identified that one system (Non-Radwaste Ventilation) had been under evaluation at 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, peTormance 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).

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The Northract l'tiLtie. =prem AN 6 1997 Docket No 53-423 n B16495 Re: 10CFR2.201 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 3 Reply to Notice of Violation 50-423/97-80-01 Maintenance Rule Inspection in a letter dated May 8,1997, tha NRC transmitted the results of their Maintenance Rule Program implementation inspection conducted at the Millstone Station on March  !

17-21,1997. The NRC Inspection Report concluded that ten systems at Millstone Unit l No. 3 were omitted from the scope of our Maintenance Rule Program contrary to 10CFR50.65(b)(1) and (2), which required implementation by July 10,1996.

Our review of the Inspection Report identified two items which differ from the results of l our investigation and the inspection exit meeting results. The items are related to the  !

scoping decision for the radiation monitoring panel, and the safety classification of the l emergency lighting battery pack supports. These items were subsequently discussed with members of the NRC Staff from Region 1 and the Millstone Unit No. 3 Resident It was inspectors during two conference calls held on May 29 and June 3,1997.

agreed that the details presented in the conference call should be addressed in our response to the Notice of Violation. Our interpretation of these two items is discussed in our reply to the violation contained in Attachment 2.

NNECO's commitments associated with the response are contained within Attachment 1 to this letter.

Attachment 2 provides our reply to the Notice of Violation pursuant to the provisions of 10CFR2.201.

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U.S. Nuclear Regulatory Commission B16495\Page 2 .

Should you have any questions regarding this submittal, please contact Mr. David -

Smith (860) 437-5840.

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- NORTHEAST NUCLEAR ENERGY COMPANY l

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M. H. Brothers Vice President - Millstone Unit No. 3 Attachments (2)

cc: H. J. Miller, Region I Admmistrator J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident Irispector, Millstone Unit No. 3 W. D. Travers, PhD, Director, Special Projects Office

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Docket No. 50-423 16495

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I Attachment 1 l l

Millstone Nuclear Power Station, Unit No. 3 NNECO's Commitments in Response To

NRC Combined Inspection Report 50-245/97-80,50/336/97-80, and 50-423/97-80 i

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U.S. Nuclear Regulatory Commission B16495\ Attachment 1\Page 1

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Enclosure List of Regulatory Commitments The following table identifies those actions committed to by NNECO in this document. '

Please notify the Manager - Nuclear Licensing at the Millstone Nuclear Power Station, Unit No. 3 of any questions regarding this document or any associated regulatory commitments.

i Number Commitment Due  !

B16495-01 issue the guidelines and instructions currently used l for implementation of the Maintenance Rule Program July 15,1997 as controlled instructions.

B16495-02 Complete the remaining activities associated with the implementation of the Maintenance Rule (risk significance determination, performance criteria July 15,1997 development, historical performance assessment, and development of system basis documents) for the new systems added to the scope.

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Docket No 50-423 B16495 l

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Attachment 2

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Millstone Nuclear Power Station, Unit No. 3 Reply to Notice of Violation 50-423/97-80-01 NRC Combined Inspection Report 50-245/97-80,50-336/97-80 and 50-423/97-80  ;

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June 1997

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U.S. Nuclear Regulatory Commission  :

4 B16495%ttachment 2(Page 1 .

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Restatement of the Violation

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, During an NRC inspection conducted March 17-21, 1997, violations of NRC '

requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below: ,

i 1. 10CFR50.65(b)(1) and (2) require, in part, that the scope of the monitoring program specified in Section (a)(1) shall include safety-related and non-safety related structures, system, and components (SSCs), as follows: (a) safety-related SSCs and (2) non-safety related SSCs: (i) that are relied upon to mitigate

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accidents or transients or are used in plant emergency operating procedures (EOPs): or (ii) whose failure could prevent safety-related SSCs from fulfilling )

their safety- related function; or (iii) whose failure could cause a reactor scram or j actuation of a safety-related system.

Contrary to the above, as of November 18,1996 for Millstone Unit No.3, the i facility failed to include the following SSCs within the scope of the maintenance :

rule: j e fuel assemblies - safety-related

. fuel handling system - safety-related

. alternate shutdown panel- safety-related i

. radiation monitoring panel - safety-related

. emergency lighting battery pack support - safety-related )

. tunnel under the service building - safety-related

. fire protection - mitigate accidents or transients e post accident sampling - used in EOPs

. communication - used in EOPs e emergency lighting - used in EOPs This is a Severity Level IV violation. )

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Reason for the Violation: l NNECO agrees with this violation, with the exceptions noted below, that Millstone Unit No. 3 failed to include the above'SSCs within the scope of the Maintenance Rule Program requirements by July 10,1996.

. Our review indicates that the radiation monitoring panel was in-scope and safety- i related at the time of the inspection. The radiation monitoring panel is not listed as a separate system within the scoping documentation but is a component within the

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B16495\ Attachment 2\Page 2

Radiation Monitoring System which was in-scope and safety-related at the time of

the inspection. During the November 1996 inspection, the inspectors identified that

' the Main Control Board system was not in-scope although this system is not listed in l

j - the violation.' The Main Control Board system was added to scope subsequent to

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. The emergency lighting battery pack supports are listed in FSAR Table 3.2-1, " List i

of QA Category 1 and Seismic Category 1 Structures, Systems, and Components,"

which does not clearly delineate the difference between which SSCs are QA l

' Category 1 (safety related) and Seismic Category 1. Master Equipment and Parts

List (MEPL) Determination No.1143, the document which defines the safety related

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functions of plant equipment, indicates that the emergency lighting SSCs are not

! safety related. The Emergency Lighting System was added to the Maintenance

! Rule scope due to the EOP scoping criterion, but not the safety-related criterion.

! Between November 1996 and the March 1997 Baseline inspection, Millstone Unit No. 3 issued two Adverse Condition Reports (ACRs M3-96-1211 and M3-96-1212) to document this condition, evaluate the causes and perform a review of the initial scoping effort. The results of this effort identified other systems in addition to those identified during the NRC inspection, which were required to be added to the Maintenance Rule Program scope. Millstone Unit No. 3 revised the initial decision documentation associated with these systems and included them in scope as of January 30,1997.

However, this was after the July 10,1996 rule implementation date.

i The causes which contributed to this event are:

1. Inadeauste Procedure Guidance The instructions for performing the Maintenance Rule Program scoping review for the " Safety Related" scoping criterion only relied on the data contained in the )

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NU Production Maintenance Management System (PMMS) data base and did not include a review of appropriate sections of the FSAR.

i 2. Inadeauste Procedure Comoliance The instructions related to the " Safety Related" scoping criterion state that "The basis for removal of a system from scope must be documented." Contrary to this statement, systems contained Category 1 components or identification Numbers without any justification or documentation stating why the SSCs did not need to be included in scope.

3. Inadeauate Response to Industry Data j

The original scoping decision process was developed consistent with industry practices at the time. However, expectations changed as indicated in the initial '

l baseline inspections conducted at other utilities and discussed in the Nuclear Energy institute (NEI) conference held in late October,1996. The pre-baseline inspection conducted in November 1996 occurred prior to NU taking action to address the scoping issues identified in the industry baseline inspection results.

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B16495\ Attachment 2\Page 3 Y-Corrective Steps Taken and Results Achieved:  ;

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e' The integrated Maintenance Program (IMP) Manual Program Instruction PI-1.1, i I

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" Phase i Scoping," for performing the Maintenance Rule scoping decisions was i

) revised. This Manual now addresses the specific technical weaknesses '

i identified and the overall philosophy or intent of the scoping process.

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. A complete scoping evaluation was conducted using the new instructions resulting in numerous systems being added to the rule scope including those

identified in the violation, b

i Corrective Steps That Were/Will Be Taken to Avoid Further Violations:

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. Millstone Unit No. 3 conducted " stand 4own" meetings in which all work was l

stopped to discuss and stress the importance of procedure compliance. This

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j was done as a generic concern related to procedure compliance and was not j specifically related to this violation.

! e The guidelines and instructions currently used for Maintenance Rule Program e

implementation will be issued as controlled instructions.

t The remaining activities associated with the implementation of the Maintenance

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Rule (i.e. risk significance determination, performance criteria development, l

historical performance assessment, and development of system basis

! documents) for the new systems added to the rule scope are in progress.

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j Date When Full Compliance Will Be Achieved:

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Millstone Unit No. 3 will be in full compliance by July 15,1997 when all Maintenance l

Rule activities for the systems added to scope are complete and the implementing l

j guidelines and instructions are issued as controlled instructions.

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