ML20033B366
| ML20033B366 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/19/1981 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20033B360 | List: |
| References | |
| AEC-MP3-250, NUDOCS 8112010325 | |
| Download: ML20033B366 (5) | |
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L J = =;2= Cl October 19, 1981 Docket No. 50-423 AEC-MP3-250 A01995 U. S.
Nuclear Regulatory Commission Mr. E.
J. Brunner, Chief Projects Branch #1, Division of Resident and Project Inspection Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 3406
Reference:
(1)
E.
J. Brunner to W. G. Counsil, Inspection 50-423/31-09, dated September 14, 1981 Gentlemen:
Millstone Nuclear Power Station, Unit No. 3 I&E Inspection 50-423/81-09 On July 27-31, 1981, the NRC Office of Inspection and Enforcement conducted a routine safety inspection of selected Millstone Unit No. 3 areas. Reference (1) was transmitted to us for response and contains essentially two parts: Appendix A, Notice of Violation, for which a response is required and IE Inspection Report No. 50-423/81-09.
Pursuant to the provisions of 10CFR2.201, Northeast Nuclear Energy Company hereby is submitting a response to the Notice of violation.
Because of time constraints, a three-day extension to the report due date was granted during a telephone conversation between Mr. J. M. Powers and yourself on October 15, 1981.
In Appendix A it was stated that contrary to 10CFR50, Appendix B Criterion V, Northeast Utilities Service Company's Architect Engineer, Stone and Webster Engineering Corporation (S&W), had initiated E&DCR's which did not fulfill procedural requirements. Specifically, E&DCR PS-S-1004 was said to have been initiated to revive an obsolete E& DOR F-S-2683 by reference only, which is not provided for in procedures.
Further, E&DCR PS-S-1004 was never incorporated into the specification mentioned. Also, as a second part to the violation it was stated that procedures also require that changes to specification requirements would be entered in the "E&DCR and N&D Specification Change Record" against the specification. However, the inspector observed that the "E&DCR and N&D Specification Change Record" for Specification C-999 did not accurately reflect the status of E&DCRs against the above specification.
Specifically, E&DCRs F-S-2640 and F-S-3374 had been incorporated in the Revision #2 of the Specification C-999 issued in January, 1981; however, the "E&DCR and N&D Specification Change Record" for the above specification listed these two E&DCRs as "open" and still to be incorporated.
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Response
(Part 1)
Upon review of E&DCRs PS-S-1004 and F-S-2683 along with the described violation, S&W has concluded:
o E&DCR F-S-2683 was issued as a no change "information only" E&DCR which included a generic concrete repair procedure. This E&DCR should have been a " specification change" to be incorporated in the C-999 Specification and not for "information only."
o E&DCR PS-S-1004 was subsequently written.against the C-999 Specification to incorporate the repair procedure into the specification. E&DCR PS-S-1004 should have more properly in-cluded the actual repair procedure as described on E&DCR F-S-2683 and a statement that PS-S-1004 thereby superseded F-S-2683.
The NRC finding incorrectly states that PS-S-1004 " revived" an v
" obsolete" F-S-2683.
E&DCR F-S-2683 had not in fact become obsolete upon issuance of Revision 1 to the C-999 Specification.
Unincorporated E&DCRs cannot be " voided or superseded" unless another E&DCR is generated as stated in EAP 6.3.
To clarify the above situation, S&W has implemented the-following action:
o A new E&DCR will be issued to supersede PS-S-1004 which will include and identify the concrete repair procedure as an addition to the C-999 Specification.
o Addendum No. 1 to Revision 2 of the C-999 Specification is presently under review and shall be issued by November 1,1981. -
This addendum will include the incorporation of the new E&DCR superseding PS-S-1004, In addition, S&W will perform a review of a sample of unin-o corporated " change" E&DCRs which revise (supplement / supersede) another E&DCR to ensure the condition identified is isolated.
Any similar situations shall be corrected accordingly. This action shall be completed by December 1,1981.
To provide further clarification in the future, S&W has taken the following action:
o NEAM 38 (MP3 Project Procedure) " Authorization of Engineering and Design Changes" has recently been revised and includes the following requirement for " Supplementing" E&DCRs. Supplementing E&DCRs are to be used only when it is not practical to issue an E&DCR to completely replace (i.e., supersede) the previous E&DCR.
This revision to NEAM 38 was issued September 22, 1981.
o EAP 6.5, " Preparation,. Review, Approval, and Control of E&DCRs -
Computerized Logging and Tracking System" has been adopted by the MP3 Project which further details the requirements for revising E&DCRs. Also, a separate block (No. 11) has been added to the E&DCR form for description of details when revising / superseding an E&DCR.
Response
(Part 2)
Revision 2 to Specification C-999 incorrectly listed E&DCRs F-S-2640 and F-S-3374 as incorporated by reference only (i.e., a one-time change "not to be-incorporated"). These E&DCRs, however, were generic changes identified as "to be incorporated" in the specification and were recorded as such in the Specification Change Record.
-The incorrect listings of these E&DCRs in Revision 2 to the C-999 Specification is an isolated instance that is attributed to an over-sight by the, preparer of the revision. These E&DCRs have teen in-cluded as text additions to Addendum No. 1 (issue date scheduled November 1, 1981) to Revision 2 of the specification. Since the Change Record still identified the E&DCRs as being outstanding and "to be incorporated" in the spncification, it properly reflected the actual condition of the change control status of the specification, and will be updatad upon issuance of the specification addendum.
To ensure that all outstanding E&DCRs are properly listed in speci-fications in the future, the Project E&DCR Coordinator-will review all revisions and addenda prior to being: issued. A similar review of E&DCR incorporation in drawings is a standing project policy (NEAM-38). This review requirement will be added to the next revision of NEAM 3, " Specification, Inquiry, and Purchase Procedure."
I We trust the above response satisfactorily responds to t' e violation cited by your inspector.
Very truly yours, i
NORTHEAST NUCLEAR ENERGY COMPANY
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.i M MA W. G. Counsil Senior Vice President s
cc:
Mr. Boyce H. Grier, Director Region I Office of Inspectbn and Enforcement U. S. Nuclear Regulatory Commission j
631 Park Avenue King of Prussia, PA 19406 (Continued on Next Page) 4 l
cc:
Mr. Harold D. Thornburg, Director Division of Reactor Construction Inspection Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. J. C. Mattia, Resident NRC Inspector Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission P. O. Box 128 Waterford, CT 06385 1
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s Then personally appeared before me W. G. Counsil, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information.in the name and on behalf of the' Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
ib h. 0$12J Notary Public
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