ML20034A678

Forwards SALP Repts 50-245/88-99 & 50-336/88-99 for Period 880101-890615.NRC Finds Overall Assessment of Plant Proper

ML20034A678
Person / Time
Site:	Millstone
Issue date:	04/10/1990
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20034A679	List: ML20034A678
References
NUDOCS 9004240111
Download: ML20034A678 (6)

See also: IR 05000245/1988099

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APR 101990

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Docket Nos. 50-245, 50-336

Northeast Nuclear Energy Company

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ATTN: Mr. E. J. Mroczka

Senior Vice President - Nuclear

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Engineering and Operations Group

P.O. Box 270

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Hartford,-Connecticut 06141-0270

Gentlemen:

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Subject:

Systematic Assessment of Licensee. Performance (SALP) Final Combined

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Report Number 50-245/88-99; 50-336/88-99

This forwards the Millstone Nuclear Power Station', Units l'and'2 SALP final

combined report for the period January 1,1988 through June 15, 1989. The in-

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itial SALP report was forwarded to you by my October 2,1989 letter-(Enclosure

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1). On October 25, 1989, we discussed the SALP with you~ and your-staff (see-

Enclosure 2.for attendees). We have reviewed your written comments, as pro-

vided by your letter dated November 27,1989 (Enclosure _3), and: herewith. trans-

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mit the final SALP report (Enclosure 4).

In addition, a revision sheet-

(Enclosure 5) is provided to assist'in locating changes, and a review summary

sheet (Enclosure 6) is provided with feedback to your comments.

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In summary, after careful consideration of your comments, and notwithstandi_ng

the changes to the SALP report-text discussed in Enclosure 6, we find the.over-

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all assessment of Millstone Units 1 and 2 to be proper.

No changes to the

ratings are warranted.

We appreciate your comments on the.SALP and the discussion of your plans for

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improving performance. Thank you for your. cooperation.

Sincerely,

Original Signed By:

Thomas T. Mortin

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Thomas T. Martin

Regional Administrator

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Enclosures:

1.

NRC Region I Letter, W.T. Russell to E.J. Mroczka, dated October 2,-1989

2.

SALP Management Meeting Attendees

3.

Northeast Nuclear Energy Company Letter,_E.J. Mroczka to NRC Document

Control Desk, dated November 27, 1989

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4.

Systematic Assessment of Licensee Performance Final Combined Report

50-245/88-99, 50-336/88-99

5.

SALP Board Report Revision Sheet

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Review Summary Sheet

OFFICIAL RECORD COPY

SALP MILL 88-99 - 0001.0.0

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APR 101990

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Northeast Nuclear Energy Company

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cc w/encis:

W. D. Romberg, Vice President, Nuclear Operations

S. E. Scace, Nuclear Station Director,' Millstone Station

J. P. Stetz, Nuclear Unit Director, Millstone Unit 1

J. S. Keenan, Nuclear Unit Director, Millstone Unit 2

D. O. Nordquist, Director, Quality Services

R. M. Kacich, Manager, Generation Facilities Licens_ing

Gerald Garfield,- Esquire

Chairman Carr

Commissioner Roberts

Commissioner Rogers

Commissioner Curtiss

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Commissioner Remick

Vandana Mathur, McGraw-Hill Publications (2 copies)

Art McGuire, Construction Industry Litigation Reporter (2 copies)

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector

State of Connecticut

Institute of Nuclear Power Operations

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K. Abraham, PA0 (25 copies)

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bec w/ enc 1:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

J. Taylor, ED0

J. Caldwell, EDO, Region I Coordinator

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W. Russell, RI

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T. Martin, RI

D. Holody, RI

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M. Knapp, DRSS

W. Hodges, DRS

W. Kane, DRP

J. Wiggins, DRP

DRP Section Chief

J. Shedlosky, SRI, Haddam Neck

M. Boyle, NRR

G. Vissing, NRR

P. Habighorst, DRP

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D. Dempsey, DRP

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Management Meeting Attendees

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DRP Wishlist Coordinator

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SALP MILL 88-99 - 0002.0.0

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Region I Docket Room (with concurrences)'

Management Assistant, DRMA (w/o encl)

J. Taylor, EDO

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W. Russell,' RI-

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T. Martin, RI

D. Holody, RI

M. Knapp, DRSS

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W. Hodges, DRS

W. Kane, DRP

J. Wiggins, DRP

DRP Section Chief

J. Shediosky, SRI, Haddam Neck

M. Boyle, NRR

G. Vissing, NRR

P..Habighorst, DRP

D. Dempsey, DRP

Management Meeting Attendees

DRP Wishlist Coordinator

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SALP MILL 88-99 - 0003.0.0

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UNITED STATES

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NUCLEAR R500LATORY COMMi&SION

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ReelON I .

476 ALLENDALE ROAD

10NG OF PRUSSIA, PENNSYLVANIA 19406

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Docket No. .50-245; 50-336

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Northeast Nuclear Energy Company

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ATTN: Mr. E. J. Hroczka

Senior Vice President - Nuclear

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Engineering and Operations Group -

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P. O, Box 270

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Hartford, Connecticut 06141-0270

Gentlemen:

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Subject:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT FOR

MILLSTONE 1 AND 2 FOR THE PERIOD JANUARY 1,.1988 TO JUNE' 15, 1989

(50-245/88-99; 50-336/88-99)

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The enclosed report transmits the initial results of the Mill' stone 1 and 2 SALP

Board meeting conducted on August 7, 1989. We will contact you soon._to

schedule a meeting to discuss the evaluation. At the. meeting, please be pre-

pared to discuss the assessments and any plans you have to improve performance.

You may provide written comments within 30 days of the meeting. A final SALP.

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report will be issued subsequent to to the meeting.

Our evaluation noted continued good performance and safe operations. Areas

requiring further attention include the solicitation and resolution of. employee

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concerns'at Millstone 2 and the weaknesses that allowed the release of contami-

nated equipment from Millstone 1.

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Thank you for your cooperation.

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Sincerely,

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William T. Russell

Regional Administrator

NRC Region I

Enclosure: NRC Region I Combined SALP Report 50-245/88-99; and 50-336/88-99

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Northeast Nuclear Energy Company.

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cc w/ enc 1:

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W. D. Romberg, Vice President, Nuclear Operations

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S. E. Scace, Station Superintendent

D. O. Nordquist, Director of Quality Services

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R. M. Kacich, Manager, Generation. Facilities Licensing

D. B. Miller, Station Superintendent, Haddam Neck

Gerald Garfield, Esquire

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P,ublic Document Room (PDR)

Local Public Document Room (LPDR)

Nuc mar Safety Information Center (NSIC)

C Resident Inspector

State of Connecticut

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ENCLOSURE-2

NRC/ NORTHEAST NUCLEAR ENERGY COMPANY MANAGEMENT MEETING

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OCTOBER 25, 1989

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NAME

TITLE

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NRC Region I

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W. T. Russell

Regional Administrator ~

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M. W. Hodges

Director, Division of Reactor Safety (DRS)

E. C. Wenzinger

Chief, Projects Branch 4, Division of Reactor Projects.

(DRP)

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D. R. Haverkamp

Chief,' Reactor Projects ~Section 4A (RPS)'

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W. J. Raymond

Senior Resident Inspector, Millstone Station

P. J, Habighorst

Resident Inspector, Millstone 2

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NRC Nuclear Reactor Regulation (NRR)

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J. F. Stolz

Director, Project Directorate I-4- (PD'I-4)

M. L. Boyle

Project Manager (Millstone 1) (PD'I-4)

G. S. Vissing

Project Manager, (Millstone 2) (P0 I-4)

Northeast Nuclear Energy Company

W. B. Ellis

Chairman and Chief Executive O'fficer

B. M. Fox

President, Northeast Utilities .

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J. F. Opeka

Executive Vice President - Engineering and

Operations

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E. J. Mroczka

Senior Vice President - Nuclear Engineer and

Operations

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R. J. Gallagher

Corporate Communications

R. Kacich

Manager, Generation Facilities Licensing

5. E. Scace

Millstone Station Superintendent

J. Stetz

Millstone Unit 1 Superintendent

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J. S. Keenan

Millstone Unit 2 Superintendent

H. F. Haynes

Millstone Station Services Superintendent'

R. T. Harris

Director, Nuclear Engineering

G. L. Johnson

Director, Generation Engineering.and Design

J. M. Black

Director, Nuclear Training

D. O. Nordquist

Director, Quality Services.

W. E. Hutchins

Generation Facilities. Licensing

R. Werner

Vice President - Generation Engineering and

Construction

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ENCLOSURE

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UTILITIES

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AR oR

ONNECTICUT 06141080

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November 27, 1989

Docket Nos. 50 245-

50 336

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B134 t , Re: SALP U.S. Nuclear Regulatory Commission ! Attention: Document Control Desk " Washington, DC 20555 , Gentlemen: Millstone Nuclear Power Station, Unit Nos. I and 2 l Systematic Assessment of Licensee Performance ~ . The Staff recently forwarded. thgcombined Systematic. Assessment- of Licensee Performance (SALP) Board Report for Millstone Unit Nos. I and ; 2 covering, the 18 month period of January ), 1988 to June 13, .1989.- Subsequently, a . ' meeting was held on October 25, 1989 between members of the Staff and members- of Northeast Nuclear Energy Company (NNECO) ~to . discuss the assessments con- 1 tained in the above-mentioned SALP Report. < Ihe purpose of this letter is to respond to and comment' on the findings of the l SALP Board and on the Board recommendations . forH the individual evaluation ! ! categories. The responses to the Board's recommendations for Millstone; Unit ' Nos. l' and 2 are contained in Attachment A. NNECO takes = very : seriously. the ratings and recommendations given by'the Board as-an input into'the continuing i process'of evaluating and improving our overall performance. As reflected by our comments and observations.during the 0ctober 25,1 1989: meeting, we gener- ally concur with the Board's observations and conclusions, and previously have'

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taken or are taking steps to address the concerns- identified.- -The - only notable exception to our concurrence with the Board's conclusions is- in.the l- functional area of Safety Assessment / Quality Verification for Millstone-' Unit- 4 L No. 2.. Details can be found -in . Attachment: A. It remains :our objective to i L achieve Category I ratings in all functional. areas for subsequent SALP evalua- e tions, and the attachments to this '. letter describe some of the steps we will. i be taking to fulfill that objective. ' (1) W. T. Russell letter to E. J. Mroczka- dated October 2,1989, Systematic j Assessment of Licensee- Performance (SALP) Report for Millstone 1 and 2 i for the Period January 1,- 1988 to June 15 - 1989 (50-245/88-99; '50-336/88-99). - % jV Of.LJ g D cY f fY l j w

n . t ! - . . - t , , . U.S. Nuclear _ReQulatoryCommission B13411/Page 2 November 27,.1989 , i We trust that the actions presented in the-attachments addressing the concerns of the Board and our general comments will be considered in subsequent SALP evaluations. We will be updating you regarding the status of implementing the , corrective actions discussed herein prior to the next SALP evaluation. In particular, we are aggressively pursuing improvements with respect to our nuclear concerns program and will be communicating with you separately on this- topic. Please feel free to contact my staff if you have any questions- regard- ing this matter.

Very truly yours,

! NORTHEAST NUCLEAR ENERGY COMPANY E. V f Mroczka (/ ^ Senfor Vice President cc: W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 , W. J. Raymond, Senior Resident inspector, Millstone Unit Nos. 1, 2, and 3 , , f 4 ' -- ' e, , - - -- ,c-- - - - , , ,

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, ' . .. Docket Nos'. 50 245

50-336 B134]l l i L l 1; ! Attachment A Northeast Nuclear Energy Company Millstone Unit Nos~. I and 2 i Response to SALP Report j ! 1 'i ) 1 p. l i l l i I

November 1989 ! .i i i ' l ij

- . ., . i . . . . . . ' U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page I l November 27, 1989

FUNCTIONAL. AREA: PLANT OPERATIONS l . + !

Millstone Unit No. I , l l [ Board Recommendation: l Licensee: Aggressively pursue ongoing E0P improvements. . l Response: i Millstone Unit No. 1 E0Ps, upgraded to Revision 4 of the BWROG Emergency Procedure Guidelines, were implemented as of September 1,1989. The recent NRC SALP Report for Hillstone Unit No.1 idy'tified prior E0Ps as having poor usability. The E0P inspection in June 1988 identified a number , l of areas that needed attention relative to our E0P program. Some of the specific technical issues were addressed and ' resolved by October 1988. The , usability issue is one that stems primarily from a human fetors viewpoint, which can be a rather subjective evaluation. We recognized that improvements. , l could be made to the E0Ps and were in the proc.ess of developing m::: EOFs with the assistance of one of the BWR Owners' Group contractors. Our objective was to make future E0Ps very usable. These E0Ps, in our opinion, have improved significantly in this area ' - 'We strongly believed that our operators could safely and ' effectively operate the plant in any transient situation using the E0Ps in existence at the time i of the . June 1988 NRC inspection. They were and continue to_ be extremely knowledgeable and had been trained to effectively use the procedures. Although the SALP report specifically addressed usability, the above-mentioned NRC inspection audit report stated that "the inspection team!was . impressed with the knowledge level of the plant staff relating to accomplishment of the- E0Ps and concluded that the operators could adequately perform the procedures in spite of the procedural inadequacies."' We agree with this. statement and question the appropriateness of the NRC concern regarding E0P usability in the SALP Report. However, we acknowledge the need- to address the issues identi- fied as having room for improvement, and will continue to strive for_ better ' performance. (1) S. A. Varga letter to E. J. Mroczka, " Emergency ' Operating Procedures inspection (Inspection Report No. 50-245/88-200)," dated September 23, , 1988. , w - + e* 9

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._ _ _ __ _ _ . __ , 4 . .- U.S. Nuclear Retjulatory Commission B13411/ Attachment A/Page 2 . November 27, 1989 Millstone Unit No. 2 r Board Recommendation: None. Response: , NNECO agrees with the Staff's assessment of our performance in this functional' area. We acknowledge the need to address the issues identified as having room for improvement, and will continue to strive for better performance. . We would also like to offer the following clarification. The SALP Report states: "The facility applied for NRC certification of the plant simulator significantly ahead of the initially proposed schedule." NNECO believes that more appropriate wording would be "The facility certified its plant reference simulator to the NRC significantly ahead of the initially proposed schedule." . l l l- I' i l L 1 - - . . , . _ . . - - .

, .. _ _ _ _ _ - _ - - _ ___-_ _ __ _ _ _ _ _ __ _ ____ __ _ _ _-_ __ 4 1 - . e U.S. Nuclear Reg'ulatory Commission B13411/ Attachment A/Page 3 ' . November 27, 1989 , FUNCTIONAL AREA: RADIOLOGICAL CONTROLS - ! Millstone Unit No. 1 i Board Recommendation: None.

$ Response: . The SALP Report noted two areas of weakness; specifically, control of high radiation area doors and the release off-site of a contaminated hydrolazing rig. NNECO, without diminishing the significance of these two items in any way, believes that further consideration could have been given to some of the e major health physics improvements made at Millstone Unit No.1, as described below. l During the SALP period, Millstone Unit No. I continued an aggressive trend in lowering man rem exposure and attained a cycle average exposure well below the l BWR industry average. As noted in the SALP Report, this performance was j accomplished by several modificathns, decontamination, and management prac- -

tices. I ' Even though Millstone Unit No. I had four incidents of high radiation area doors left unlocked during the SALP period (only one of which exceeded the - criterion of 1000 mR/hr at 18 inches from the source), the unit did take aggressive and effective action to eliminate this problem. By changing . the , I unit's Technical Specifications to incorporate the 18-inch criterion- (locked high radiation area if greater than- 1000 mR/hr at 18 inches from source), we were able to eliminate 14 high radiation area doors without' compromising

- radiological safety. An additional three doors were eliminated from the ' turbine deck by establishing new barriers and collapsing the high radiation area. These three doors had been the source of the majority of noted unlocked high radiation area doors. Additionally, a design change which will ensure l positive locking of the high radiation area doors prior to alarm silencing was developed and tested on select doors. This modification has proven very , effective and will be expanded to additional doors. The elimination of 17 of l- the 59 high radiation area doors at Millstone Unit No.1 is a major accom- plishment, one which we believe to be underestimated by the NRC. ' The release of the contaminated-hydrolazer off-site indicated a programmatic weakness in the control of radioactive material, and is viewed- seriously by NNECO. Appropriate corrective actions are being taken. Nonetheless,' we believe that NNECO's aggressive and effective action- in reducing man-rem, collapsing high radiation areas, decontaminating, along with other high quality aspects of our Health Physics Program, have been underemphasized in the SALP report due to the contaminated hydrolazer issue. However, we 1 - - - , - - .-- , ,, e- - - . . - - - -

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. U.S. Nuclear Regulatory Commission. . B13411/ Attachment A/Page '4 - November 27, 1989 acknowledge the need to address the issues identified as having room for improvement, and will continue to strive'for better performance. t Millstone Unit No. 2

' t Board Recommendation: + ' None. Resoonse: - NNECO agrees with the Staff's assessment of our performance in this functional area. We acknowledge the need to address the issues identified as having room for' improvement,- and will continue to strive for better performance, t . . l I f f , -,

. . . . . . U.S. Nuclear Regu'latory Commission B13411/ Attachment A/Page 5 November 27, 1989 ' FUNCTIONAL AREA: MAINTENANCE / SURVEILLANCE l 1 Millstone Unit No.1 Board Recommendation: None.- Resoonse: NNECO agrees with the Staff's assessment of our performance in this functional We acknowledge the need to address the issues identified as having room area. for improvement, and will continue to strive for better performance. At the October 25, 1989 SALP meeting, discussion took place regarding the torque switch for 1-LP 2B which was inadvertently worked on by a maintenance electrician. Additional information was_ requested to be provided -in our 30 day response. 1-LP-2D had been tagged out for torque switch ' work when the maintenance l electrician misidentified these two valves which are located in the same

vicinity of the Reactor Building northeast corner room. The cause of- this i 1 error was inadequate labeling of these components and the relative inexperi- ence of the maintenance electrician. The insufficient labeling = of these and similar valves has been corrected, and the electrician involved has received i a additional training. Additionally, all Maintenance Department electricians received training on the importance of. properly identifying components to be- worked. ' , > Although this incident identified a clear deficiency in maintenance practice, ' this was an isolated event with no other similar instances. l l Millstone Unit No. 2 ' . i I Board Recommendation: ' None. Response:

. One of the areas of concern was an NRC-perceived deficiency in the root cause I analysis for the reactor vessel head 0-ring leak which resulted in several l l unplanned forced outages. Preliminary indications showed a possible head l , i L-

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3 . . , U.S. Nuclear Reguiatory Commission B13411/ Attachment A/Page 6 , November 27,-1989 l however, the data were neither consistent nor ' 0 ring leak in late March; conclusive. More specific indications were from secondary-side sources because we had recently opted to utilize boric acid addition to the secondary The buildup of boric acid on the CEDM coolers was, therefore, original- In retrospect, had side. ly thought to be from secondary sources, not the 0 ring. indications, plant additional emphasis been placed on the originai 0-ring management may have been able to deduce that the only ma.ior source of primary system leakage was the 0-ring. While the need for more than one plant shut-vi down was unfortunate, we do not , ' -inattentive management. NNECO was also requested to explain some- of I At the SALP management meeting, he lessons learned from one plant to all .four the mechanisms we use to apply t Approximately once per month, super- of Northeast Utilities' nuclear units. intendent staff meetings take place in which the three Millstone plant and two Millstone station superintendents-meet with the Haddam Neck Plant superinten- These meetings place dents and the Vice President of Nuclear Operations. considerable emphasis on transfer of pertinent plant information between the Lessons learned at one plant are therefore passed on to the others. units. Also, telephone conversations between individuals at similar various organiza- tional levels result in the transfer of information between meetings. The plant personnel are kept abreast of the other units' activities at each Each plant has a counterpart at the other units and these morning meeting. individuals discuss pertinent events that occur at each unit. . 5 a J A - . . - - . .. - - , - -* 5 v

. _ _ - ._. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . ' . ' U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page 7 1 , November 27, 1989 l ! i l FUNCTIONAL AREA: EMERGENCY PREPAREDNESS > l Millstone Unit Nos. I and 2-

L Board Recommendation: ' None. Resoonse: The NRC identified a concern regarding an apparent lack of independence of the auditors performing emergency plan audits. This issue has' been resolved in NE0 3.02, " Conduct and Format of Nuclear Review Board Audits," Rev. 4, dated- November 1, 1988. Previously, the individuals performing emergency plan audits worked for the corporate manager in charge of the corporate emergency plan, thus creating the - NRC perceived conflict of interest. The Site Emergency Plan and Implementing Procedures are now audited at least once per 24 months by an audit team led by a certified lead auditor from the Quality Services Department. , , The 1989 Emergency Plan Audit (A24015) was successfully performed by four individuals from the Quality Services Department. We believe the above actions to be responsive to the stated concern. NNECO agrees with the Staff's assessment of our performance in this functional - area. We acknowledge the need to address the issues identified as having. room for improvement, and will continue to strive for better performance. ' l <

.- - . - - - - . - ._ . i . . U.S. Nuclear Regulatory Comnission - 813411/ Attachment A/Page 8 4 November 27, 1989 .1 FUNCTIONAL AREA: SECURITY- l Millstone Unit Nos. I and 2 Board Recommendation: , ! l None. Response: The NRC noted that' the turnover rate in 1988 was very high . (approximately 47 percent), and that the overall experience level of the guard force- was- being reduced by this high turnover rate. In - evaluating this concern, a single root ' cause could .not be determined. There are, however, several factors that may have contributed to the turnover - ' figures. o At the present time, the region of southeastern Connecticut is experienc- , l ing a very low unemployment rate. Burns International Security Services - has conducted a survey which shows that the young officers (age 18-30) account for the majority of the turnover figures. The. low unemployment- i rate has permitted younger security officers to " job hop," thus adding to the termination totals.

o In May of 1988 the contractor union guard force went on strike. As a- ' ,

result of this job action, many of the -union security officers either - 4 resigned giving two weeks' notice, or quit without notice. .Statisti- cally, all of these officers appear as " terminations," and hence add to the turnover rate. In reality, some of these, officers were rehired in

, ' the months following the strike. These rehires are then reflected as "new hires," although some have several years of experience.-

l o Due to a shortage- of security personnel through September"1988, many officers were required to work- excessive overtime. In September, man- power was increased and the guard force returned to' a normal work week.. The Burns survey shows that terminations decreased in the months follow- . ing September. The Burns survey of terminations shows that. the turnover figures are higher for the unarmed officers (the less experienced) and lower for armed officers and supervisors (the more experienced). With the turnover rate being concen- trated among the younger and less experienced officers, the loss ce overall experience is not as great as it appears. A review ' of the security force roster showed that more than half of all security personnel have been employed for two years or greater. In an effort to reduce the turnover rate, Burns has given . training to supervisors on how to reduce turnover. Additionally, they 1 l~ i - - . .. . ~ . . -

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' B13411/ Attachment'A/Page 9 ' November 27, 1989 .! interviews for terminating have enhanced their program of conducting exit , officers in an effort to identify problems or trends. The information on .t* turnover is being entered into a computer data base that can be sorted on ' " This program is maintained by Burns and will various fields of information. provide a means of better analyzing the reasons for turnover. An analysis of the turnover for the period of January 1,1989 to October 31, Of the total 1989, indicates that the rate has been reduced to 25 percent. ' number of personnel that have- terminated their employment during 1989, approx- ' imately 37 percent were terminated for either violations of rules and regula- tions or attendance. Both Burns and NNEC0 management are reviewing other incentive programs that Anticipated improvements in morale are , will reward attendance and safety. expected to have a positive influence in this area. In conclusion, NNECO agrees with the Staff's assessment of our performance in We acknowledge the need to address the issues identi- this functional area. fied as having room for improvement, and will continue to strive for better performance. I ! l - ._. - .. - - . . . .. - - - -

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4 - , " U.S. Nuclear Regulatory Commission '. B13411/ Attachment A/Page 10- November 27, 1989 FUNCTIONAL AREA: ENGINEERING / TECHNICAL SUPPORT Millstone Unit No. 1 Board Recommendation: Licensee: Improve technical evaluations. > Response: ! The Category 2 rating appears to be heavily influenced by four technical evaluations: - , o LER 88-13 Inadequate Seismic Anchorage on Bus 14D o LER 89-01 Clean-Up System EEQ o LER 89-12 LNP While Switching Out RSST , o LER 89-13 Core Spray Flange Pressure Rating Three of these four LERs resulted from evaluations made during the SALP period I which were written to document corrective action taken for situationsowhich occurred priot to this SALP period.- For example, the Seismic Anchorage on Bus 14D LER (88-13) was the result of a thorough technical evaluation which corrected an oversight made in.1980. The Clean-Up System EEQ=LER (89-01) was an example- of an in-depth technical evaluation which corrected EEQ-determina- tions made in 1987. The Core Spray Flange Pressure Rating LER (89-13).. result- ed from an engineer's observation and_ technical support follow-up which ,- corrected a situation which occurred during initial plant construction. ! The three technical evaluations discussed above reflect a vigorous- technical evaluation process which actively seeks to identify problem areas and effec- tively addresses _them. These are - examples - of NNECO'sEpositive attitude , - regarding nuclear safety ethic, which is a major. corporate commitment. We believe this strong technical evaluation- process should be. reflected- more favorably in the SALP Report, rather than being penalized for situations which j occurred prior to this SALP period.- ' The LNP While Switching Out RSST LER (89-12)- occurred during the scheduled- refueling outage while installing major LNP modifications. Even .though the LNP itself was an error, little credit appears to have been. given; to' the- y - complexity of this modification and its testing, and the commendable manner in j which this project was designed, installed, and tested, j u . . .. . .. - ,

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-. . --. _. .. . " . j U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page 11 ,; November 27, 1989 Also, included in the.SALP Report was reference to "an instance that resulted in the emergency diesel generator being inoperable for 17 hours prior to On the i discovery due to installation of an nondedicated commercial part." I contrary, the diesel generator had been administratively logged as inoperable upgraded. This action became while the installed component was properly made in 1986 for-this component necessary after a safety determination (MEPL)d. This emergency diesel gener- , ' was questioned and found to be safety-relate The installed j actually. operable throughout this 17-hour period. ator . was component was ultimately found to be acceptable as is. An NRC Emergency Operating Procedures (EOPs) team inspection of Millstone Unit 1 No.1 E0Ps (Revision 2 of the BWROG EPGs) identified nonconservative errors ' and missing evaluations in the supporting calculations for the containment control procedures; Specifically, it was identified that the primary contain- ment pressure limit and design pressure curves were nonconservative at'sup- Although the curves depicted pression pool water levels greater than 25 feet.a nonconservative operatin , conditions, it should be noted that the procedures did not allow entry into The procedures limited the operator to a suppression pool level th pnly j this region. of less than 22.5 feet which corresponded to the upper. limit of I At the time of identification, the curves- available level instrumentation. The lack of detail to- the curves was nonconservative were properly amended. at very elevated pool levels; the guidance in the procedures assured that the plant'would not be operated in a nonconservative condition. At the SALP management meeting, NNECO commented that there .seems to be an inconsistency in the SALP assessment regarding technical evaluations. Page RI-8 of the SALP. Report appears to commend the discovery and correction i ' of the deficiencies identified, while page 26 of the SALP Report appes to criticize the actions taken to detect these deficiencies. NNECO believes that . this inconsistency warrants clarification. The SALP Report contains a stttement that "to assure top management involve- ment in the timely review and reporting of issues, a monthly status report listing all reportable evaluations was issued." As discussed during the SALP meeting, a clarification is appropriate to reflect .that this report identified the potentially reportable issues being addressed at the corporate office, and it does not include issues dispositioned via the plant PIR processes. In conclusion, NNECO believes that Millstone Unit No.1 Engineering / Technical Support during the SALP period was thorough, professional, and appropriately the focused on safety. We will continue our efforts to further improve quality of technical evaluations, consistent with the Board recommendation. , I -- , , . .- -- - . ,.

_ _ . _ _ . _ . - . < - I . 4 . . U.S. Nuclear Regulatory. Commission B13411/ Attachment A/Page 12 November 27, 1989 Millstone Unit N W Board Recommendation: = None, i Resoonse: ' .NNECO agrees with the Staff's assessment of our performance in this functional We acknowledge the-need to address the issues identified as having room- area. for improvement, and will continue tn strive for better performance. >

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, l . .. U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page 13 November 27, 1989 l . FUNCTIONAL AREA: -SAFETY ASSESSMENT / QUALITY VERIFICATION Millstone Unit No. 1 't ' Board Recommendation: \\ None. ] Response:

NNECO agrees with the Staff's assessment of our performance in this functional; area. We acknowledge the need to address the issues identified as having room i for improvement, and will continue to strive for better performance. The; NRC noted a concern that there were no Quality Assurance organization = audits to verify corrective action commitments for NRC concerns, SALP Board '; recommendations, or LERs. ' i Northeast Utilities Quality Services Department audits, at least once per ! six months, those corrective action systems whose function _is to identify and

correct - deficiencies occurring in unit equipment, structures, systems, and' ] , method of operation that affect nuclear safety. I We have identified the following as corrective action systems which are I audited at-least once during a two year period: 4 o Nonconformances j o PIRs/LERs o Instrumentation Nonconformances

! o Corrective Action Requests Contrary to the NRC statement, Northeast Utilities has audited and will

' continue to audit the adequacy, effectiveness, and timeliness of corrective '! action for LERs. Audits of the corrective action for LERs have been performed i periodically, with the most recent, Audit A21019, being performed November 30, ' 1988. - Northeast Utilities believes that the responsibility for the verification of l implementation of corrective action for NRC concerns and SALP recommendations- ! rests with the respective line management and, as such, is not an audit item under the Technical Specification. Nonetheless, we have a high level of

confidence that the administrative tracking mechanisms in place are effective

in ensuring action items and commitments are appropriately. addressed. These ! tracking systems are an administrative tool for tracking action items which - include Appendix B-related items. Thus, these systems are maintained and i reviewed to ensure the various types of action items are raet. -l

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a U.S. Nuclear Regulatory Commission

B13411/ Attachment A/Page 14

' November 27, 1989 -Millstone Unit No. 2 ' Board Recommendation: Licensee: Further emphasize solicitation and resolution of employee concerns. , Resoonse: The Northeast Utilities Nuclear Concerns procedure has .recently been revised. The-procedure continues to encourage employees to utilize the internal report- ' ing system at Northeast- Utilities. Employees who utilize this system are - assured of a response to their concern (or a schedule of when a response will l be provided) within a specific . time interval. Additionally, employees are afforded an appeal provision at the vice presidential level if they believe that the initial response to their concern is not adequate. The entire nuclear concerns program is also being evaluated for. other. enhance- ' ! ments which will make it more attractive for employees to report nuclear concerns within Northeast Utilities for resolution. Further communications on this subject will occur with the NRC Staff when the provisions of the program have been finalized. , Additional Comments:

' NNECO has reviewed the specific concerns noted by the Staff;in the functional i area of Millstone Unit No. 2 Safety' Assessment / Quality Verification and- l believes, after due consideration, that our understanding of- some of the i . circumstances is different than that summarized' by the Staff in the SALP- ! report. NNECO offers the following comments and clarifications'for considera- l L tion by the Staff. NNECO trusts that after review of 'these clarifying -com- i ments, depending on the individual significance the Staff; placed on these 4 circumstances in the assessment of the Category 2 rating, the Staff would

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revisit the Category 2 rating. NRC Concern The licensee had not established a mechanism to administrative 1y control plant

quality assurance activities. NRC inspection concluded that the Quality . Assurance Audit Department was not sufficiently aggressive-in ensuring timely. j station response to their surveillance findings on Millstone Unit No. 2.- ' Management-involvement in assuring quality could be improved in this regard. j NNECO Response NNEC0 does have a well-defined mechanism to control plant- quality assurance , activities. These directions are basically found in two sets of procedures: .i Administrative Control Procedures (ACPs) governing plant activities, and- l l i.I ' ! L 1 ! l

- -- .. _ __ __ _ _ . . . U.S. Nuclear Reguistory Conmission B13411/ Attachment A/Page 15 November 27, 1989 , Quality Services Department (QSD) Procedures governing QSD activities. There are 93 ACPs covering qtality assurance activities including topics such as procedure control, naconformance reporting, and surveillance and audit There are 31 QSD procedures covering QSD activities including response. tcpics such as receipt inspection, audits, and surveillance performance. The program in effect at the time of the NRC evaluation required surveillance reports to be categorized as either A, B, C, or D. 'A" surveillance reports were required to be resolved prior to placing the equipment back into service. 'B" surveillance reports were required to be resolved prior to the end of the

outage.

• C" surveillance reports were required to be resolved in accordance

with the priority set by the applicable unit superintendent.

• D" surveillance

reports required no response. The NRC concern on timely response focused on Category C surveillances. This category of surveillance does not have a specified response date. The program had intentionally allowed the unit superintendent to determine an appropriate response schedule. The status of responses to these surveillance reports was being periodically reviewed by both the unit and QSD and were being addressed in a manner acceptable to the unit superintendent, in accordance with the A number of the surveillances, in fact, were responded to during the program. week of the inspection on this issue. NRC Concern A request for operation at reduced RCS flow rate, however, was submitted at a late stage of the application review for Cycle 10 operation. This allowed the Staff a very short time to complete the review and created difficulty in 1 combining the two license amendment applications into one amendment. Better planning on this long-expected need could have provided more timely Technical 4 Specification changes and supporting analyses. NNECO Response In a letter dated October 27,1986, NNEt0 submitted a request to amend the Technical Specifications for Millstone Unit No. 2 by reducing the minimum required RCS flow rate from 350,000 gpm to 340,000 gpm. This change was requested because of the reduced flow anticipated from poteatial plugging of steam generator tubes and the resulting potential operation.1 restrictions. License Amendment #113, authorizing this change, was issued prior to Cycle 8 start-up. NNECO submitted the Start Up Test report for Cycle 8 on March 16, 1987. This report showed the measured RCS flow at 100 percent power was 370,200 gpm. This was well above the then recently approved minimum of 340,000 gpm. On April 20, 1988, NNECO submitted the Start-Up Test report for Cycle 9. This showed the measured flow at 100 percent power was 361,600 gpm; still well above the required minimum of 340,000 gpm. It was at this point in time that NNECO judged it prudent to assess RCS flow rate trends from previous cycles. A project assignment was initiated for this purpose. The preliminary recommendations from this project assignment were made in September 1988. F- _ _ _ . . . . . . . _ _ ,

- . - - - . . _ - . . - - - _- - -. . _ _ _ , i . . ~ 1 . U.S.NuclearRegulatoryCommission ' B13411/ Attachment A/Page 16 ,; November 27, 1989 , ~ During the course of this project, it became apparent that in order to account < for measurement uncertainties and potential degradation, a reduced flow amendment request would be a prudent contingency measure. In a letter dated August 26, 1988, NNECO formally informed the Staff that all " ongoing ANF analyses, which were well under way, will assume an RCS flow rate It was too gpm (minimum Technical Specification RCS flow rate). of 340,000 late in the ANF analysis effort to change assumptions for a reduced flow condition and still support the rigorous schedule NNECO hnd committed to the Staff to support NRC review of the Cycle 10 reload analysis. In this letter, we informed the Staff that the reduced flow analysis and supporting amendment , request would be submitted in February 1989 as a supplement to the November 1988 Cycle 10 reload license amendment request. The ANF report to support ' reduced RCS flow was submitted to NNECO on January 18, 1989. (It is noted that a draft ANF report was given to the NRC approximately 1 month earlier to facilitate the review.)- NNECO submitted the report on the docket on .' and submitted the supplemental license amendment ree et on January 23, 1989, This effectively provided the Staff 45 days to prorass the February 1, 1989. supplemental amendment. We acknowledge this interval to be less than ideal, but one that was very responsive under the circumstances. During this period, we believe that the entire reload amendment request was appropriately coordinated with the NRC. We also believe the Staff was ex- tremely cooperative and responsive to the conditions we were facing. In fact, it was the project manager who suggested that ongoing Cycle 10 analyses should 340,000 gpm value, and NNECO could simply supplement continue based upon the its original amendment request when the analyses for the reduced RCS flow were Regarding the NRC statement concerning the difficulty in combining completed. the two license amendment applications, we informally provided a c0py of the merged Technical Specification pages assuming that both license amendment applications were approved simultaneously by the Staff as submitted. As such, In summary, we we do not understand the basis for the Staff's comment. believe that our approach to this transition reload and safety analysis was Upon more recent reflection, we continue to believe our proper and timely. For your information, prior to the recent shutdown, RCS approach was prudent. 356,280 gpm at 100 percent power, with a measurement uncertainty of - flow was 13,000 gpm. This computes to 343,280 gpm, the minimum guaranteed RCS flow rate. > NRC Concern fire protection licensing reviews continued to be a . Millstone Unit No. 2 weakness. The two key difficulties were postfire ventilation requirements and restoration of electrical power. NNECO Responie 1. Ventilation: , - . , . - - - - . . - - . . , - - - - .-,-y . . - , .v.,.. . , . . - . . . , ~ . - - . -

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. ' . i U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page 17 November 27, 1989 ! l \\

a. Contrary to the Staff's statement that "the licensee's post- . i tion . . . changed substantially" and ' subsequent NRC and licensee review indicated a need for temporary post fire ventilation in t several key safety related plant locations," NNECO's position has i not changed -no temporary ventilation was or is required. This is . specifically stated in our submittals, and most recently in our

September 27, 1989 submittal regarding information requested by the < NRC on August 29, 1989. For all required areas, existing ventila- tion remains either . intact and functioning, or its loss will not

impact safe shutdown of the plant.

b. The NRC Staff letter of May 18, 1989 indicated thtt additional licensee evaluation was required concerning postfire ventilation in additional areas identified by the Staff. In addition, the NRC

requested more detailed information from what had been requested and ? included in our April 18,:1989 submittal, for both the previously identified areas of concern and the additional areas now identified by the Staff. In the SALP report, regarding this, the NRC found our submittals to be untimely and incomplete, , NU submitted the requested information in a letter dated July 10, 1989, within the required 45 days from receipt as specified in the NRC's May 18, 1989 letter. While it is true that a number of areas addressed in this submittal were not previously identified to the Staff, all our evaluations continued to support our original posi- tion that no temporary or interim ventilation would be required for any fire scenario. In addition, every NRC telephone request was verbally responded to in usually under a week, and all written responses with a specified due date were either submitted on or before that date. The one exception to this was our written re- sponse of April 18, 1989. The NRC verbally requested this infor-

mation during a telephone conference on January 24, 1989, and although no specific cue date was then established, the submittal , took approximately 2% months and not the expected 'few" weeks. It , is important to note that this information was verbally provided to ' the NRC in December 1988 during a telephone conference, and at that , time the NRC was satisfied with our verbal response. It was not until the January 24, 1989 telephone conference that the - NRC re- quested that this information be formally provided in a written submittal. In addition, the exact wording and content of this - requested submittal was discussed verbally during this telephone ' conference, and our April 18, 1989 submittal reflected what had been , verbally agreed upon. The NRC's characterization of " untimely and incomplete * does not appear to be appropriate in light of the above. 2. Restoration of Power Contrary to the NRC's statement that "the licensee was initially unresponsive to the NRC Staff's attempt to resolve issues associated

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t , U.S. Nuclear Regulatory Commission j B13411/ Attachment A/Page 18 ' November 27, 1989 with post-fire provision of power from Millstone 1 to Millstone 2" and that "the licensee appeared unwilling to demonstrate adequacy via a walkdown . . . ,' NNECO's belief is that we were never unre- sponsive to the NRC's requests for a walkdown or to discuss this issue. We recognized then, and reiterate now, that the. Staff has the right to ask us to demonstrate the efficacy- of an approved i procedure at any time, provided such demonstration can be done i safely. NNECO's position, as documented in several submittals to ! the NRC Staff, was that our analysis can support the loss of AC power for up to four hours after initiation of a fire. This time- t ! interval could include extinguishing the fire, stabilizing the ! plant, and the physical connection of the plant to Millstone Unit No. I power supplies. In repeated discussions with the Staff, the Staff focused only on the time required to accomplish the physical '; connection of Millstone Unit No. I's on site power sources and showed no apparent interest in the other factors. The Staff stated , l that four hours was too long for the plant to be without AC power notwithstanding the results of our analysis. ' During a telephone conference on September 29, 1988, as well as during several previous telephone conversations, NNECO made it clear

that we had no reservation about validating the four hours via a walkdown. Our only concern was that the walkdown be realistic and , include a walkdown of all evolutions required for this worst case 7

fire scenario, and not just the actions required to perform the

l physical cross-connect of power supplies. NNECO and the NRC had i difficulty reaching a consensus on this point and on the acceptabil- e ' ity of the total four hour time interval. The NRC chose to charac- i terize this as " unwilling and unresponsive.' Subsequently, on October 7,1988 the NRC Staff observed a walkdown of this evolution

including the actions and assumptions defined by NNECO as required to be performed in addition to the physical cross connection of , power su] plies, and verified that all required actions could be ,. , performec in under four hours. As of this writing, the Staff has not yet issued an SER on this . matter, apparently in part due to this four hour interval issue l Also, as of this writing, we are unaware of any unanswered NRC questions associated with an SER on Appendix R for Millstone Unit 3 No. 2. We do observe that the NRC had previously issued an SER for - Millstone Unit No.1, concluding that the four-hour cross-connect > duration is safe and acceptable (see the Millstone Unit No.1, i Appendix R SER, dated April 14, 1988). Further, in a conversation v with the Staff on November 21, 1989, the Staff indicated that a favorable SER, including approval of the four hour interval, should

be issued shortly.

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813411/ Attachment A/Page 19 ' November 27, 1989 , t ! Chronoloav of Events - Anoendix R Review

May 29, 1987 NU submitted the 10CFR50, Appendix R Compliance Review to l the NRC. , July 13 17, 1987 NRC conducted Appendix R audit of Millstone Unit No. 2. ! September 25, 1987 NRC issued the inspection report from the July 13-17, 1987- , team inspection. The report cited that NRR would be ! reviewing the May 29, 1987 shutdown analysis. Between September NRC project manager relayed several -verbal questions I 1987 and February concerning the Compliance Review from the NRC technical- ' 1988 reviewer. All questions during this interval were verbal- ly answered to the reviewer's satisfaction. The project - manager requested that NNECO representatives and the e technical reviewer continue to interface directly on all i related questions with the exception of one issue, namely ' ' the potential minimum four-hour delay in restoring AC " power. (In a real event, power would be restored as soon as practical. The four-hour interval is relevant in that , it defines the maximum time available to perform the task , and still achieve safe shutdown.) Additionally, after direct contact between the technical reviewer and NNECO - was established, the technical reviewer would telephone 4 almost weekly with additional questions. These interfaces continued with all questions being answered usually within a week of receipt. March 23, 1988 in an effort to finally resolve the continuing influx of NRC questions, a conferer.ce call was held between NNECO and the NRC. During this call, NNECO responded to 23 , l questions, of which the NRC requested that additional

information on four (4) of them be provided in a formal

submittal. This was the first requested submittal by the NRC Staff. ' April 22, 1988 NU submitted the information requested by the NRC from the March 23, 1988 telephone conference. . May 1988 to NRC questions continued to be telephoned in on nearly a , October 1988 weekly schedule. At this time, the major questions were

! concerned with the plant's ability to deal with a four- l hour loss of AC power. The NRC did not agree with this

concept and requested that NNECO demonstrate that power could be restored in substantially less time. The NRC t l stated at this time that the major concern was the ability

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O -Q . . U.S. Nuclear Regulatory Commission B13411/ Attachment A/Page 20 November 27, 1989 to maintain RCS inventory without charging capability during this interval. NNECO maintained that we had demonstrated that a four hour delay would be acceptable and that RCS inventory would be maintained. The NRC maintained that this position was unacceptable, unambigu- ous technical reasons were not provided, and insisted that NNECO reduce the four hour interval to "something around one hour." At this point, this issue was the only out- standing issue to our knowledge. October 7, 1988 The NRC observed a walkdown of the evolutions required to restore AC power after a worst-case fire scenario. December 1988 The NRC verbally requested a clarification of the Compli- ance Review section on ventilation. Specifically, the NRC requested clarification of what the evaluation entailed, what equipment and areas were actually evaluated, and if all areas were within satisfactory bounds. These ques- tions were answered verbally to the NRC's satisfaction and no written response was requested. January 24, 1989 The NRC verbally requested that NU formally submit .the information previously provided verbally in December and stated that this was the .last remaining issue. The NRC also stated that the four-hour power question was still open and that the NRC was still reviewing this issue. No submittal date was established; however, a time frame of a "few" weeks was deemed acceptable.

January - The NRC requested information letter was drafted and was February 1989 essentially ready to be submitted. However, a separate I evaluation was ongoing on a new issue regarding contain- ment habitability. Since the outcome of this evaluation could affect the response to the NRC, NNECO elected not to , submit the letter until this issue was resolved. ' t February 17, 1989 NNECO submitted information voluntarily on the issue of l the RCP seals, which was one stated.NRC concern associated with the four-hour interval issue. l , l April 18, 1989 NNECO submitted the information the NRC had requested on January 24, 1989. This information also contained the ' resolution to the containment habitability issue. .It was submitted approximately 24 months after the initial request and not within the expected "few" weeks. It is important to note that the format and' content of this information was specifically discussed with the technical reviewer, with the exception of the containment L I- , . - - - - ,

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U.S. Nuclear Regulatory Commission ' B13411/ Attachment A/Page 21 November 27, 1989 l l I habitability issue, and he had agreed that this was the specific information he required. ' April - May 1989 A number of telephone conversations with the NRC were ' held. The NRC now required additional information from what was provided in our April 18, 1989. submittal. ! Because of our interest in getting a clear understanding of Staff needs. NNECO requested the NRC to document the

questions in a written letter. { May 18, 1989 The NRC issued a Request f'or Additional Information as was discussed in previous telephone conversations. The agreed ! upon due date of the required response was 45 days from ' receipt, which was July 10, 1989. j ' July 10, 1989 NU submitted the required response to the NRC request of May 18, 1989. This submittal provided all the information requested. August 29, 1989 The NRC requested still further specific information on . our July 10, 1989 letter for four plant areas during a e telephone call. it was agreed this information would be ! aubmitted by the end of September 1989. September 27, 1989 NU submitted the information requested by the NRC on . August 29, 1989. November 21, 1989 NNECO received a telephone call from the NRC project

manager asking to see specific responses to LER's submit- ted in regard to loss of RCP seal cooling events in 1985 for Millstone Unit No. 2. During this call, the NRC ' ! stated that the Appendix R review was completed with only I a few items needing verification and that the Staff had. l decided to acce >t the 4-hour interval for power restora- l tion as proposec by NNECO. The NRC Stated that an accept- ' able SER would soon be issued. . NRC Concern

An emergency request for an amendment for the operation of the spent fuel pool ' , t cooling system under limiting conditions during the refueling for Cycle 10 operation failed the emergency provisions criteria of 10CFR50.91 in that the application was not timely. I NNECO Response ' On February 22, 1989, NNECO submitted to the Staff, pursuant to 10CFR50.90 and , I 91, a proposed emergency change to the Technical Specifications of Millstone

Unit No. 2. Specifically, the change requested Staff approval to add a , ! l ' l I t + , . _ .., ,. . . . . . . - . .. _,__..m,.,. ,-- -.

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! , ' . U.S. Nuclear Regulatory Commission ' B13411/ Attachment A/Page 22 November 27, 1989 , I footnote to the Limiting Condition for Operation (LCO) of Specifica- tion 3.9.3.2 which would have required, for Cycle 9 refueling only and with the spent fuel pool temperature being maintained below 140'F, only one train of spent fuel pool cooling being OPERABLE provided shutdown cooling is avail- able within 6 hours for spent fuel pool cooling. In discussions on the afternoon of February 23, NNECO-informed the Staff that changing conditions involving the refueling schedule had obviated this pro- posed change. NNECO formally withdraw the emergency request in a letter dated February 28, 1989. NNECO notes that the Staff expressed no concern over the technical validity of , the proposed request, only the exigent circumstances issue governed by 10CFR50.91. NNECO acknowledges that there was insufficient written justifica- tion of exigent circumstances in the February 22 submittal. Following a conference call with the Staff, NNECO commenced preparation of additional information to document the presence of exigent conditions. Part of the justification involved the then recently issued Generic Letter 8817 (Loss of , Decay Heat Removal) and its associated impact on acceptable configurations'for core and spent fuel pool cooling. This was the first instance of nonpower operation since the issuance of Amendment #114, which imposed the minimum 504 hours of decay time, and Generic Letter 8817. During our conference call, the Staff by no means assured us that the amendment would be issued, but they expressed a willingness to evaluate a more detailed demonstration of compliance with 50.91. At this time, NNECO was reasonably confident that exigent conditions could be demonstrated. Shortly after the conference call, in light of increasing complications and schedular _ delays regarding the ongoing outage, NNECO opted to not submit the supplemental letter and subse- quently withdrew the amendment, NNECO reiterates that the amendment request was withdrawn, and not denied. , l because the motivation to process it no longer existed, and not because we ! were not prepared to justify the presence of exigent circumstances, ! , i }}