ML20057A877
| ML20057A877 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/08/1993 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9309160118 | |
| Download: ML20057A877 (2) | |
See also: IR 05000336/1993081
Text
..-
.
.
..
.
__
.
.
-
-
-
~
, -
, . .
-
.
.
.
.
8 1993
-
Docket No. 50-336
Mr. John F. Opeka
Executive Vice President - Nuclear
Northeast Nuclear Energy Company
P. O. Box 270
llartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT: INSPECTION NO. 50-336/93-81
This letter refers to your July 26,1993, correspondence, in response to our June 25,1993,
letter.
4
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
M s:iura si n d by1
Jucluo l'.4 Dm',
I
Jacque P. Durr, Chief
Engineering Branch
Division of Reactor Safety
G:CHEUNG.RL
OFFICIAL RECORD COPY
16008.L
p
9309160118 930908
-
I(
ADOCK 05000336
t
G
a
.
.
.w,-
N
_
_
_,
- - . -
_
-
--
.
.
1
,
8 1993
'
.
.
-
.
Mr.' John F. Opeka
2
cc:
W. D. Romberg, Vice President - Nuclear, Operations Services
,
i
S. E. Scace, Vice President, Millstone Station
J. S. Keenan, Nuclear Unit Director
R. M. Kacich, Director, Nuclear Licensing
G. H. Bouchard, Director of Quality Services
Gerald Garfield, Esquire
Nicholas Reynolds, Esquire
K. Abraham, PAO (2)
Public Document Room (PDR)
4
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut SLO
bec w/ encl:
Region I Docket Room (with concurrences)
bec w/enct (VIA E-MAIL):
V. McCree, OEDO
J. Stolz, NRR/PD I-4
e /
-
)
g
y
yi
RI:DRS
131:-
RI:DRS
Cheung
itu and
Durr
08//M)3
08/3/93
07///93
l
G:CHEUNG.RL
OFFICIAL RECORD COPY
i
.
.
,
}
NORTHEAST UTILITIEJ
-
o n.,.i Omcu . s,io,n si,.. . e.,iin. Conn.ciicoi
,
1
.[N$'57$I' ~#~$
P.O. BOX 270
aC,,YuUcC.,
HARTFORo, CONNECTICUT 06141-0270
'
J
.o.w a,%ca.ae.n e co
.
(203) 665-5000
.
July 26, 1993
Docket No. 50-336
B14555
U.S. Nuclear Regulatory Commission
Attention:
Document Control Desk
Washington, DC 20555
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2
Inspection Report No. 50-336/93-81
Reolv to Notice of Violation
In a letter dated June 25, 1993,'" the NRC Staff transmitted to Northeast
Nuclear Energy Company (NNECO) a Notice of Violation (N0V) relating to
Inspection Report No. 50-336/93-81.
The report discussed the results of an
electrical distribution system functional inspection conducted during the
period between March 15 and April
2,
1993.
Based on the results of the
Staff's inspection, one apparent violation of NRC requirements was identified.
Attachment I to this letter provides NNEC0's reply to the violation, on behalf
of Millstone Unit No. 2, in accordance with the requirements of 10CFR2.201,
and the instructions contained within the inspection report.
1
Additionally, the NRC letter requested that NNEC0 provide, in writing, a
chedule for the resolution of the 13 unresolved items identified in the
s
subject inspection report.
This document is currently being prepared and will
be submitted by August 24, 1993, in accordance with the requirement denoted in
the inspection report.
We trust that you will find this information satisfactory, and we remain
available to answer any questions you may have.
Very truly yours,
NORTHEAST NUCLEAR ENERGY. COMPANY
& ekw
-
J.FbWeka
D
Executive Vice President
cc:
(See Page 2)
_
(1)
M. W. Hodges letter to J. F. Opeka, " Notice of Violation, NRC Inspection
Report No. 50-336/93-81," dated June 25, 1993.
!
oS3422 REV,4-68
h
- ~
~ , , .
.
.
.
.
'
.
,
.
,
.
t
U. S. Nuclear Regulatory Commission
B14555/Page 2
July 26, 1993
)
.
cc:
T. T. Martin, Region I Administrator
G. S. Vissing, NRC Project Manager, Millstone Unit No. 2
P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.
1, 2,
and 3
i
l
1
!
l
l
l
1
,
.
..
.
,.
.
.
.
'
Docket No. 50-336
-
,
B14555
Attachment 1
Millstone Nuclear Power Station, Unit No. 2
Inspection Report 50-336/93-81
Reply to Notice of Violation
>
h
i
'
s
i
.l
...y 1993
i
J
.
.
,
.
e
.
.
Millstone Nuclear Power Station Unit No. 2
-
.
Inspection Report 50-336/93-81
Reply to Notice of Violation
Restatement of Violation
l
During an NRC inspection conducted on March 15 through April
2,
1993, a
violation of NRC requirements was identified.
In accordance with the " General
l
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C, the violation is listed below:
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B,
j
Criterion XVI, Corrective Action, requires measures shall be established
to assure that conditions adverse to quality,
such as failures,
malfunctions,
deficiencies,
deviations,
defective
material
and
equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures
shall
assure that the cause of the condition is determined and
j
corrective action taken to preclude repetition.
4
Contrary to the above, as of March 17, 1993, the .neasures to assure
conditions adverse to quality were not taken to promptly identify and
correct deficiencies as evidenced by the following: (1) NRC natification
on August 29, 1984, and February 24, 1986, to avoid the potential for
rendering
all
emergency
diesel
generators
(EDG)
unavailable
by
paralleling one or more EDGs to the grid while the remaining EDG(s) were
inoperable, and (2) on January 7,1987, the licensee had experienced a
situation where both EDGs were rendered inoperable for 56 minutes due to
an event which occurred while the
"A" EDG was declared inoperable and
the "B" EDG was paralleled with the grid.
In spite of these notices and
the previous failure, the licensee continued to load one EDG in parallel
with the grid during testing while the other EDG was declared
In addition, on March 17, 1993, while the plant was at full
'
power, both EDGs were loadr:
'n parallel with the grid for more than one
hour.
This is a Severity Level IV vio.ation (Supplement 1).
1.
Reason for the Violation
In response to Information Notice No. 84-69 issued August 29, 1984,
NNECO evaluated Millstone Unit No. 2's practice of loading one EDG in
parallel with the grid while the other EDG was declared inoperable.
This evaluation almost entirely focused on the issue that the EDGs would
not be paralleled with the grid during adverse weather conditions that
could jeopardize EDG paralleling operations.
The potential risks under
,
these conditions were recognized and acknowledged.
However,
the
!
counter concern was the potential risk cited by the engine vendor of oil
fouling to the engine from unloaded runs.
This vendor concern, coupled
with the Millstone Unit No. 2 Technical Specification requirement that
the EDG be paralleled to the grid for a 60 minute loaded run each month
led NNECO to conclude that performing loaded runs was appropriate,
i
.
.
i
'e
-
.
.
.
- independent of the operability status of the second EDG.
On this basis,
.
past practice was considered appropriate until the recent electrical
distribution system functional inspection (EDSFI).
2.
Corrective Steos That Have Been Taken and Results Achieved
'
In response to the violation, a lessons learned presentation was made to
the Millstone Unit No. 2 Engineering Department on July 16, 1993.
The
presentation emphasized the importance of Information Notices, and of
giving full consideration to the information presented therein.
This
presentation included a discussion of the specific violation received on
paralleling the EDGs with the grid, and the failure to change the
practice.
The presentation was made to increase the awareness of those
individuals who
typically
review
Information Notices
and provide
recommendations regarding the appropriate actions to take to resolve the
condition described in the Information Notice.
As stated in NRC Combined Inspection Report 50-245/93-10, 50-336/93-06,
and 50-423/93-07,"' the tracking and distribution of NRC Information
Notices had been loosely controlled, since one specific individual was
not responsible for that area. To improve performance in this area, the
responsibility of tracking NRC Information Notices was transferred from
the Nuclear Operations Department to Nuclear Licensing.
Additionally,
one
individual
was
assigned
the
specific
task of tracking NRC
Information Notices. The NRC Combined Inspection Report stated: "the
inspector determined that the revised Information Notice tracking system
!
should improve performance since positive administrative controls have
now been placed on Information Notice distribution.
Therefore, this
issue is closed."
NNEC0 believes that this action is applicable to
resolution of this violation, since the NRC Information Notice of note
was issued prior to 1993.
The Millstone Unit No.
2 condition,
regarding the potential
of
paralleling the operable EDG with the offsite electrical power grid
while the other EDG was inoperable, was reported under Licensee Event
Report 93-007-00 on April 28, 1993. <2'
To resolve this condition,
changes to operating procedure OP 2346A, " Emergency Diesel Generator,"
,
and the associated surveillance procedures SP 2613A, " Diesel Generator
Operability Test,
Facility
1,"
and
26138,
" Diesel
Generator
Operability Test,
facility
2,"
have been implemented to prohibit
paralleling the only operable EDG to the offsite power grid.
These
changes were implemented following discussions with the diesel engine
vendor which demonstrated that unloaded EDG runs can be performed on a
limited basis withoutrdegrading EDG operability.
(1)
A. R. Blough letter to J. F. Opeka, " Millstone Combined Inspection 50-
245/93-10; 50-336/93-06; 50-423/93-07," dated April 30, 1993.
(2)
S.
E. Scace letter to U. S. Nuclear Regulatory Commission, " Facility
Operating License No. DPR-65, Docket No. 50-336, Licensee Event Report
93-007-00," dated April 28, 1993.
a
.
.
t
.
.
.
-
3.
' Corrective Steps That Will Be Taken to Avoid Further Violatio_n
Northeast Utilities Service Company's Nuclear Safety Engineering Group
(NSE) will perform a technical evaluation of a sample of the Millstone
Unit Nos.
1,
2,
and 3 and Haddam Neck Plant dispositions of NRC
Information Notices to ensure dispositions have addressed the issues in
a complete and thorough manner.
The technical evaluation will be
completed by November 15, 1993. Actions will be taken commensurate with
the findings.
A lessons learned presentation, similar to that discussed in item 2
above, will be made to the Engineering Departments of Millstone Unit
Nos. I and 3 by September 30, 1993.
A license amendment will be requested to propose a revision to the
action statements of Millstone Unit No. 2 Technical Specification 3.8.1.1.
The proposed changes will eliminate the requirement that the
operable EDG must be started when the other EDG becomes inoperable for
preplanned preventative maintenance or testing.
The proposed license
amendment will be submitted by December 15, 199".
4.
Date When Full Compliance Will Be Achieved
NNECO believes Millstone Unit No. 2 fully complies with Criterion XVI of
Appendix B of 10CFR50.
As stated in item 3,
NSE will perform a
technical evaluation of a sample of the Millstone Unit Nos.1, 2, and 3,
and Haddam Neck dispositions of NRC Information Notices to ensure
dispositions have addressed the issues in a complete and thorough
manner.
5.
Generic Imolications
As stated in sections 3 and 4, a technical evaluation of a sample of -
Millstone Unit Nos.1, 2, and 3, and the Haddam Neck Plant dispositions
to NRC Information Notices will be conducted.
Alsc, NNECO is reviewing the condition regarding the potential of
paralleling an operable EDG with the offsite electrical power grid while
the other EDG is inoperable for applicability to Millstone Unit Nos.1
1
and 3 and the Haddam Neck Plant.
Actions will be taken commensurate
I
with findings.
On July 2,
1993, a Hillstone Unit No. 3 Operations Department Night
Order was issued to prohibit paralleling the operable EDG with the
offsite electrical power grid while the other EDG is inoperable.
An
engineering evaluation was initiated on July 14, 1993, to determine
whether Millstone Unit No. 3 is susceptible to a condition similar to
the Millstone Unit No. 2 condition.
If the Millstone Unit No. 3
situation is determined to be reportable, NNEC0 will report this via
separate correspondence.
'
i
J
,