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Forwards Insp Repts 50-245/96-06,50-336/96-06 & 50-423/96-06 on 960627-0826 & Nov.Violations of Concern Because of Repetitive Nature & Another Example of NRC Concern W/Overall Corrective Action Program
	ML20128M114
Person / Time
Site:	Millstone
Issue date:	10/09/1996
From:	Lanning W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T; NORTHEAST UTILITIES SERVICE CO.
Shared Package
ML20128M120	List: ML20128M114; ML20128M194; ML20128M201;
References
	EA-96-146, EA-96-331, EA-96-332, EA-96-333, EA-96-350, EA-96-351, NUDOCS 9610160006
	Download: ML20128M114 (4)
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October 9,1996

EA Nos.96-146

Mr. Ted C. Feigenbaum

Executive Vice President and

Chief Nuclear Officer

Northeast Utilities Service Company

c/o Mr. Terry L. Harpster

P.O. Box 128

Waterford, Connecticut 06385

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Dear Mr. Feigenbaum:

SUBJECT: NRC COMBINED INSPECTION 50-245/96-06;50-336/96-06;423/96-06

Dear Mr. Feigenbaum:

On August 26,1996, the NRC completed an inspection at your Millstone Units 1,2 & 3

reactor facilities. The enclosed report presents the results of that inspection.

During the eight weeks covered by this inspection period, your conduct of activities at the

Millstone facilities was generally characterized by safety-conscious operations, sound

engineering and maintenance practices, and careful radiological work controls. We are

concerned, however, about the one cited violation and six apparent violations of NRC

requirements that were identified.

The results from the Joint Utility Management Assessment (JUMA) audit are of particular

concern to the NRC. The JUMA audit generally concluded that the Quality Assurance

Program was ineffective because the O.A organization lacked support by NU executive line

management. Quality Assurance effectiveness has been identified in the NRC restart plan

as an issue to be addressed before restart.

Based on the results of Inspection Report 96-05, the NRC has determined that a violation

of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation

and the details of the circumstances surrounding it are described in the referenced

inspection report. The violation deals with the failure to implement effective corrective 1

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actions to ensure safeguards information was properly controlled. The violation is of

.150044 l

9610160006 961009 01

PDR ADOCK 05000245 ,

G PDR

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Mr. Ted C. Feigenbaum 2

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concern because of its repetitive nature, and it is another examplo of the NRC's concern

with your overall corrective action program.

You are required to respond to this letter and should follow the instructions specified in the ,

enclosed Notice when preparing your response. The NRC will use your response, in part, I

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

One apparent violation at Unit 1, three ..pparent violations at Unit 2 and two apparent )

violations at Unit 3 were identified and are being considered for escalated enforcement

action in accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions" (Enforcement Policy), NUREG-1600.

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The apparent violation at Unit 1 involved the loss of physical control of the i

Nonconformance Reporting (NCR) process and the failure to properly utilize the NCR

process in accordance with a procedure written to comply with 10 CFR 50 Appendix B

Criterion XV. The vulnerability associated with the mis-application of the NCR process is l

that it circumvents other plant processes, which would provide the controls necessary for i

prompt operability determinations, and to ensure all degraded and nonconforming

conditions are tracked and corrected prior to restoring systems to an operable status. l

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The first apparent violation at Unit 2 involveo the control of reactor shutdown margin

during plant cooldowns, and the failure to conduct safety evaluations to support changes

in the Final Safety Analysis Report description of these reactivity controls. Additionally,

your practice of not verifying the concentration of boric acid intended for injection into the

reactor coolant system (RCS) does not provide an acceptable set of barriers to preclude

inadvertent dilution of the RCS. Therefore, when you address the apparent violation

regarding shutdown margin, please discuss why additional barriers, such as sampling, are

not needed to assure the probability of this analyzed accident remains sufficiently remote.

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The second apparent violation involved a potential common mode failure of emergency

core cooling systems in the recirculation mode of accident response. Discrepancies in the

installation and repair of the containment sump screens could allow larger debris than

analyzed to clog and degrade the ECCS function.

The third apparent violation at Unit 2 involved the lack of environmental qualification for

seven containment isolation valves that must be re-opened during the post-accident phase

of an accident. This issue is of particular concern because qualifications of four of the

seven valves were the subject of specific NRC review in 1988, and the safety function for

these valves was not identified and corrected at that time. Further, the NRC identified

other weaknesses in the implementation of the environmental qualification program that

raise questions regarding the ability of EEQ components to perform their safety function.

Therefore, NRC considers the completion of outstanding EEQ and high energy line break

program activities, and the revalidation of the qualification of affected components to be a

plant start-up issue.

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1 Mr. Ted C. Feigenbaum 3

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, The first apparent violation at Unit 3 relates to a deficiency in the design of the

recirculation spray and quench spray system piping supports, for which the loading

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analysis had not apprcpriately considered accident temperatures. This deficiency was

docurnented since at least 1993, but was not adequately addressed until an adverse

condition report was generated in 1996. The second apparent violation at Unit 3 involves

j the failure to correctly translate the technical requirements of the ASME Code, relating to

the use of replacement stud materialin the chemical volume and control system letdown

heat exchanger, into design documents. The latter issue also entailed the premature

closure of a nonconformance report, issued to track the letdown heat exchanger leakage.

i Thus, for both of these apparent violations, plant records document evidence that the

, identified technical problems could have been addressed with more rigorous corrective

actions.

No Notice of Violation is presently being issued for the above apparent violations. Please

be advised that the number and characterization of apparent violations described in the

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enclosed inspection report may change as a result of further NRC review. You will be

l informed by separate correspondence of the results of our deliberations on this matter. No

response regarding the apparent violations is required at this time; however, corrective

actions deemed appropriate should not be delayed.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures will be placed in the NRC Public Document Room (PDR).

l Sincerely,

Original Signed By:

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Wayne D. Lanning, Director

Millstone Oversight Team

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Docket Nos. 50-245

50-336

50-423

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! Enclosures: NRC Combined inspection Report

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50-245/96-06;50-336/96-06; 50-423/96-06

cc w/ encl:

, P. Richardson, Nuclear Unit 2 Director

< M. H. Brothers, Nuclear Unit 3 Director

L. M. Cuoco, Esquire

W. J. Riffer, Nuclear Unit 1 Director

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F. C. Rothen, Vice President, Maintenance Services

1 V. Juliano, Waterford Library

, J. Buckingham, Department of Public Utility Control

S. B. Comley, We The People

State of Connecticut SLO Designee

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Mr. Ted C. Feigenbaum 4

Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC

NRC Resident inspector

D. Screnci, PAO

C. O'Daniell, DRP

Distribution w/enci (VIA E-MAIL):

J. Andersen, NRR

W. Dean, OEDO

P. McKee, NRR/PD l-4

V. Rooney, PM, NRR

D. Mcdonald, PM, NRR

R. Correia, NRR

R. Frahm, Jr., NRR

Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 6\MSIR9606.123 l

Ta receive e copy of this document, Indicate in the boa: 'C' = Copy without attachment / enclosure "E" - Copy with ettachment/ enclosure 'N' = No copy

l OFFICE Rl/DRP l Rl/Oftp y l / l l l j

JDurr WLaFnirig

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lNAME

lDATE 10/08/96 10/g/96 10/ /96 10/ /96 10/ /96

OFFICIAL RECORD COPY

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ML20128M114

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