ML20135C974
| ML20135C974 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/03/1996 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20135C977 | List: |
| References | |
| EA-96-352, NUDOCS 9612090183 | |
| Download: ML20135C974 (5) | |
See also: IR 05000245/1996008
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December 3,1996
EA 96-352
Mr. Bruce D. Kenyon
President and Chief Executive Officer
Northeast Nuclear Energy Company
c/o Terry Harpster
P. O. Box 128
Waterford, Connecticut 06385-0128
Dear Mr. Kenyon:
SUBJECT: NRC COMBINED INSPECTION 50-245/96-08; 50-336/96-08; 423/96-08 and
On October 25,1996, the NRC completed an inspection at your Millstone 1,2 & 3 reactor
facilities. The enclosed report presents the results of that inspection.
During the two-month period covered by this inspection, the performance of your staff at
the Millstone facilities was generally characterized by a deliberate approach to assuring the
proper consideration of shutdown risk in the conduct of operational activities, and by
significant management attention to recovery planning and reorganization in each unit.
However, we remain concerned about the continuing violations of NRC requirements. At
Unit 2, we identified one violation and six apparent violations. In addition, three apparent
violations were identified at Unit 1, and are being considered for escalated enforcement
actions in accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions" (Enforcement Policy), NUREG-1600. In addition, your continued
failures to fulfill commitments made to the NRC are of particular concern. We are
disappointed to find that corrective actions were not completed which further erodes our
confidence in your organization and is indicative of management weaknesses that require
irnmediate attention.
One of the apparent violations at Unit 2 is inadequate corrective actions, which had three
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examples. As stated previously in NRC Combined Inspection Report 96-04 for all three
units, the corrective action program had not been effective in correcting identified
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deficiencies; therefore, this program must be demonstrated effective before the restart of
any of the Millstone units. The apparent violation illustrates that Unit 2 has not yet
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attained a level of performance to show that the corrective action program is improving.
A fourth apparent violation, which occurred at Unit 2, was a technical specification
violation due to both trains of containment air hydrogen monitors being inoperable. The
fifth apparent violation was a Unit 2 concern in which the NRC found that due to an
9612090183 961203
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Mr. Bruce D. Kenyon
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inadequate review of the steam generator replacement modification, it was not identified
that the design basis and licensing basis time periods for placing the hydrogen monitors in
service and taking a containment atmosphere sample could not be met. The sixth apparent
violation at Unit 2 is a concern in which the NRC found that the Final Safety Analysis
Report had not been updated to reflect the licensing basis regarding the amount of time
following an accident that the hydrogen monitors would be placed in service.
A violation at Unit 2 involved the failure to adequately perform the monthly technical
specification required valve line up of containment isolation valves because not all the
required valves were specified in the procedure and operators had been documenting as
"not applicable" those valves located inside containment. This violation is cited in the
enclosed Notice of Violation, and the circumstances surrounding the violation are described
in detail in the enclosed report. Please note that you are required to respond to this letter
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and should follow the instructions specified in the enclosed Notice when preparing your
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response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
The first apparent violation at Unit 1 involved the failure to provide a troubleshooting plan
and troubleshooting guidelines with the work order package associated with the repair of a
travelling screen differential pressure transmitter. The second apparent violation at Unit 1
involved the failure to maintain the standby gas treatment system operable under all
conditions. Specifically, if actuation of the standby gas treatment system had occurred
during the time period that the outside ambient temperature was less than 45 F,
coincident with a loss of normal power and a single failure in one train, the required
negative pressure may not have been maintained throughout the secondary containment.
The third apparent violation at Unit 1 concerned a corrective action issue involving the
failure to implement the design modifications necessary to bring the control rod drive
system into design compliance within the NRC specified time period.
Accordingly, no Notice of Violation is presently being issued for the nine apparent
violations. Please be advised that the number and characterization of apparent violations
described in the enclosed inspection report may change as a result of further NRC review.
You will be 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.
Following a review of your plans for entering Mode 6 at Unit 2, the NRC had concerns
regarding your intent to perforn: a core offload using systems which, although operable,
had known discrepancies that were contrary to the current operating license. Although no
violations of NRC requirements were identified, this is considered to be a significant
weakness in light of the recent attention given to compliance with the current design and
licensing basis.
Although no violations were cited against the Millstone Unit 3 docket, two inspection
issues discussed in this report merit additional licensee management attention. The first
issue involved a concern affecting all three Millstone units, i.e., the identification of fuses
with cracked ferrules in the safety-related warehouse stock supply, initial licensee actions
to address this concern were inadequate until the Nuclear Oversight Organization
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Mr. Bruce D. Kenyon
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conducted follow up activities and identified concerns. Even then, the licensee
investigation to ensure that the suspect fuses were capable of performing their safety
function was implemented without evidence of a timely review of installed fuse conditions.
The second issue related to the numerous inservice testing program deficiencies
documented in licensee event reports (LER) 50-423/96-21 and 96-24. Similar to the
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problem in the handling of the cracked fuse ferrules, licensee corrective actions in
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addressing the programmatic concerns documented in the applicable adverse condition
report were found to be less than comprehensive. Given the programmatic nature of the
identified inservice testing program problems, as well as the lack of specificity provided in
LER 50-423/96-21, we request that you inform us in writing within 60 days of the receipt
of this letter of your plans to address the inservice testing program deficiencies. This
response should include your position on the need for the development of a more
comprehensive approach to corrective action controls for such reportable programmatic
concerns.
Finally we have determined that your fire protection program lacks appropriate direction for
resolving and prioritizing identified issues. Quality assurance audits of fire protection were
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limited in scope, sometimes incorrectly categorized the significance of findings, and failed
to followup on previously identified issues. Your staff failed a fire drill during the
inspection, requiring you to conduct a remedial drill. Given the large number of design
deficiencies that could affect the safe shutdown capability of safety systems, e.g., cable
separations, and fire mitigation weaknesses, we believe that your fire protection program
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needs more attention. Therefore, we will need to meet with you to discuss your resolution
of program oversight concerns, including Appendix R issues, prior to any unit start-up.
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).
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Sincerely,
ORIGINAL SIGNED BY:
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Wayne D. Lanning
Deputy Director of Inspections
Special Projects Office
Docket Nos. 50-245
50-336
50-423
Enclosures:
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NRC Combined Inspection Report 50-245/96-08;50-336/96-08;50-423/96-08
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Mr. Bruce D. Kenyon
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cc w/ encl:
T. C. Feigenbaum, Executive Vice President - Chief Nuclear Officer
J. McElwain, Unit 1 Recovery Officer
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M. Bowling, Jr., Unit 2 Recovery Officer
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J. Cowan, Unit 3 Recovery Officer
D. M. Goebel, Vice President, Nuclear Oversight
J. K. Thayer, Recovery Officer, Nuclear Engineering and Support
P. D. Hinnenkamp, Director, Unit Operations
H. F. Haynes, Director, Nuclear Training
P. M. Richardson, Nuclear Unit Director, Unit 2
M. H. Brothers, Nuclear Unit Director, Unit 3
J. F. Smith, Manager, Operator Training
F. C. Rothen, Vice President, Work Services
P. Olson, General Accounting Office
L. M. Cuoco, Esquire
J. R. Egan, Esquire
V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Control
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S. B. Comley, We The People
State of Connecticut SLO Designee
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Mr. Bruce D. Kenyon
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Distribution w/ encl:
Region i Docket Room (with concurrences)
W. Lanning, Deputy Director of Inspections, SPO, Rl
M. Kalamon, SPO, RI
NRC Resident inspector
Nuclear Safety Information Center (NSIC)
PUBLIC
D. Screnci, PAO
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Distribution w/enci (VIA E-MAIL):
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W. Travers, SPO, NRR
D. Screnci, PAO
N. Sheehan, Field-Public Affairs Officer, RI
W. Dean, OEDO
P. McKee, Director, Deputy Director of Licensing, SPO, NRR
G. Imbro, Deputy Director of ICAVP, Oversight, SPO, NRR
L. Plisco, Chief, SPO, NRR
D. Mcdonald, SPM, SPO, NRR
M. Callahan, OCA
R. Correia, NRR
R. Frahm, Jr., NRR
inspection Program Bratich, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 6\\96-08.123
To receive a copy of this document,Indicete in the boa: "C" = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
- N' = No copy
OFFICE
Rl/SPO
Rl/SPO
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NAME
DURR [ G
LANNING R,OL
DATE
12/2/96
1A/3/96
OFFICIAL RECORD COPY
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