ML20135F804
| ML20135F804 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/12/1997 |
| From: | Travers W NRC (Affiliation Not Assigned) |
| To: | Carns N, Laudenat R NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9703140131 | |
| Download: ML20135F804 (5) | |
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~l March 12,1997 Mr. Neil S. Carns Senior Vice President and Chief Nuclear Officer Northeast Nuclear Energy Company c/o Mr. Richard T. Laudenat Director - Regulatory Affairs P.O. Box 128 Waterford CT 06385
Dear Mr. Carns:
During the public meeting on February 5,1997, the NRC staff had requested additional information regarding the Independent Corrective Action i
Verification Program proposed by Northeast Nuclear Energy Company (NNECO) for Units 1 & 3.
This information was provided in your letter to NRC. B16273.
dated. February 21. 1997. As a result of the NRC staff's review of the I
information provided in letter B16273, the following additional information is requested. The following items regarding the financial independence of Sargent & Lundy and the restriction on future Sargent & Lundy work for Northeast Utilities need to be addressed as part of NRC's organizational approval of Sargent & Lundy as the ICAVP contractor.
Financial Independence of Sargent & Lundy (S&L)
The Certification of Ownershi) Interest prepared by S&L' indicates that their Retirement Plan may hold stoc( or other ownership interest either directly or indirectly in Northeast Utilities or the other entities named on the Unit 1 and Unit 3 operating licenses through a Trust Fund. Additionally. S&L stated that their Savings and Investment Plan (including 4nik) may indirectly hold stock or other ownership interest in Northeast Utilities or the other entities named on the Unit 1 and Unit 3 o)erating licenses through investments that participating individuals may mace in mutual funds or similar instruments.
It is requested that S&L provide a copy of the Prospectus for their retirement plan including a list of currently held assets.
In addition. it is requested that S&L provide a copy of the Prospectuses for the financial instruments in which individuals participating in the S&L Savings Investment Plan may invest.
Restrictions on Sargent & Lundy from Performing Future Work It was stated in the above referenced February 21, 1997, letter that S&L will be contractually restricted from performing or seeking new work at Millstone l9 Units 1 and 3 for 12 months following completion of the ICAVP.
In order to further assure the independence of the ICAVP effort, we request that this restriction on future work be extended to any Northeast Utilities facility for a period of 12 months following the completion of the ICAVP.
The following items are not necessary for NRC to reach a judgement regarding approval of S&L as the ICAVP contractor for Units 1 & 3.
The questions on Life Cycle Management and Resume 13 may be addressed by S&L in the ICAVP Audit p 55We8$r NRC Fil.E CENTER COPY I
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Neil S. Carns l Plan and will be reviewed by NRC during the Audit Plan approval process. The l
modification of the licensees Quality Assurance Plan, if necessary, will be handled through the established regulatory process set forth in 10 CFR-50.54(a).
Quality Assurance Program Requirements The NRC recognizes that NNECO's commitment to Regulatory Guide 1.123. " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear' Power Plants." Revision 1. dated July 1977, which endorses ANSI N45.2.13-1976. requires that an acceptance review be conducted for engineering and consulting services performed under Apoendix B to 10 CFR Part 50.
In our judgement, if an acce)tance review was con' ucted by NNECO it would compromise d
the independence of tie ICAVP and would be contrary to the requirements of NRC's confirmatory order of August 14, 1996. Therefore, recognizing that the work performed by S&L will be performed in accordance with their NRC approved Quality Assurance Program Topical Report and the need for independence of the ICAVP we recommend that NNECO amend its Quality Assurance Plan using the j
regulatory process specified in 10 CFR 50.54(a) to indicate that NNECO will not conduct an acceptance review of the engineering and consulting services provided by S&L under the ICAVP contract.
Life Cycle Management Study Performed by Sargent & Lundy As a part of the Life Cycle Management Study performed by S&L. the NNEC0 letter of February 21, 1997. stated that S&L made component-specific recommendations based on a comparison of Northeast Utilities practices with industry practices. Although not explicitly stated we assume from the content of the letter that these recommendations may relate to qualification (e.g.,
seismic and environmental qualification, qualified life, etc.) of specific components.
It was also stated that these recommendations did not directly impact issues related to the completeness of the design and licensing bases.
Please provide further clarification as to why the design and licensing bases of the facility was not impacted by these recommendations.
Qualifications of the Individual Represented in " Resume 13" In reviewing the resumes submitted it appears from the information presented that the individual represented on Resume 13 has primarily project management
. experience and rather limited " hands-on" design ex)erience of electrical systems at nuclear power generation facilities. W1ile the individual has substantial electrical design experience at coal-fired power stations we are
l Neil S. Carns 3-concerned that the possible lack of substantial nuclear design experience may adversely impact the results of the-ICAVP review.
We request that additional supporting information be provided for this individual.
Sincerely,
/s/
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, William D.' Travers, Director J Special, Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50-245 and.50-423'
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4 Northeast Nuclear Energy Company Miilstone Nuclear Power Station Units 1 and 3 cc:
Lillian M. Cuoco. Esquire Mr. Wayne D. Lanning Senior Nuclear Counsel Deputy Director for Inspections Northeast Utilities Service Company Special Projects Office P.O. Box 270 475 Allendale Road Hartford, CT 06141-0270 King of Prussia, PA 19406-1415 Mr. Kevin T. A. McCarthy, Director Mr. D. M. Goebel Monitoring and Radiation Division Vice President - Nuclear Oversight De)artment of Environmental Northeast Utilities Service Company 3rotection P.O. Box 128 1
79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 Mr. J. McElwain Mr. Allan Johanson, Assistant Millstone Unit No. 1 Director Nuclear Recovery Officer Office of Policy and Management Northeast Utilities Service Company Policy Development and Planning P.O. Box 128 Division Waterford, CT 06385 450 Capitol Avenue - MS 52ERN P.O. Box 341441 Mr. F. C. Rothen Hartford. CT 06134-1441 Vice President - Nuclear Work Services Mr. Ted C. Feigenbaum Northeast Utilities Service Company Executive Vice President and P.O. Box 128 Chief Nuclear Officer Waterford, CT 06385 Northeast Utilities Service Company P.O. Box 128 Ernest C. Hadley. Esquire Waterford, CT 06385 1040 B Main Street P.O. Box 549 Mr. W. J. Riffer West Wareham, MA 02576 Nuclear Unit Director Millstone Unit No. 1 Mr. John Buckingham Northeast Nuclear Energy Company Department of Public Utility Control P.O. Box 128 Electric Unit Waterford, CT 06385 10 Liberty Square New Britain, CT 06051 Regional Administrator, Region I U.S. Nuclear Regulatory Commission M. H. Brothers, Nuclear Unit 475 Allendale Road Director King of Prussia, PA 19406 Millstone Unit No. 3 i
Northeast Nuclear Energy Company First Selectmen P. O. Box 128 Town of Waterford Waterford, CT 06385 Hall of Records i
200 Boston Post Road i
Waterford, CT 06385
4 Burlington Electric Department Deborah Katz, President c/o Robert E. Fletcher, Esq.
Citizens Awareness Network 271 South Union Street P.O. Box 83 Burlington, VT 05402 Shelburne Falls, MA 03170 Mr. M. R. Scully Executive Director Senior Resident Inspector 3
Connecticut Municipal Electric Millstone Nuclear Power Station Energy Cooperative c/o U.S. Nuclear Regulatory 30 Stott Avenue Commission Norwich, CT 06360 P.O. Box 513 Niantic, CT 06357 Mr. William D. Meinert Nuclear Engineer Citizens Regulatory Commission Massachusetts Municipal Wholesale ATTN:
Ms. Susan Perry Luxton Electric Company 180 Great Neck Road P. O. Box 426 Waterford, Connecticut 06385 Ludlow. MA 01056 Mr. James S. Robinson Manager, Nuclear Investments and Administration New England Power Company 25 Research Drive Westborough, MA 01582 1
Mr. P. D. Hinnenkamp Director Unit Operations Northeast Utilities Service Company P.O. Box 128 i
Waterford. CT 06385 Josep& Associates P.C.
h R. Egan. Esq.
Egan 2300 N Street, NW Washington, D.C. 20037 Mr. J. K. Thayer Recovery Officer. Nuclear-Engineering and Support Northeast Utilities Service Company P.O. Box 128 Waterford, CT 06385 Mr. J. P. Cowen Millstone Unit No. 3 Nuclear Recovery Officer Northeast Utilities Service Company P. O. Box 128 Waterford, CT 06385
.