ML20141E283
| ML20141E283 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/24/1997 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20141E286 | List: |
| References | |
| 50-245-97-02, 50-245-97-2, 50-336-97-02, 50-336-97-2, 50-423-97-02, 50-423-97-2, EA-97-205, EA-97-206, EA-97-304, NUDOCS 9707010020 | |
| Download: ML20141E283 (4) | |
See also: IR 05000245/1997002
Text
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June 24,1997
97-206
97-304
Mr. Bruce D. Kenyon
President and Chief Executive Officer
Northeast Nuclear Energy Company
P.O. Box 128
Waterford, Connecticut 06385
Dear Mr. Kenyon:
SUBJECT: NRC COMBINED INSPECTION 50-245/97-02; 50-336/97-02; 423/97-02 and
,
All three units remained in cold shutdown status throughout this inspection period. NU
management changed the recovery strategy to shift from three units in parallel to a lead
plant concept. Unit 3 was designated as the lead unit, and on May 27,1997, the unit was
declared ready for independent Corrective Action Verification Process. Recovery managers
for Units 1 and 2 assumed responsibility for Unit 3 physical plant readiness and regulatory
readiness, respectively. Processes and management changes continued during this period.
Although we have observed progress in the configuration management program, the NRC
staff continued to identify violations of NRC requirements during this inspection period.
We are particularly concerned about the repetitiveness and number of examples where
radiation workers fail to wear dosimetry in the radiation protection areas. In addition, we
remain concern about the effectiveness of the correction action program, and the
reluctance of some staff to document deficiencies.
At Unit 1, a violation involved failure to translate correctly the plant design basis into
drawings and to implement appropriate administrative controls on the positions of certain
containment isolation valves in the main feedwater system. Additionally, NRC inspectors
identified that corrective actions were inadequate to address a Unit 2 single failure
vulnerability associated with an enclosure building damper. Finally, five examples of
unauthorized radiological workers or workers lacking proper dosimetry entering or working
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in the radiologically controlled areas, one each in Units 1 and 3, and three in Unit 2, were
identified since the conclusion of our last inspection of this area. This is of particular
concern as it is a repetitive violation.
These violations are cited in the enclosed Notice of Violation, and the circumstances
surrounding the violations are described in detail in the enclosed report. Please note that
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you are required to respond to this letter and should follow the instructions specified in the
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97'7010020 970624
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ADOCK 05000245
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Mr. Bruce D. Kenyon
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enclosed Notice when oreparing your response. The NRC willme your response, in part,
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to determine whether further enforcement action is necessary to ensure compliance witn
regulatory requirements.
This report also discusses several apparent violations of NRC requirements at Unit 1
pertaining to the conduct of containment leakage rate testing, extended operation beyond
the plant licensing basis without performing a safety evaluation foi the torus water
temperature, inoperability of the low pressure coolant injection (LPCI) systGm, failure to
trend condition reports, and failure to identify and correct significant conditions adverse to
quality associated with containment leak rate testing and fouling of LPCI system heat
exchanger tubes.
Over the last six months, NRC inspection reports have discussed 17 licensee event reports
at Unit 2 involving inadequate surveillances. These appear to be repetitive violations nd
are being considered collectively as an apparent volation.
These apparent violations at Units 1 and 2 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. You will be advised by
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separate correspondence of the results of our deliberations on these matters. No response
regarding these seven apparent violations is required at this time; however, any corrective
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actions deemed appropriate should be instituted in a timely manner. Please be advised that
the number and characterization of apparent violations descrit,ed in the enclosed inspection
report may change as a result of further NPC review.
Furthermore, the Unit 1 staff planned to perform a test of the core spray system in the
recirculation mode using normal surveillance procedures. An evaluation had not been
performed to verify that an unreviewed safety question did not exist in accordance with 10 CFR 50.59. Since a 50.59 review / screening had not been performed in preparation for this
test, the intervention of the NRC prevented a potential violation of NRC requirements. The
NRC is concerned that a weakness exists, which would have allowed the performance of
an unreviewed test to occur. This performance demonstrated a lack of send.vity for the
regulatory framework under which Millstone must operate. Consequently, we request that
you inform us in writing within 30 days of the receipt of this letter of your completed
corrective actions to address this issue.
This report further discusses a review of the corrective action program at Unit 1, which
indicated that overall, the implementation of procedure RP-4, " Corrective Action Program,"
revision 4 has resulted in only limited improvements in the corrective action process. The
revision of the condition report (CR) process was poorly implemented in that, specific
guidelines were not put in place to ensure the initiation and appropriate processing of CRs
for conditions adverse to quality. Additionally, there appears to be some reluctance on the
part of some Unit 1 staff to initiate condition reports.
At Unit 3, NRC followup of a licensee condition report identified an event reportable in
accordance with 10 CFR 50.73, and further NRC questions were raised regarding the
acceptability of the most limiting failure serving as the design basis for the Unit 3 steam
generator tube rupture analysis. Also, some design control weaknesses are documented in
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Mr. Bruce D. Kenyon
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this report, which merit your continued attention to ensure that past programmatic
weaknesses in design control are not reflected in your current efforts to restore proper
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configuration management to the unit. Finally, while general improvements in the
radwaste program at Unit 1 were observed, clear lines of management responsibility for
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the liquid radwaste systems at Unit 3 still do not exist.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
arid its enclosures will be placed in the NRC Public Document Room (PDR).
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Sincerely,
ORIGINAL SIGNED BY:
Wayne D. Lanning
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Deputy Director of inspections
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Special Projects Office, NRR
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Docket Nos
50-245
50-336
50-423
Enclosures:
2. NRC Combined Inspection Report 50-245/97-02; 50-336/97-02;50-423/97-02
cc w/enci:
N. S. Carns, Senior Vice President and Chief Nuclear Officer
M. H. Brothers, Vice President - Millstone, Unit 3
J. McElwain, Unit 1 Recovery Officer
M. Bowling, Jr., Unit 2 Recovery Officer
-D. M. Goebel, Vice President, Nuclear Oversight
J. K. Thayer, Recovery Officer, Nuclear Engineering and Support
P. D. Hinnenkamp, Director, Unit Operations
F. C. Rothen, Vice President, Work Services
J. Stankiewicz, Training Recovery Manager
R. Johannes, Director - Nuclear Training
L. M. Cuoco, Esquire
J. R. Egan, Esquire
V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Control
S. B. Comley, We The People
State of Connecticut SLO Designee
D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN
J. M. Block, Attorney, CAN
S. P. Luxton, Citizens Regulatory Commission (CRC)
Representative T. Concannon
E. Woollacott, Co-Chairman, NEAC
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Mr. Bruce D.' Kenyon
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Distribution w/ encl-
Region 1 Docket Room (with copy of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
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FILE CENTER, NRR (with Oriainal concurrences)-
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NRC Resident inspector
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W. Axelson, DRA
M. Kalamon, SPO, RI
W. Lanning, Deputy Director of Inspections, SPO, RI
D. Screnci, PAO
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W. Travers, Director, SPO, NRR
Distribution w/ encl (VIA E-MAIL):
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M. Callahan, OCA
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R. Correia, NRR
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W. Dean, OEDO
G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR
P. McKee, Deputy Director of Licensing, SPO, NRR
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S. Reynolds, Chief Assistant, SPO, NRR
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D. Screnci, PAO
Inspection Program Branch (IPAS)
DOCDESK
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DOCUMENT NAME: G:\\ BRANCH 6\\ 97-02. ALL
To receive a copy of this document, Indicate in the bos: "C" = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
'N' = No copy
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DATE
06/9 /97 6/24
06/'Lo /97
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06/
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0FFICIAL RECORD COPY
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