ML20153E976
| ML20153E976 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/22/1998 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-245-98-206, 50-336-98-206, 50-423-98-206, NUDOCS 9809280307 | |
| Download: ML20153E976 (3) | |
See also: IR 05000245/1998206
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September 22, 1998
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Mr. in ~. Bowling, Recovery Officer - Technical Services
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/o M; . P. A. Loftus, Director - Regulatory
Affairs for Millstone Station
NORTHEAST NUCLEAR ENERGY COMPANY
PO Box 128
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Waterford, CT 06385
SUBJECT:
COMBINED INSPECTION NO. 50-245,336,423/98-206
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Dear Mr. Bowling:
This letter refers to your June 26,1998 correspondence, in response to our May 26,
1998, letter. We note this letter only addresses corrective action for a violation identified
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at Unit 1; and that corrective actions for violations identified at Unit 3 were addressed
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separate correspondence to tha NRC.
Thank you for informing us of the corrective and preventive actions for Unit 1 documented
in your letter. Since subsequent to this response, you have notified the NRC of your intent
to permanently shut down Unit 1, your actions for this and previous NRC violations, which
are still open are being reviewed generically by the NRC for applicability.
Your cooperation with us is appreciated.
Sincerely,
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ORIGINAL SIGNED BY:
Jacque P. Durr, Chief
Inspections Branch
Millstone inspection Directorate
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Docket Nos. 50-245;50-336;50-423
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9809280307 980922
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ADOCK 05000245
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Mr. M. L. Bowling
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cc:
B. Kenyon, President and Chief Executive Officer - Nuclear Group
M. H. Brothers, Vice President - Operations
- J. McElwain, Recovery Officer - Millstone Unit 2
J. Streeter, Recovery Officer - Nuclear Oversight -
P. D. Hinnenkamp, Director - Unit 3
J. A. Price, Director - Unit 2 -
D. Amerine, Vice President - Human Services
E. Harkness, Director, Unit 1 Operations
. J. Althouse, Manager - Nuclear Training Assessment Group
F. C. Rothen, Vice President, Work Services
J. Cantrell, Director - Nuclear Training (CT)
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S. J. Sherman, Audits and Evaluation
cc w/cv of licensee resoonse ltr:
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. Bass llakis, 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. M. L. Bowling
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Djstribution w/cv of licensee resoonse ltr:
Region i Docket Room (with so.py of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
FILE CENTER, NRR (with Oriainal concurrences)
Millstone Inspection Directorate Secretarial File, Region i
NRC Resident inspector
H. Miller, Regional Administrator, RI
B. Jones, PIMB/ DISP
W. Lanning, Director, Millstone inspection Directorate
D. Screnci, PAO
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DOCUMENT NAME: 1:\\ BRANCH 6\\REPLYLTR\\98206-2.RPY
To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
"E"
=
Ccpy with attachment / enclosure
"N" = No copy
OFFICE
Rl/MID jy))
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NAME
NJBLUMBERG
JPDURR- M
DATE
09//7/98
09pg/98
09/ /98
09/ /98
09/ /98
OFFICIAL RECORD COPY
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Northeast
11 pe Fcrry Rd. (Route 156), Wtterford, CF 06385
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Nuclear Energy
Muhtone Nuclear Power Station
Northeast Nuclear Energy Company
P.O. Box 128
Waterford, Cr 06385-0128
(860) 447-1791
Fax (860) 444 4277
The Northeast Unditics Symem
JUN 2 61998
Docket No. 50-245
817292
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U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555
Millstone Nuclear Power Station, Unit No.1
Reply to a Notice of Violation
NRC Combined Inspection Report No. 50-245!98-206
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This letter responds to a Notice of Violation contained in the enclosure to the NRC
Combined Inspection Report issued on May 26,1998.W The inspection Report was
issued following an inspection conducted during the period January 1,1998 through
February 28,1998. The inspection performed an evaluation of Millstone Unit No.1
programs, prccedures, and' operations during shutdown conditions.
An investigation revealed a previous valve lineup had been revised to reflect a new
pcsition for a valve, and the valve position subsequently had not been verified in
accordance with the new valve lineup. This lack of configuration control of plant valves
was determined to be a violation of Technical Specification Section 6.8.1. The steps
Northeast Nuclear Enorgy Company has taken to address the violation, as well as the
steps that will be taken to avoid recurrence are provided in our reply to the violation in
Attachrnent 1. In addition, the reply to this violation addresses the process problems
identified with configuration control, valve lineup updates, and quality record retention
for completed valve lineups as requested by the NRC Staff.
Attachment 2 provides the regulatory commitments associated with this letter.
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NRC Letter to NNECO, "NRC COMBINED INSPECTION 50-245/98-206;
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50-336/98-206;50-423/98-206 and NOTICE OF VIOLATION," dated May 26,1998.
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U.S. Nucicar Regulatory Commission
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B17292\\Page 2
Should you have any questions regarding this submittal, please contact Mr. Peter J.
Miner at (860) 440-2085.
Very truly yours,
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NORTHEAST NUCLEAR ENERGY COMPANY
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Martin L. Bowling, Jr.
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Recovery Officer - Technical Services
Sworn to and subscribed before me
this Mday of 1t
1998
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Notary Pubic
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NOTARY PUllLIC
My Commission expires
a couwssa cxmts at 30.2000
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- Attachments:
1) Reply to a Notice of Violation
2) List of Regulatory Commitments
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cc:
H. J. Miller, Region i Administrator
S. Dembek, NRC Project Manager, Millstone Unit No.1
T. A. Easlick, Senior Resident inspector, Millstone Unit No.1
W. D. Travers, Ph.D, Director, Special Projects Office
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Docket No. 50-245
.B17292
Attachment 1
Millstone Nuclear Station, Unit No.1
Reply to a Notice of Violation
NRO Combined inspection Report No. 50-245/98-206
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June 1998
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U.S. Nuclecr Regulatory Commission
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B17292\\ Attachment 1\\Page 1
Restatement of the Violation
Technical Specification 6.8.1.a requires that written procedures be established,
implemented and maintained covering the activities referenced in Appendix A of
Regulatory Guide 1.33, February 1978, item ic, Administrative Procedures, " Equipment
Control." The failure to establish and implement a procedure for equipment control to
process revisions to system valve lineups and thereby ensure that the appropriate
changes are communicated to the field, constitutes a violation of NRC requirements. In
addition, the response to this violation should address the process problems identified
with configuration control, valve lineup updates, and quality racW retention for
completed valve lineups.
Reasons for the Violation
The lack of verification of valve position following update of the valve lineups has been
attributed to an inadequate configuration control process design for positions of plant
valves. Updating of valve lineups is performed in accordance with the design and
procedure change processes. However, there were no expectations requiring i valve
to be verified in the new position following the valve lineup change. Cont c.suting
factors are: a lack of procedural guidance, inadequate initial and continuing training
with regard to configuration control, and failure to communicate management
expectations to ensure valve lineups, operating procedures, and piping and
instrumentation diagrams (P&lDs) are revised in a consistent manner. The failure to
forward completed valve lineups to Nuclear Document Services (NDS) for retention has
been attributed to a misinterpretation of technical specification requirements for records
retention.
Corrective Actions Taken and Results Achieved
The following corrective actions have been taken:
Ninety percent of accessible vaives in valve lineups for systems in operation or
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systems credited for Shutdown Risk have been verified and Condition Reports
initiated for any additional valve position discrepancies found.
Accessible valves in those systems in operation or credited for Shutdown Risk,
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which have been found out of position, have either been returned to their required
position or tagged.
Operations Manual Section 9.2 " Procedure Administration" has been reded to
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require all valve lineup changes / revisions to be reviewed and authorized by the
Shift Manager before entering the change into the controlled copies.
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A Millstone Unit No.1 tagging audit, to verify the actual position of valves versus the
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position tagged, has been completed. Two minor discrepancies were found and
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have been resolved.
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B17292\\ Attachment 1\\Page 2
Completed refueling outage (RFO) 14 valve lineup sheets have been transmitted to
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NDS for retention.
Corrective Steps to Prevent Further Violations
The following corrective actions will be taken:
Valve lineups for those remaining accessible valves and inaccessible valves in
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operating systems or systems credited for Shutdown Risk will be performed prior to
startup from RFO 15.
Millstone Unit No.1 will develop guidance which defines the process for ensuring
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valve lineups, operating procedures, and P&lDs are revised in a consistent manner.
This will be completed prior to startup from RFO 15.
Millstone Unit No.1 will provide to Operations department personnel initial and
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continuing training including the description of, and management's expectations for,
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the process for maintaining configuration control of plant valves. This will be
completed prior to startup from RFO 15.
Millstone Unit No.1 will revise crocedures and valve lineups required to establish
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the flowpath for system operation and include guidance specifying the method of
control of redundant components. This will be completed prior to startup from RFO
15.
As previously committed, in accordance with the Configuration Management
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Program, Millstone Unit No.1 will verify existing plant conditions are consistent with
the licensing basis. Thit, will be completed prior to startup from RFO 15.
Millstone Unit No.1 will develop and implement a procedure / process to ensure that
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changes to valve positions in lineups that are not controlled by Operations, e.g.,
instrumentation and Controls, Chemistry, are reviewed and authorized before
entering the change in the controlled copies. This will be completed prior to startup
from RFO 15.
Millstone Unit No.1 departments will perform a review of the records retention
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requirements specified in the technical specifications and reviu the Record
Retention and Turnover Schedule Handbook in accordance with NDM 1 for
Millstone Unit No.1 department documents required to be retained by NDS.
Documents required to be retained will be submitted to NDS prior to startup from
RFO 15.
Date When Full Compliance will be Achieved
Completion of all corrective actions associated with physical and programmatic
changes are required prior to startup from RFO 15.
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Docket No. 50-245
B17292
Attachment 2
Millstone Nuclear Power Station, Unit No.1
List of Regulatory Commitments
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June 1998
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B17292\\ Attachment 2\\Page 1
List of Regulatory Commitments
The following table identifies those actions committed to by NNECO in this document.
Any other actions discussed in the submittal represent intended or planned actions by
NNECO. They are described to the NRC for the NRC's information and are not
regulatory commitments. The Millstone Unit No.1 Manager - Regulatory Compliance -
should be notified of any questions regarding this document or any associated
Commitment
Committed Date
Number
or Outage
B17292-01
Ninety per cent of accessible valves in valve lineups
Complete
for systems in operation or systems credited for
Shutdown Risk have been verified and Condition
Reports initiated for any additional valve position
discrepancies found.
B17292-02
Accessible valves in those systems in operation or
Complete
credited for Shutdown Risk, which have been found
out of position, have either been retumed to their
required position or tagged.
B17292-03
Operations Manual Section 9.2 " Procedure
Complete
Administration" has been revised to require all valve
lineup changes / revisions to be reviewed and
authorized by the Shift Manager before entering the
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change into the controlled copies.
B17292-04
A Millstone Unit No.1 tagging audit, to verify the
Complete
actual position of valves versus the position tagged,
has been completed. Two minor discrepancies were
found and have been resolved.
B17292-05
Completed refueling outage (RFO) 14 valve lineup
Complete
sheets have been transmitted to NDS for retention.
B17292-06
Valve lineups for those remaining accessible valves
Prior to startup
and inaccessible valves in operating systems or
from RFO 15
systems credited for Shutdown Risk will be
performed.
B17292-07
Millstone Unit No.1 will develop guidance which
Prior to startup
defines the process for ensuring valve lineups,
from RFO 15
operating procedures, and P&lDs are revised in a
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consistent manner.
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B17292-08
Millstone Unit No.1 will provide to Operations
Prior to startup
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department personnel initial and continuing training
from RFO 15
including the description of, and management's
expectations for, the process for maintaining
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B17292\\ Attachment 2\\Page 2
Commitment
Committed Date
Number
or Outage
configuration control of plant valves.
B17292-09
Millstone Unit No.1 will revise procedures and valve
Prior to startup
lineups required to establish the flowpath for system
from RFO 15
operation and include guidance specifying the
method of control of redundant components.
B17292-10
Millstone Unit No.1 will develop and implement a
Prior to startup
procedure / process to ensure that changes to valve
from RFO 15
positions in lineups that are not controlled by
Operations, e.g., Instrumentation and Controls,
Chemistry, are reviewed and authorized before
entering the change in the controlled copies.
B17292-11
Millstone Unit No.1 departments will perform a
Prior to startup
review of the records retention requirements
from RFO 15
specified in the technical specifications and revise
the Record Retention and Turnover Schedule
Handbook in accordance with NDM 1 for Millstone
Unit No.1 department documents required to be
retained by NDS. Documents required to be retained
will be submitted to NDS.
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