ML20154D068

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Forwards Insp Rept 50-423/98-211 on 980413-24,0511-15,27-29, 0609-11 & 23-25 & Nov.Insp Was One Part of Ongoing, Multifaceted NRC Evaluation of ICAVP Being Conducted at Unit 3 by Sargent & Lundy
ML20154D068
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/11/1998
From: Imbro E
NRC (Affiliation Not Assigned)
To: Bowling M
NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20154D072 List:
References
50-423-98-205, 50-423-98-211, EA-98-366, EA-98-438, NUDOCS 9810070116
Download: ML20154D068 (6)
v • d • e


See also: IR 05000423/1998211

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D.C. 20066 0001

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September 11, 1998

EA 98-366

EA 98-438

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Mr. Martin L Bowling, Recovery Officer, Unit 2

c/o Ms. Patricia Loftus, Director, R,egulatory Affairs

Northeast Nuclear Energy Company

P. O. Box 128

Waterford, CT 06385

SUBJECT:

NOTICE OF VIOLATION AND INDEPENDENT CORRECTIVE ACTION

VERIFICATION PROGRAM CORRECTIVE ACTION IMPLEMENTATION

INSPECTION OF MILLSTONE UNIT 3 AND EXERCISE OF ENFORCEMENT

DISCRETION (NRC INSPECTION REPORT NO. 50-423/98-211)

Dear Mr. Bowling:

On April 13 through 24, May 11 through 15, May 27 through 29, June 9 through'11, and June

23 through 25,1998, a team from the U.S. Nuclear Regulatory Commission (NRC), Special

Projects Office, Office of Nuclear Reactor Regulation, performed the final phase of a corrective

action implementation inspection of the Millstone Nuclear Power Station Unit 3 facility (Unit 3),

licensed to Northeast Nuclear Energy Company (NNECO). This inspection was one part of an

ongoing, multifaceted NRC evaluation of the Independent Corrective Action Verification

Program (ICAVP) being conducted at Unit 3 by Sargent & Lundy (S&L). The corrective action

inspection was conducted in several phases as corrective actions were completed by NNECO.

The first phase of the corrective action implementation inspection results are documented in

Inspection Report (IR) No. 50-423/98-205.

Consistent with the guidance in SECY-97-003, " Millstone Restart Review Process," this

inspection included r' views of NNECO's self-assessments related to modifications made during

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the current outage and of the implementation of corrective actions in response to issues

identified by the NRC during oversight of the ICAVP; corrective actions documented in Licensee

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Event Reports (LERs) resulting from NNECO's Configuration Management Plan (CMP) or the

ICAVP; corrective actions documented in Confirmed Level 3 ICAVP Discrepancy Reports (DRs)

issued by S&L; and corrective actions resulting from NNECO's response to the Recirculation

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Spray System (RSS) bellows failure.

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Also reviewed were samples of DRs closed as Previously Identified, Non-discrepant, and

Confirmed Level 4 to assure appropriate categorization and closure. Further, DRs were

reviewed collectively to identify trends and assess their significance. DRs that required multiple

interactions between S&L and NNECO were also reviewed to gain additionalinsights into the

effectiveness of your corrective action process. In addition, Unit 2 preliminary DRs that

identified possible programmatic weaknesses were reviewed to determine if similar issues

existed at Unit 3.

9810070116 980911

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Mr. '1. L. Bowling

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During this inspection, the NRC closed 11 LERs that describe events that were determined to

be violations of NRC regulations for which the NRC has decided to exercise enforcement

discretion pursuant to Section Vll.B.1 of the NRC Enforcement Policy. The violations were

Severity Level IV that NNECO had identified and corrected. As defined in the NRC's

Enforcement Policy, Severity Level IV violations are the least significant within the NRC's

categorization of severity level, but are more than a minor concem (that is, if . eft ungorrected, .

they could lead to more serious concems).

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The NRC had considered LER 50-423/98-029-00, dated June 11,1998, for escalated

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enforcement and a civil penalty. This LER documents a condition in wnich nonsafety-related

exhaust fans in the Engineered Safety Features and Auxiliary Building Ventilation Systems

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could continue to operate, increasing the potential for leakage of contaminated air to the

atmosphere during a Loss-of-Coolant-Accident (LOCA), with offsite power available. This

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condition could cause the dose to the control room to exceed the limits specified by

Criterion 19, in Appendix A to Title 10, Part 50, of the Code of Federal Regulations (10 CFR Part 50). In addition, the report documents two examples of a violation of 10 CFR 50.73 for

failure to submit Licensee Event Reports for two conditions that were outside the design basis

of the plant. These issues involved the maximum design steam flow through the turbine bypass

valves (LER 50-423/98-026-00) and the maximum design temperature in service water pump

cubicles (LER 50-423/98-035-00). However, in closing these issues, and in consultation with

the Director, Office of Enforcement, I have decided to exercise enforcement discretion pursuant

to Section Vll.B.2 of the NRC's Enforcement Policy, " Violations identified During Extended

Shutdowns or Work Stoppages," rather than issuing a formal Notice of Violation. This decision

is based on (1) the violations arose as a result of NNECO's activities before the events leading

to the shutdown; (2) the violations were not classified higher than Severity Level 11; (3) NNECO

did not demonstrate willful intent to commit the violation; (4) you decided to report the two

instances that were a violation of 10 CFR 50.73 prior to plant restart; and (5) plant restart

required NRC approval.

Discretion in accordance with Section Vil.B.2 of the Enforcement Policy is appropriate because

the NRC had in place a formal plan that provided a broad-based evaluation of Millstone

readiness for restart. Moreover, that plan has confirmed that NNECO has taken corrective

action for these issues, and further enforcement action is not necessary to achieve remedial

action. The fundamental performance issues related to this violation are similar to those that

resulted in the many violations cited with-the $2.1 million civil penalty issued to you on

December 10,1997. You are not required to respond to these violations because the NRC

concluded that the information regarding the reason for the violations and, the corrective

actions taken to correct the violations and to prevent recurrence are adequately addressed in

LERs 50-423/98-029-00, 50-423/98-026-00, and 50-423/98-035-00 and the enclosed inspection

report.

During this inspection, the NRC closed LER 50-423/98-007-00, which described the failure to

' include all containment bypass leakage pathways in the calculation for containment leakage in

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violation of NRC requirements. This issue v/as identified by S&L, and is cited in the enclosed

Notice of Violation. However, you are not required to respond to this violation because the

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Mr. M. L. Bowling

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NRC concluded that the information regarding the reason for the violation and, the corrective

actions taken to correct the violation and to prevent recurrence are adeqeately addressed in

LER 50-423/98-007-00 and the enclosed inspection report.

The NRC is withdrawing parts of two violations. For the part of violation 50-423/97-206-03

involving the sizing of the discharge piping for charging system relief valves 3CHS*RV8119 arjd

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3CHS*RV8123, the team concluded, based on discussions with the staff, that the'pTping was

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sized in accordance with Code requirements. For the part of violation 50-423/97-209-03 related

to the radiation dose assessments in Final Safety Analysis Report (FSAR) Table 15.0.8, the

team determined, based on additional information provided by NNECO, that the values in the

table were consistent with the calculation results. - In both cases, we are withdrawing those

parts of the violations discussed above and will adjust our records accordingly.

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The NRC is closing 2 Escalated Enforcement Items (Eels). eel 50-423/97-209-02 describes

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the failure to monitor Service Water leakage from the RSS heat exchangers in accordance with

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Technical Specification 6.8.4. eel 50-423/97-209-06 describes the failure to implement

adequate corrective actions for the single-failure vulnerability of control room inlet dampers. In

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a letter dated May 6,1998, NNECO responded to the Eels and identified corrective actions.

The NRC determined that these Eels constitute violations of NRC requirements; however, they

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do not warrant escalated enforcement action because they are of low safety significance.

These are cited as Severity Level IV violations in the enclosed Notice of Violation. You are not

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required to respond to these violations because the NRC concluded that the information

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regarding the reason for the violations, and the corrective actions taken to correct the violations

and to prevent recurrence are adequately addressed in your May 6,1998, response and the

enclosed inspection report.

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You may provide a response to this letter for those violations for which no response is required

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if the description of the violations does not accurately reflect your corrective actions or your

position. In that case, or if you choose to provide additionalinformation regarding the violations

for which no response is required, you should follow the instructions specified in the enclosed

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Notice of Violation.

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Overall, the NRC staff determined that the DRs reviewed were properly categorized, and

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acceptable corrective actions were assigned to the LERs reviewed. NNECO's corrective

actions in response to issues identified by the ICAVP process and in response to the RSS

expansion bellows failure, including the integrated System Functional Review, and the outage

modification self-assessments were comprehensive and appropriately identified areas that

required additional actions, and the corrective actions for these self-assessment findings were

acceptable. The corrective actions in response to NRC inspection report findings and Level 3

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DRs were also acceptable. The issues identified in the preliminary Unit 2 DRs reviewed were

either previously identified and corrected during the Unit 3 CMP, or were not applicable to Unit

3. DRs with multiple interactions between S&L and the licensee did not indicate an inadequate

corrective action process; rather, these repeated interactions were a consequence of the

communications protocol between the licensee and S&L. DR trends in the areas of calculatior

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control / accuracy and drawings / component information were identified, but were considered nr

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to be significant. The types of errors identified in these trends, even when viewed collectively,

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did not suggest that an expansion of the ICAVP scope would have identified enors that wr,uld

call into question conformance with the design and licensing bases.

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Mr. M. L. Bowling

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The findings from this inspection were presented to you and your staff during a public meeting

on July 7,1998. The violations identified during this inspection are categorized as equivalent to

ICAVP significance Level 3 findings. In a letter to you dateo January 30,1998, the NRC stated

that if the reviews conducted by either the ICAVP contractor or the NRC confirmed an ICAVP

Significance Level 3 finding, the NRC staff would consider expanding the scope of the ICAVP

taking into consideration the effectiveness of ydur corrective actions. During this iaspection, the

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NRC staff determined that NNECO has taken effective corrective actions for ICAVP significance

Level 3 findings identified by the NRC and the ICAVP contractor and that these corrective

actions represented an appropriate expansion of the scope of NNECO's CMP ano provided

confidence that similar issues, if present, would likely have been found. Therefore, expansion

of the ICAVP scope was not warranted.

In accordance with 10 CFR, Section 2.790(a), a copy of this letter and the enclosures will be

placed in the NRC Public Document Room. Should you have any questions concerning the

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enclosed inspection report, please contact the project manager, Mr. J. Andersen, at (301)

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415-1437, or the inspection team leader, Mr. S. Tingen, at (301) 415-1280.

Sincerely,

N

Eugene V. Imbro, Director

Millstone ICAVP

Associate Director for Technical Review

Office of Nuclear Reactor Regulation

Docket No. 50-423

Enclosures:

1. Notice of Violation

2. Inspection Report 50-423/98 211

cc w/encls: See next page-

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Mr. M. L. Bowling

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The findings from this inspection were presented to you and your staff during a public meeting

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on July 7,1998. The violations identified during this inspection are categorized as equivalent to

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ICAVP significance Level 3 findings. In a letter to you dated January 30,1998, the NRC stated

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that if the reviews conducted by either the ICAVP contractor or the NRC confirmed an ICAVP

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Significance Level 3 finding, the NRC staff would consider expanding the scope of the ICAVP

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taking into consideration the effectiveness of your corrective actions. During this inspection, the

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NRC staff determined that NNECO has taken effectiva corrective actions for ICAVP significance

Level 3 findings identified by the NRC and the ICAVP contractor and that these corrective

actions represented an appropriate expansion of the scope of NNECO's CMP and povided

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confidence that similar issues, if present, would likely have been found. Therefore, expansion

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of the ICAVP scope was not warranted.

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in accordance with 10 CFR, Section 2.790(a), a copy of this letter and the enclosures will be

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placed in the NRC Public Document Room. ' Should you have any questions concerning the

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enclosed inspection report, please contact the project manager, Mr. J. Andersen, at (301)

415-1437, or the inspection team leader, Mr. S. Tingen, at (301) 415-1280.

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Sincerely,

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Original Signed by &

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Eugene V. Imbro, Director

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Millstone ICAVP

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Associate Director for Technical Review

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Office of Nuclear Reactor Regulation

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Docket No. 50-423

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Enclosures:

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1. Notice of Violation

2. Inspection Report 50-423/98-211

cc w/encis: See next page

Distribution:

Region 1 Docket Room (w/ copy of concurrences)

Nuclear Safety Information Center (NSIC)

NRC Resident inspector, Unit 3

File Center (w/ original concurrences)

OE (2)(EA Packages Only)

Inspection Program Branch, NRR (IPAS)

D. Screnci, RI PAO (e-mail)

N. Blumberg, RI (e-mail)

PUBLIC

W. Axelson, RI S. Collins

W. Lanning, RI

M. Callahan, OCA

W. Dean

E. Imbro

S. Tingen

P. Koltay

J. Andersen

B. Sheron

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S. Dembek

D. Mcdonald

S. Castro

T. Walker, RI

J. Nakoski

SPO R/F

  • See previous concurrence page

DOCUMENT NAME: A:98_211R5.423

This document was reviewed by a Tech Editor on July 27,1998

To feceive e <cpy of this document. Indicate in the box: "C" = Copy without ottachment/ enclosure *E" = Copy with attachment / enclosure *N" a No ccpy

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OFFICE ADT:lCAVP

E ADT:lCAVP , E ADT:lCAVP

E D:OE

D:lCAVP

NAME

STingen*

JNakoski/W

PKoltay*

JLieberman *

Elmbro &

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DATE

9/ 10 /98

9/ l( /98'

9/ 10 /98

9/ll /98

9/// /98

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OFFICIAL RECORD COPY

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Mr. M. L. Bowling

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cc for letter to Mr. Martin L. Bowling dated:

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J. Streeter, Vice President, Nuclear Oversight

D. Amerine, Vice President, Engineering and Support Services

J. Price, Unit Director, Unit 2

P. Hinnenkamp, Director, Unit 3 Operations

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F. Rothen, Vice President, Work Services

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J. Stankiewicz, Training Recovery Manager

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J. Cantrell, Director, Nuclear Training

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S. Sherman, Audits and Evaluation

L. Cuoco, Esquire

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V. Juliano, Waterford Library

J. Buckingham, Department of Public Utility Control

S. Comley, We the People

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State of Connecticut Designee

D. Katz, Citizen Awareness Network (CAN)

R. Bassilakis, CAN

J. Block, Esquire, CAN

S. Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon

E. Woollacott, Co-Chairman, Nuclear Energy Advisory Committee (NEAC)

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