ML20155B111

Forwards Tier 2 Special Insp Rept 50-336/98-213 on 980810-0903 & Nov.Insp Consists of Part of Ongoing Multifaceted NRC Effort to Evaluate Pearsons Power Corp,Inc Conduct of ICAVP & Effectiveness of CMP

ML20155B111
Person / Time
Site:	Millstone
Issue date:	10/23/1998
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20155B115	List: IR 05000336/1998213 ML20155B111 ML20155B152
References
50-336-98-213, NUDOCS 9810300063
Download: ML20155B111 (5)

See also: IR 05000336/1998213

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UNITED STATES

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s j NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D.C. 3066H001

% # . October 23, 1998 l

Mr. Martin L. Bowling

Recovery Officer - Millstone Unit 2

clo Ms. Patricia A. Loftus

Director - Regulatory Affairs

Northeast Nuclear Energy Company

P.O. Box 128

Waterford, CT 06385

SUBJECT: NOTICE OF VIOLATION AND INDEPENDENT CORRECTIVE ACTION

VERIFICATION PROGRAM TIER 2 SPECIAL INSPECTION OF MILLSTONE

UNIT 2 (NRC INSPECTION REPORT NO. 50-336/98-213) i

Dear Mr. Bowling:

From August 10,1998, through September 3,1998, a team from the U.S. Nuclear Regulatory

Commission's (NRC's) Office of Nuclear Reactor Regulation, in accordance with guidelines

outlined in SECY-97-003, " Millstone Restart Review Process," performed a Tier 2 special

inspection of your Millstone Unit 2 facility. This inspection was part of an ongoing, multifaceted

NRC effort to evaluate Parsons Power Group inc.'s (Parsons) conduct of the Independent '

Corrective Action Verification Progam (ICAVP) and the effectiveness of your Configuration

Management Plan (CMP). The results of the ICAVP will provide insights that will be used by

the NRC in assessing the effectiveness of your CMP and your readiness to restart Millstone

Unit 2.

Selected accident mitigation systems were reviewed to assess Parsons' Tier 2 review, to verify

the ability of these systems to perform their intended safety functions during postulated

accidents described in Chapter 14 of the Final Safety Analysis Report (FSAR), and to

determine whether the accident analysis assumptions were properly translated into instructions,

procedures, and drawings. The NRC determined that Parsons successfully implemented the

Tier 2 verification of critic 11 design characteristics controlling plant configuration aspects of its

NRC approved ICAVP AL.dit Plan in accordance with the applicable project procedures and

instructions.

The inspection findings were presented to you and your staff during a public exit meeting on

October 6,1998. The issue cited as a violation in the enclosed Notice of Violation, is described

in detailin the enclosed report. The number of examples identified in this violation, as well as

issues recently identified in the Tier 1 In-Scope inspection and discussed with you at the public

exit meeting held on October 6,1998 appear to be indicative of a configuration control process

weakness in the translation or reconci' ation of the accident analyses inputs and results v ith

station procedures and other supporting engineering analyses that form the bases for the

system design. Please note that you are required to respond to the Notice of Violation and

should follow the instructions specified in it when preparing your respense. We request that .

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your response address the team's observations regarding configuration controlindicated above

9810300063 981v23

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in addition to the specific technicalissues identified in the violation. The NRC will use your

response, in part, to determine whether further enforcement action is necessary to ensure

compliance with regulatory requirements,

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The violation described in this report has been categorized as equivalent to ICAVP Significance '

Level 3 findings. ICAVP Level 3 findings have been defined by the NRC to occur if a system is

outside its licensing and design bases while still able to perform its intended function. In a

January 30,1998, letter to you, the Director of the Special Projects Office described the NRC's

criteria for determining whether to expand the scope of the ICAVP An important factor in

making this determination is the NRC's assessment of the effectiveness of the corrective

actions taken to address the findings. The NRC will assess the corrective actions taken in

response to these findings as part of its review of the implementation of ICAVP-related

I corrective actions.

As noted earlier, this inspection was part of the NRC's ongoing assessment of the effectiveness

of your CMP and Parsons' ICAVP. The findings of this inspection will be combined with the

results of other NRC inspections to make an overall determination of the restart readiness of

Unit 2 and your configuration management practices. However, the results from this inspection

provide a measure of confidence that the Unit 2 accident mitigation systems are adequately

designed and tested and will perform as assumed in accident analyses as described in

Chapter 14 of the FSAR.

In accordance with Section 2.790(a) of Title 10 of the Code of Federa/ Regulations (10 CFR

2.790(a)), a copy of this letter and the enclosures will be placed in the NRC Public Document

Room.

If you have any questions concerning the enclosed inspection report, please contact the project

manager, Mr. Daniel Mcdonald, at (301) 415-1408 or Mr. Peter Koltay at (301) 415-2957.

Sincerely,

m

Eugene V. Imbro, Director

Millstone Independent Corrective Action

Verification Program Inspections

l Associate Director for Technical Review

Office of Nuclear Reactor Regulation

Docket No. 50-336

License No. DPR-65

Enclosures:

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1. Notice of Violation

2. Inspection Report 50-336/98-213

cc w/ enclosures: See next page

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in addition to the specific technical issues identified in the violation. The NRC will use your

, response, in part, to determine whether further enforcement action is necessary to ensure

compliance with regulatory requirements.

The vioistions described in this report have been categorized as equivalent to ICAVP

Significance Level 3 findings. ICAVP Level 3 findings have been defined by the NRC to occur if

a system is outside its licensing and design bases while still able to perform its intended

function. In a January 30,1998, letter to you, the Director of the Special Projects Office

described the NRC's criteria for determining whether to expand the scope of the ICAVP. An

important factor in making this determination is the NRC's assessment of the effectiveness of

the corrective actions taken to address the findings. The NRC will assess the corrective actions

taken in response to these findings as part of its review of the implementation of ICAVP-related

corrective actions.

As noted earlier, this inspection was part of the NRC's ongoing assessrnent of the effectiveness

of your CMP and Parsons'ICAVP. The findings of this inspection will be combined with the

results of other NRC inspections to make an overall determination of the restart readiness of

Unit 2 and your configuration me.nar,ement practices. However, the results from this inspection

provide a measure of confidence that the Unit 2 accident mitigation systems are adequately

designed and tested and will perform as assumed in accident analyses as described in

Chapter 14 of the FSAR.

In accordance with Section 2.790(a) of Title 10 of the Code of FederalRegulations (10 CFR

2.790(a)), a copy of this letter and the enclosures will be placed in the NRC Public Document

Room.

If you have any questions concerning the enclosed inspection report, please contact the project

manager, Mr. Daniel Mcdonald, at (301) 415-1408 or Mr. Peter Koltay at (301) 415-2957.

Sincerely, g stgne W

o

Eugene V. Imbro, Director

Millstone Independent Corrective Action

Verification Program inspections

Associate Director for Technical Review

Office of Nuclear Reactor Regulation

Docket No. 50-336

License No. DPR-65

Enclosures:

1. Notice of Violation

2. Inspection Report 50-336/98-213

cc w/ enclosures: See next page

Distribution: See next page

DOCUMENT NAME: TIER 2.RPT

(*see previous concurrence) Review completed by Technical Editor on 10/21/98

To receive a copy of this document, Indicate in the box "C" copy w/o attach / encl "E" copy w/ attach /enci"N" no copy _

OFFICE ADT:lCAVP E TechED. lN ADT:lCAVP l C:lCAVP D:lCAVP

NAME RMcIntyre* JNakoski PKoltay Elmb[

DATF 10D1 /4R 10/71 /QR 10/??/QR* 10/ /9R 10/ /98

OFFICIAL RECORD COPY

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, Letter to Mr. M. L. Bowlino dated: October ,1998

Distribution w/ enclosures:

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FILE CENTER, NRR (with original concurrences)

PUBLIC

Region i Docket Room (with copy of concurrences)

Nuclear Safety Information Center (NSIC)

ICAVP R/F

DOCDESK

NRC Resident inspector, Millstone Unit 2

OE (2)(EA Package only)

W. Axelson, DRS -

S. Collins

W. Lanning, RI

M. Callahan, OCA

W. Dean, NRR

E. Imbro, NRR

R. McIntyre, NRR

P. Narbut, NRR

J. Nakoski, NRR .

B. Hughes, NRR

J. Houghton, NRR

D. Mcdonald, NRR

S. Dembek, NRR

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P. Koltay, NRR

J. Andersen, NRR

D. Screnci, RI, PAO (e-mail)

Inspection Program Branch NRR, IPAS

S. Castro NRR, PIMB/ DISP

T. Walker, RI

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, Letter to Mr. M.L. Bowling dated:

cc w/encis:

J. Streeter, Vice President, Nuclear Oversight

J.K. Thayer, Fecovery Officer, Nuclear Engineering and Support

D. Amerine, Vice President, Engineering and Support Services

J.A. Price, IJnit Director, Unit 2

P.D. Hinnennamp, Director, Unit Operations

F.C. Rothen, Vice President, Work Services

J. Stankiewicz, Training Recovery Manager

J. Cantrell, Direchr, Nuclear Training

S.J. Sherman, Audits and Evaluation

L.M. Cuoco, Esquire

J.R. Egan, Esquira

V. Juliano, Waterferd Library

J. Buckingham, Depr.rtment of Public Utility Control

S.B. Comley, We Tt.o Pecple

State of Connecticut Ocsignee

D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN

J.M. Block, Esquire, CAN

S.P. Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon

E. Woollacott, Co-Chairman, Nuclear Energy Advisory Council

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