ML20155J044
| ML20155J044 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/22/1988 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20155J040 | List: |
| References | |
| A07491, A7491, NUDOCS 8810250137 | |
| Download: ML20155J044 (5) | |
Text
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(203) 66F5000 Sep temt. er 22, 1988 Docket No. 50-336 A07491 Re Inspection 85-10 Hr. V. T. Russell, Regional Administrator U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pa.
19406
References:
(1)
R. H. Gallo letter to E. J. Hroczka, dated August 23, 1988, Specialist Team Inspection 50-336/88-10 (Hay 10-17, 1988).
(2)
V.
G. Counsil (NNECO) to J.
R.
Hiller (NRC) letter, dated January 30, 1985, Procedure Generation Package (PGP).
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Response to Inspection Specialist Team Inspection 50-336/88-10 (May 10-17, 1988J In a letter dated / ; gust 23, 1988 (Reference (1)), the NRC Staff issued an inspection report to Northeast Nuclear Energy Company (NNECO) for Hillstone Unit No. 2.
This action was the result of an announced special safety inspection conducted May 10-17, 1988 to 4
reviev Unit 2 Emergency Operating Procedures (EOPs).
Reference (1) forwarded a Notice of Deviation and also discussed a number of technical concerns and deficiencies.
Pursuant to Reference (1), NNECO hereby provides the following response:
The Notice of Deviation, forwarded as Appendix A to Reference (1), has been reviewed and evaluated by NNECO.
Response to the Notice of Deviation is forwarded as Attachment I, attached.
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Mr. V. T. Russell A07491/Paga 2 September 22, 1988 DEFICIENCY RESPONSE PLAN Reference (1) also requested plans for corrective actions related to other stated deficiencies.
In support of this request, NNECO notes that many of the observations made by the team during the inspection i
have already been incorporated into Unit 2 E0Pa during a planned July 1988 revision.
- 1) Reference (1), Section 3 Independent Technical Adequacy. Review of E0Ps A) The use of 30*F subcooling as an acceptance criteria for the operation of two Reactor Coolant Pumps.(RCP) has bee n clarified via the use of a caution.
B) The deviation from CEN-152 with respect to Steam Generator (S/G) U-tube void elimination in E0P 2532 has bcen resolved.
E0P 2532 and E0P 2534 are discussed further in Attachment I.
- 2) Reference (1), Section 4 Validation and Verification, and Section 7 - Human Factors Analysis In a telephone conversation on September 15, 1988, the NRC Ctaff agreed with NNECO that a separate submittal containing the balance of the above information vill be submitted by October 31, 1988.
Ve trust the above information satisfactorily responds to your concerns.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY M W
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E. 4f( Hroczka #
Senior Vice President Attachment cc D. H. Jaffe, NRC Project Manager, Hillstone Unit No. 2 W. J. Raymond, Senior Resident Inspector, H111 stone Unit Nos. 1, 2 and 3 R. H. Gallo, Region I U. S. Nuclear Regulatory Commission l
Document Control Desk Vashington, D. C 20555
(
Docket No. 50-336 A07491 l
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Attachment I
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Hillstone Nuclear Power Station, Unit No. 2 Specialist Team Inspection 50-336/88-10 (May 10-17, 1988)
NRC Notice of Deviation l
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Septemb r 1988 l
NRC NOTICE OF DEVIATION (from Reference (1), Appendix "A"]
NRC Generic Letter 82-33 (GL 82-33) required that licensees develop basic emergency response capabilities including the upgrade and implementation of emergency operating procedures (EOPs) using an NRC approved procedures generation package. NUREG 0899 states that the licensee's plant-specific guidelines should be based on the generic guidelines provided by the licensee's owners group and the deviations from the generic guidelines shoulu be fully documented and justified.
By letter dated January 30, 1985, the licensee submitted the Hillstone Unit 2 Procedure Ceneration Package (Revision 1) in which they committed to conform with the guidance provided by NUREG 0899 and the Combustion Engineering Emergency Procedure G11delines (CEN-152), and to implement an E0P verification program to evaluate written co:rectness of the procedures and to ensure that applicable generic and plant-specific technical information had been incorporated properly.
CEN 152, Revision 2 provides guidance on steam generator U-tube voiding and subsequent elimination in Steps 40 and 41.d. of Section 5, "Loss of Coolant Accident Recovery Guideline" and in Steps 34 and 35.d of Section 6.0, "Steam Generator Tube Rupture Recovery Guideline."
Contrary to the above, the licensee did not incorporate this guidance into plant-specific E0P 2532, "Loss of Primary Coolant" and E0P 2534 "Steam Generator Tube Rupture" or justify the omission of this guidance from the specified prvcedures.
ROOT CAUSE NNFC0 considers that adequate guidance existed in both E0P 2532 and in E0P 2534 when coupled with their referral to E0P 2540, "Functional Recovery," to eliminate voids and ensure the Heat Removal Safety Funct on was not compromised. This deviation occurred due to i
insefficient documentation of this position during the verification phase of E0P development required by the Unit 2 Proceduras Generation Package (PGP) (Reference 2).
CORRECTIVE ACTION To be responsive to the NRC Inspection Team's concern as stated during the inspection and exit meeting, UNECO incorporated guidance on S/G U-tube void elimination into E0P 2532 during a planned revision to the E0P's in July, 1988. Also, included in the July E0P revisions vere enhancements responsive to several other observations and recommen-dations stated by the inspection team. These revisions became effective on August 3, 1988.
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. The next planned revision to the Millstone Unit 2 E0Ps is targeted for February 1, 1989.
Since NRC concern with E0P 2534 was not known until receipt of Reference (1), the guidance on G/G U-tube void elimination vill be incorporated into E0P 2534, "Steam Generator Tube Rupture," at that time. In the interim, NNECO remains confident that sufficient guidance exists within E0P 2534 and its referral to E0P 2540, "Functional Recovery," to ensure that the Heat Removal Safety Function j'
is not jeopardized.
ACTION TO PREVENT RECURRENCE NNECO considers the omission of this guidance on S/G U-tube void elimination from both E0P 2532 and E0P 2534 and a lack of documentation concerning these omissions to be an isolated incident, rather than a programmatic failure.
As committed to in Reference (2),
NNEC0 performed an extensive verification and validation program to I
ensure that the Unit 2 E0P's were both technically accurate and practical for the operator. All steps of this program were evaluated by the inspection team and were found to be adequate. Therefore, no l
programmatic corrections vill be implemented at this time.
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