ML20195B694
| ML20195B694 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/05/1998 |
| From: | Imbro E NRC (Affiliation Not Assigned) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20195B701 | List: |
| References | |
| 50-336-98-203, EA-98-468, NUDOCS 9811160248 | |
| Download: ML20195B694 (6) | |
See also: IR 05000336/1998203
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 30e86 0001
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Novanber 5,1998
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EA 98-468
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Mr. Martin L. Bowling, Jr.
Recovery Officer- Technical Services
c/o Ms. Patricia A. Loftus
Director- Regulatory Affairs
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Northessi Nuclear Energy Company
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P.O. Box 128
Waterford, CT 06385
SUBJECT:
INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM
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FUNCTIONAL INSPECTION OF MILLSTONE UNIT 2 (NRC INSPECTION
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REPORT NO. 50-336/98-203)
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Dear Mr. Bowling:
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During the periods fron. August 24 - September 4,1998, and September 14 -25,1998, a team
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from the U.S. Nuclear Regulatory Commission's (NRC's) Independent Corrective Action
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Verification Program (ICAVP), Office of Nuclear Reactor Regulation, in accordance with
SECY-97-003, "Millatone Restart Review Process," performed a Tier 1 in-scope inspection of
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your Unit 2 facility. This inspection was one part of an ongoing, multifaceted, NRC effort to
evaluate Parsons Power Group Inc.'s (Parsons) conduct of the ICAVP and the effectiveness of
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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 to determine your
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readiness to restart of Unit 2.
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The inspection team assessed the capability of the auxiliary feedwater (AFW) system and the
emergency diesel generator sequencer, to perform the safety functions required by their design
bases. Adherence of the systems to their design and licensing bases, the consistency of the as-
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built configurations with the Final Safety Analysis Report, and the consistency of system
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operations with the plant Technical Specifications (TSs), were also evaluated. The inspection
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findings were presented to you and your staff during a public meeting on October 6,1998.
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The inspection identified one apparent violation regarding Unit 2 Technical Requirements Manual
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(TRM) TS clarification that allowed an AFW flow path to be isolated for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Approval
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of this alignment was made by the plant staff at a time when plant procedures required no formal
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safety evaluation of the clarification. The NRC believes that an evaluation should have been
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performed based on the requirements of Title 10 of the Code of Federa/ Regulations, (10 CFR)
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Section 50.59. The failure to do such an evaluation is considered an apparent violation.
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The ICAVP Tier 2 inspection (Inspection Report 50-336/98-213) identified an apparent
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configuration control process weakness regarding the proper translation of accident analyses
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reconciliation of the facility design and procedures to the accident analyses inputs and
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assumptions. This apparent violation and other findings in this report are additional examples
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that further highlight that concem.
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9811160248 981105
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ADOCK 05000336
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Mr. Martin L. Bowling, Jr.
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The apparent violation discussed above is being considered for escalated enforcement in
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accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
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(Enforcement Policy), NUREG-1600. The circumstances surrounding the apparent violation, the
significance of the issue, and the need for lasting and effective corrective action were discussed
with you and your staff at the inspection exit meeting. As a result, it may not be necessary to
conduct a predecisional enforcement conference in order to enable the NRC to make an
enforcement decision.
Before the NRC makes its enforcement decision, we are providing you an opportunity to either
(1) respond to the apparent violation addressed in this inspection report within 30 days or (2)
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request a predecisional enforcement conference. If a conference is held, it will be open for
public observation. The NRC will also issue a press release to announce the conference.
Please contact me at (301) 415-2379 within 7 days of the date of this letter to notify the NRC of
your intended response.
If you intend to respond in writing, your response should be clearly marked as a " Response to An
Apparent Violation in Inspection Report No. 50-336/98-203," and should include (1) the reasons
for the apparent violation, or if contested, the basis for disputing the apparent violation, (2) the
corrective step that have been taken and the results achieved, (3) the corrective steps that will
be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Please be advised that the number and characterization of apparent violations described in the
enclosed inspection report may change as a result of further NRC review. You will be advised by
separate correspondence of the results of our deliberations on this matter.
Although at the time of the inspection the AFW system was being modified, the team was able to
review a substantial portion of the AFW system design including some of the modifications
completed during this outage. Based on the results of the team's independent design review, the
team's assessment of the Parsons implementation of Tier 1, preliminary indications are that the
NNECO's CMP was generally effective in identifying and correcting nonconformances with the
plant's design and licensing bases. Although neither your CMP nor the Parsons review identified
the TRM clarification issue discussed above, the failure to do so, appears to be an isolated case.
Subsequent to the inspection, at the request of the staff, Parsons performed an additional review
of the TRMs within the scope of the Tier 1 systems. This review, conducted with both an
operational and engineering perspective, identified no additional discrepancies.
As noted earlier, this inspection was part of the NRC's ongoing assessment of the effectiveness
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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 assessment of the restart readiness of Unit 2
and your configuration management practices.
The apparent 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 corrective actions.
In accordance with 10 CFR, Section 2.790(a), a copy of this letter and its enclosures and your
response (if you choose to provide one) will be placed in the NRC Public Document Room.
To the extent possible, your response should not include any personal privacy, proprietary, or
safeguards information, so that it can be placed in the PDR without redaction.
Mr. M:rtin L. Bowling, Jr.
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November 5, 1998
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Should you have any questions conceming the enclosed inspection report, please contact the
project manager, Mr. D. Mcdonald at (301) 415-1408, or the inspection team leader,
Mr. J. Luehman, at (301) 415-3150.
Sincerely,
Original signed by:
Eugene V. Imbro, Director
Millstone Independent Corrective Action
Verification Program
Associate Director for Technical Review
Office of Nuclear Reactor Regulation
Docket No. 50-336
Enclosure:
Inspection Report 50-336/98-203
cc w/ encl: See next page
Distribution: See next page
DOCUMENT: A:LUEHMAN
- see previous concurrence
OFFICE
ICAVP:SPO
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D:lCAVP
NAME
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OFFICIAL RECORD COPY
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Mr. Martin L. Bowling, Jr.
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Should you have any questions conceming the enclosed inspection report, please contact the
project manager, Mr, D. Mcdonald at (301) 415-1408, or the inspection team leader,
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Mr. J. Luehman, at (301) 415'3150.
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Sincerely,
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Eugene V. Imbro, Director
Millstone Independent Corrective Action
Verification Program
Associate Director for Technical Review
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Office of Nuclear Reactor Regulation
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Docket No. 50-336
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Enclosure:
Inspection Report 50-336/98-203
cc w/ encl: See next page
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CC's for letter and inspection report to Mr. M.L. Bowling
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M. Brothers, Vice President - Operations
J. Streeter, Vice President, Nuclear Oversight
J. Price, Unit Director- Millstone Unit 2
. D. Amerine, Vice President for Engineering and Support Services
F. Rothen, Vice President, Work Services
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S. Sherman, Audits and Evaluation
R. Johannes, Director, Nuclear Training
L. Cuoco, Esquire
J. Egan, Esquire
V. Juliano, Waterford Library
' J.. Buckingham, Department of Public Utility Control
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S. Comley, WE THE PEOPLE
State of Connecticut SLO Designee
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D. Katz, Citizens 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 Council
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