ML20195B694

Forwards Insp Rept 50-336/98-203 on 980824-0904.No Violations Noted

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: IR 05000336/1998203 ML20195B694
References
50-336-98-203, EA-98-468, NUDOCS 9811160248
Download: ML20195B694 (6)

See also: IR 05000336/1998203

Text

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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

P.O. Box 128

Waterford, CT 06385

~; SUBJECT: INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM

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

i 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

i 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

j your Configuration Management Plan (CMP). The results of the ICAVP will provide insights that

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will be used by the NRC in assessing the effectiveness of your CMP and to determine your

readiness to restart of Unit 2.

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The inspection team assessed the capability of the auxiliary feedwater (AFW) system and the l

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-

built configurations with the Final Safety Analysis Report, and the consistency of system {

j operations with the plant Technical Specifications (TSs), were also evaluated. The inspection ,

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

, (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 i

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of this alignment was made by the plant staff at a time when plant procedures required no formal

- 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. 1

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! The ICAVP Tier 2 inspection (Inspection Report 50-336/98-213) identified an apparent /

l configuration control process weakness regarding the proper translation of accident analyses /

- inputs and assumptions into the facility design and plant operating procedures and the

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, reconciliation of the facility design and procedures to the accident analyses inputs and

i assumptions. This apparent violation and other findings in this report are additional examples

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that further highlight that concem. h gl

9811160248 981105

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PDR ADOCK 05000336

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j Mr. Martin L. Bowling, Jr. -2-

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,"

(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 l

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(1) respond to the apparent violation addressed in this inspection report within 30 days or (2)

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 '

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. -3-

. November 5, 1998

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 TechED. ICAVP D:lCAVP

NAME JLuehman/sjEI(y * Pkoltay Elmbro

DATE 1l/@198 10/ 23/98* 1)/ Ir l98 1lIMl98

OFFICIAL RECORD COPY

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Mr. Martin L. Bowling, Jr. -3-

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,

l Mr. J. Luehman, at (301) 415'3150.

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Sincerely,

l. Eugene V. Imbro, Director

Millstone Independent Corrective Action

Verification Program

Associate Director for Technical Review I

Office of Nuclear Reactor Regulation i

Docket No. 50-336 1

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 -

S. Comley, WE THE PEOPLE

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State of Connecticut SLO Designee

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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