ML20195J476

Forwards Insp Rept 50-336/98-219 on 981214-18,990126-29 0208-19 & 0301-05.Four Violations Identified & Being Treated as Noncited Violations

ML20195J476
Person / Time
Site:	Millstone
Issue date:	06/10/1999
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Necci R NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20195J482	List: IR 05000336/1998219 ML20195J476
References
50-336-98-219, NUDOCS 9906210032
Download: ML20195J476 (5)

See also: IR 05000336/1998219

Text

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NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20566-0001

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.....l June 10,1999

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Raymond P. Necci, Vice President

Nuclear Oversight and Regulatory Affairs

. c/o Mr. David A. Smith i

Manager- Regulatory Affairs -

Northeast Nuclear Energy Company

P.O. Box 128

Waterford, CT 06385-0128

SUBJECT: EXERCISE OF ENFORCEMENT DISC 4ETION; NRC INDEPENDENT i

CORRECTIVE ACTION VERIFICATION PROGRAM CORRECTIVE ACTION

IMPLEMENTATION INSPECTION OF MILLSTONE UNIT 2

(NRC INSPECTION REPORT NO. 50-336/98-219)

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Dear Mr. Necci:

A team from the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor

Regulation, performed the final phase of a corrective action implementation inspection of the

Millstone Nuclear Power Station Unit 2 facility licensed to Northeast Nuclear Energy Company ,

(NNECO) during December 14-18,1998, January 26-29, February 8-19, and March 1-5,1999.

This inspection was one part of an ongoing, multifaceted, NRC evaluation of the Independent

Corrective Action Verification Program (ICAVP) being conducted at Unit 2 by Parsons Power

Group, Inc (Parsons).

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

inspection evaluated corrective actions implemented in response to issues identified during the l

lCAVP oversight, including (1) a sample of corrective actions resulting from NNECO's

Configuration Management Plan (CMP), and (2) a sample of corrective actions documented in ,

confirmed Level 3 ICAVP discrepancy reports (DRs) issued by Parsons. Additionally, the //

inspection examined selected technical areas, such as electrical separation, to provide a /;

broader review of areas where the ICAVP had a number of discrete findings.

The team found that your corrective actions were adequate. Generally, the root cause g

evaluations were comprehensive, the extent of the problem was adequately explored, and the I

corrective actions matched the root causes and the extent of condition.

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Based on the inspection results, NRC has determined that four violations of NRC requirements

occurred. These violations are being treated as Noncited Violations (NCVs), consistent with

Appendix C of the Enforcement Policy. Three of the NCVs were issued as a result of our

followup of unresolved items identified in previous ICAVP inspections. One of the NCVs was a

new instance of an ineffective corrective action. Specifically, the team had examined your

f corrective actions for a previous violation. The original inspection finding, Violation 50-336/98-

202-05, was issued because the sampling flow to the Reactor Building Cloted Cooling Water

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system radiation monitors was not adequately controlled by operations to match the

assumptions for flow made in setting the radiation monitor's setpoint . The corrective action you

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had taken consisted of reperforming the radiation monitor's setpoint calculation. However, the

revised calculation still was not adequate. During the inspection, you took additional corrective

action. The team was able to assess your actions taken in response to the new NCV and found

them to be acceptable. These NCVs are described in the subject inspection report. If you

contest the violation or severity level of these NCVs, you should provide a response within 30

days of the date of this inspection repost, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with

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copies to the Regional Administrator, Region I, and the Director, Office of Enforcement.

Nine additional violations were identified as a result of your efforts during the CMP and, because

of this, NRC is exercising enforcement discretion in accordance with Section Vll.B.2 of the

Enforcement Policy and refraining from issuing citations for potential Severity Level IV violations.

These issues satisfy the appropriate criteria in Section Vll.B.2 (namely, (1) enforcement action -

was not considered necessary to achieve remedial action, (2) violations were based on activities

that occurred before you implemented the extended shutdown of the station, (3) violations vyould

not be categorized at Severity Level I, (4) violations were not willful, and (5) restarting Unit 2

. required NRC concurrence).

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The team examined the areas of calculation controls and accuracy, and drawings and

component information that the Parsons final report identified as potential trends. The team

determined the types of errors identified in these trends, evea when viewed collectively, did not

suggest that an expansion of the ICAVP scope would likely have identified errors that would call

into question conformance with the design snd licensing bases.

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

- on March 19,1999. The violations identified during this inspection are categorized as equivalent <

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

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

Significance Level 3 finding, NRC would consider expanding the ICAVP scope, taking into

consideration the effectiveness of your corrective actions. During this inspection, the NRC staff - ,

determined that NNECO has taken effective currective actions for ICAVP Significance Level 3 l

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~ 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 provided confidence j

that similar issues, if present, would likely have been found. Therefore, expansion of the ICAVP ,

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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

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. Ron Eaton, at

(301) 415-3041, or the inspection team leader, Mr. Paul Narbut, at (301) 415-2962.

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Sincerely,

[Y An N

Eugene V. Imbro, Director

Millstone hdependent Corrective Action

Verification Program inspections

Associate Director for Technical Review

Office of Nuclear Reactor Regulation

~ Docket No. 50-336

Enclosure:

Inspection Report 50-336/98-219 j

cc w/encls: See next page

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in accordance with 10 CFR, Section 2.7W(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. Ron Eaton, at

(301) 415-3041, or the inspection team leader, Mr. Paul Narbut, at (301) 415-2962.

Sincerely,

/2

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

Enclosure:

Inspection Report 50-336/98-219

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cc w/encts: See next page

Distribution:

Docket /PUBLIC

ICAVP R/F

Region I Docket Room (w/ copy of concurrences)

Nuclear Safety Information Center (NSIC)

NRC Re :t inspector, Unit 2

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Inspection M ogram Branch, NRR (IPAS)

IPAS

OE(2) (EA Packages Only)

W. Travers F. Miraglia S. Collins B. Sheron H. Miller, RI

OPA OCA W. Lanning D. Serenci, RI PAO (e-mail)

W. Dean E. Imbro P. Narbut P. Koltay J. Andersen

R. Eaton S. Castro T. Walker, RI J. Houghton S.,Tingen

J. Luehman J.Nakoski

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NOTE: This report was reviewed by a Technical Editor on May 14,1999

DOCUMENT NAME: A:Narbut.

To receive a copy of this document, indicate in the box: "C" = Copy without attachmenvenctosure T s Copy with attachment / enclosure "N" = No copy

OFFICE ADT:lCAVP E ADT:lCAVP E ADT:lCAVP E D:lCAVP

NAME PNarbut Ch BSheron PKoltay & Elmbro EE

DATE 06/ (/99 7 06/ /99 06/8 /99 " 06/a /99

OFFICIAL RECORD COPY

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cc for letter to Mr. Raymond P. Necci dated -

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D. Amerine, Vice President, Engineering and Support Services 1

C. Schwarz, Director of Units 2 and 3

F. Rothen, Vice President, Work Services  !

D. Hicks, Director, Training

L Cuoco, Esquire ]

V. Juliano, Waterford Library

J. Buckingham, Department of Public Utility Control

- S. Comley, We the People

State of Connecticut Designee

D. Katz, Citizen Awareness Network (CAN) -

R. Bassilakis, CAN

J. Block, Esquire, CAN {

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S. Luxton, Citizens Regulatory Commission (CRC)

Ms. T. Concannon, NEAC

E. Woollacott, Co-Chairman, NEAC

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