ML20199L614
| ML20199L614 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/25/1997 |
| From: | Durr J NRC (Affiliation Not Assigned) |
| To: | Carns N NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-245-97-202, 50-336-97-202, 50-423-97-202, NUDOCS 9712020070 | |
| Download: ML20199L614 (3) | |
See also: IR 05000245/1997202
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November 25, 1997
Mr. N. S. Carns, Senior Vice Prealdent
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and Chief Nuclear Officer
Nwtheast Nuclear Energy Company
PO Box 128
Waterford, CT 06385
SU83 JECT: NRC INSPECTION REPORT NO. 50-423,50 336,50-245/97 202- REPLY -
Dear Mr. Carns:
This letter refers to your October 6,1997 correspondence, in response to our
August 29,1997 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. Those actions will be examined during a future inspection of your licewed program.
Your cooperation with us is appreciated.
Sincarely,
ORIGINAL SIGNED BY
RICHARD J URBAN FOR
Jacque P. Durr, Chief
Inspections Branch
Office of Special Projects
Docket Nos. 50-245;50-336;50-423
cc:
M. H. Brothers, Vice President - Millstone, Unit 3
J. McElwain, Unit 1 Recovery Officer
M. Bowling, Jr., Unit 2 Recovery Officer
D. M. Goebel, Vice President, Nuclear Oversight
D. Amerine, Vice President for Engineering and Support Services
P. D. Hinnenkamp, Director, Unit Operations
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F. C. Rothen, Vice President, Work Services
J.' Stankiewicz, Training Recovery Manager
R. Johannes, Director - Nuclear Training
S. J. Sherman, Audits and Evaluation
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9712020070 971125
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- Mr. N. S. - Carns
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cc w/ cy_of licensee reponse ltr:
~ L. M. Cuoco, Esquire
.J. R. Egan, Esquire
- V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Control
- S. B. Comley, We The People
State of Connecticut SLO Designee
D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN
J. M. Block, Attorney, CAN
S. P. Luxton, Citizens Regulatory Commission (CRC)
Representative T. Concannon
E. Woollacott, Co-Chairman, NEAC
Distribution w/cv of licensee resoonse ltr:
Region i Docket Room (with somy of concurrences)
Nuclear Safety Information Center (NSIC)
FUBLIC
FILE CENTER, NRR (with Oriainel concurrences)
NRC Resident inspector
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B. Jones, PIMB/ DISP
M. Kalamon, SPO, RI
W. Lanning, Deputy Director of Inspections, SPO, RI
D. Screnci, PAO
W. Travers, Director, SPO, NRR
M. Callahan, OCA
R. Correia, NRR
W. Dean, OEDO
G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR
P. McKee, Deputy Director of Licensing, SPO, WRR
L. Plisco, Chief, SPO, NRR
S. Reynolds, Technical Assistant, SPO, NRR
Dist, w/ cv of licensee resoonse ltr: E-MA/L
D, Screnci, PAO
Inspection Program Branch (IPAS)
.DOCDESK (Inspection Reports Only)
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Mr. N. S. Carns
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DOCUMENT NAME: G:\\ BRANCH 6\\ MIL 97202.RPY
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure
"E" =
Copy with attachment / enclosure
"N" = No copy
OFFICE .
SPO/NRR
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OFFICIAL RECORD COPY-
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Rope Ferry Rd. (Route 156), Teterford, CT 06385
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Northeast Nucicar Emergy Cotnpaoy
P.O. Bos 128
Waterford. CT 06*85-0128
(860) 447-1791
Fax (860) 444 4277
The Nortleast Utihties Systern
OCT - 6 1997
Docket No. 50-423
B16754
Re: 10CFR2.201
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
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Millstone Nuclear Power Station, Unit No. 3
Reply to Notice of Violation 50-423/97-202
Failure To Follow Procedures and
incomplete and Inaccurate Information
in a letter dated August 29,1997,m the NRC transmitted the results of the routine NRC
resident inspection for inspection Report 50-423/97-202. The NRC Inspection Report
identified two violations during the applicable inspection period.
This istter provides Northeast Nuclear Energy Company's (NNECO) response to these
violations which includes a discussion of the causes and corrective actions taken or
planned.
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NNECO's commitments associated with the response are contained within
Attachment 1 to this letter.
Attachment 2 provides our reply to the Notice of Violations pursuant to the provisiona of
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W. D. Lanning letter to Neil S. Cams, 'NRC Combined inspection Report 50-
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245/97-202; 50-336/97-202; 50-423/97-202 and NOTICE OF VIOLATION,"
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dated August 29,1997.
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Lt.S. Nuclear Regulatory Commission
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B16754\\Page 2
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- Should you have any questions regarding this submittal, please contact Mr. David
' Smith at (860) 437-5840.
NORTHEAST NUCLEAR ENERGY COMPANY
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M. H. Brothers
Vice President - Millstone Unit No. 3
Attachments (2)
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cc:
H. J. Miller, Region i Administrator
J. W. Andersen, NRC Project Manager, Millstone Unit No. 3
A. C. Come, Senior Resident inspector, Millstone Unit No. 3
W. D. Travers, PhD, Director, Special Projects Office
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Docket No 50423
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B16754
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Attachment i
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Millstone Nuclear Power Station, Unit No. 3
NNECO's Commitments
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In Response To
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NRC Combined inspection Report 50-423/97-202
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U:S. Nuclear Regulatory Commission
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' B16754%ttachment 1\\Page 1
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Enclosure
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List of Regulatory Commitments
The following table identifies thoso actions committed to by NNECO in this document.
Please notify the Manager
Regulatory Compliance at the Millstone Nuclear Power
Station, Unit No. 3 of any questions regarding this document or any associated
Number
Commitment
Due
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B16754 01
Complete investigation into the use of one procedure
1/11/98
for application of ARCOR.
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B16754-02
Revise
Millstone
Station
Procedure,
DC-4,
12/31/97
' Procedural Compliance,' to clekrly communicate
Management expectations applicable to procedural
compliance.
B16754 03
Future responses to the applicable request for
10/15/97
information will be reviewed and approved by each
Ongoing
Unit's
Plant Operating
Review Committee
as
described ir he verification and validation process.
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pocket No. 50423
B16754
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Attachment 2
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Millstone Nuclear Power Station, Unit No 3
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Reply to Notice of Violation 50-423
NRC Combined Inspection Report
50-423/97-202
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816754\\ Attachment 2\\Page 1
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Restatement of the Violations
During an NRC inspection conducted on May 29, 1997 through July 21, 1997,
v6olations of NRC requirements were identified.
In accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the
violations are listed below;
A.
Unit 3 Technical Specification 6.8.1 requires that written procedures shall be
established, implemented, and maintained for activities referenced in Appendix
A of Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements
(Operation)." item 9. " Procedures for Performing Maintenance," of Appendix A
to RG 1.33 requires, in part, that maktenance that can affect the performance of
safety-related equipment should
properly performed in accordance with
written procedures.
Procedure MP 3710C, " Application of Linings to Plant Systems Subject to Salt
Water immersion," step 4.5.2.c, states, " Refer to applicable product cpecific
technique sheet (PSTS) for the coat to be applied and using
surface
temperature, OBTAIN minimum and maximum times to recoat and RECORD on
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Maint. Form 3710C-3."
Montenance Form 3710C-A-S30Pr, PSTS for Arcor Pcimeric S30 Prime, states
that the acceptable maximum overcoat condition is '7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> @72*F or Thumb
Nail Test with no indentation, whichever is less."
Contrary to the above, on several occasions in May and June 1997, the overcoat
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windnw was exceeded by 45 minutes to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 41 minutes.
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This is a Severity Level IV Violation (Supplement 1).
B.
Paragraph (a) of 10 CFR 50.9, " Completeness and accuracy of information,"
requires that "Information provided to the Commission by an applicant for a
license or by a licensee or information required by a statute or by the
Commission's regulations, orders, or license conditions to be maintained by the
applicant or the licensee shall be complete and accurate in all' material
respecth."
Contrary to the above, in letters to the NRC dated May 29,1997 and July 14, the
licensee provided, in part, "...significant items needed to be accomplished prior
to restart" and " items to be deferred until after restart."
This information was
inaccurate or incomplete in that: 1) Open !!em Reports (OIRs) were not included
in the May 29,1997 submittal; 2) centrol room deficienclos and bypass jumpers
were not reviewed for inclusion h the May 29,1997 submittal; 3) all existing
items were not included in the submittals; and, 4) a number of items that the
licensee did not intend to defer were improperly included in the list of items to be
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816754\\ Attachment 2\\Page 2
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deferred until after restart. A complete and accurate sub nittal is important to
permit the NRC to assess the potential safety significance of all items that will
not be completed prior to startup.
This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.
Reason for the Violation (Violation A):
NNECO agrees with this violation.
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The Root Cause of this event was procedure non-compliance. The procedure for
ARCOR application was not followed.
Contributing Factors:
1.
Failure of management to clearly state expectations to both painters and
inspectors. The importance of procedure adherence was not discussed at the
pre-job briefs. The contract inspectors had not been indoctrinated regarding NU
procespns or programs. There was no guidance given to the inspectors on the
station's Non-conformance Report (NCR) or Condition Report (CR) proceQJres
for conditions outside of the expected results.
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Due to the inconsistent behavior of the ARCOR product, the painters and
inspectors found themselves in a situation in which they perceived that they
needed to react to and deviate from the procedure guidance. The painters and
inspectors stated that based on their previous experiences, environmental
factors and manufacturing differences could a4ect ARCOR set up times.
3.
The inspectors were using different procedures from the other Millstone Units
which created confusion.
Corrective Steps That Have Been Taken And The Results Achieved (Violation A)
Two Root Cause_ investigations are completed.
Key elements of the Corrective Action Plans are:
1. Procedure MP3710C has been revised incorporating lessons learned based on
input from the paintars and inspectors who identified areas that needed clarification.
2. Training on the revised procedure has been completed for both painters and
inspectors.
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U.S. Nuclear Regulatory Commission
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3. Field walkdowns were performed on the remaining ARCOR work to be performed at
Unit 3 to identify spools which complicate the application of ARCOR, special work
dtfinition sheets were developed and work was successfully implemented as a
result of these walkdowns.
4. Pre-job briefings with personnel associated with the ARCOR project were conducted
to explain expectations for strict procedural compliance.
5. To verify coating integrity, the coatings on the affected spools were successfully X-
CUT tested by certified coating inspectors in one or more locations to verify coating
integrity. These local X-cut test areas were then repaired in accordance with the
procedure.
Corrective Steps That Will Be Taken To Avoid Further Violations (Violation A)
1. There are curruly ?c separate procedures for the application of the ARCOR
product. A recowrwcMnn from the root cause investigations was to investigate
the use of one proc 6aut or the Millstone Site. The fact that this material is applied
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to several different material surfaces may preclude the use of one procedure. This
investigation is ongoing with a scheduled completion date of January 11,1998.
2. Millstone Station Procedure, DC-4, ' Procedural Compliance," is being revised to
clearly communicate Management expectations
applicable
to
procedural
compliance. Included as part of the revision are the requirements that procedure
steps be performed as written and in sequence. When conditions are such that a
procedure can not be complied with as written, it is required that the applicable
activity cease and the procedure be revised.
The revision to DC-4 will be
completed prior to December 31,1997.
Date When Full Compliance Will Be Achieved (Violation A):
Millstone Unit No. 3 is currently in full compliance conceming this violation.
T
UlS. Nuclear Regulatory Commission
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Reason for the Violation (Violation B):
NNECO agrees with this violation.
The cause of this event is:
inadequate management oversight resulted in the initial submittal and the first
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update not receiving adequate management review or attention.
Corrective Steps That Have Been Taken And The Resulte Achieved (Violation B):
1.
Management has defined the roles and responsibilities of personnel developing
the required response and reinforced the standards required for this submittal.
2.
Due to its unique complexity, a specific verification and validation proceso has
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been developed for this project. The verification and validation process has
been reviewed and approved by all three Millstone Units Plant Operating Review
Committees.
Corrective Steps That Will Be Taken To Avoid Further Violations (Violation B)
Subsequent submittals to this request for information will be reviewed and approved by
each Unit's Plant Operating Review Committee as described in the verification and
validation process,
y e.
Date When Full Compliance'Will Be Achieved (Violation B):
Millstone Unit No. 3 will be in full compliance by October 15, 1997 when a new
remonse to the Request for Information is submitted.
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