ML20202J755
| ML20202J755 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/05/1997 |
| From: | Imbro E NRC (Affiliation Not Assigned) |
| To: | Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20202J759 | List: |
| References | |
| 50-423-97-206, EA-97-562, NUDOCS 9712110234 | |
| Download: ML20202J755 (5) | |
See also: IR 05000423/1997206
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 30406 4001
December 5, 1997
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EA 97 562
Mr. Bruce D. Kenyon
President and Chief Executive Officer
Northeast Nuclear Energy Company
P.O. Box 128
Waterford, CT 06385
SUBJECT:
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NOTICE OF VIOLATION AND INDEPENDENT CORRECTIVE ACTION
VERIFICATION PROGRAM FUNCTIONAL INSPECTION OF MILLSTONE
UNIT 3 (NRC INSPECTION REPORT NO. 50-423/97-206)
Dear Mr. Kenyon:
During the periods from August 18 29 and September 8-19,1997, the staff of the Special
Projects Office (SPO) performed a safety system functionalinspection (SSFI), of the
emergency core cooling and sealinjection functions of the chemical volume and control
systems. The capability of the system to perform the safety functions required by its design
basis, adherence of the system to its design and licensing bases, the consistency of the as built
configuration with the Final Safety Analysis Report (FSAR), and the consistency of system
operations with the plant technical specifications were assessed. The functions of important
support systems including charging pump cooling, electrical, and ventilation, and those of
interfacing systems such as the recirculation spray, reactor plant component coding, service
water, and safety injection were also verified.
The SSFl was conducted as part of the NRC staff's Millstone restart review process, as
described in SECY 97-003, dated January 3,1997. Northeast Nuclear Energy Company
(NNECO) has been carrying out assessments, principally through the Millstone Unit 3
Configuration Management Plan (CMP), to provide assurance that Unit 3 is in conformance with
its design and licensing bases. The NRC staff's SSFI, conducted by the SPO,is part of a
multifaceted effort designed to verify the effectiveness of your CMP efforts. The results of this
inspection, icgether with additional team inspections, and results from reviews by the
Independent Corrective Action Verification Program (ICAVP) contractor (Sargent and Lundy)
will be used by the NRC to assess the effectiveness of your CMP,
The findings of the inspection were presented to NNECO during a public exit meeting on
September 24,1997. The inspection identified three principal findings, as discussed below and
in further detail in the report. Additionally, the inspection identified other issues, which are fully
discussed in the report.
The first principal finding identified was that NNECO's staff had failed to recognize and evaluate
the potential for air in certain portions of the recirculation spray system to be swept into the
suction of the charging and safety injection pumps during the cold leg recirculation phase of a
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loss-of-coolant accident. While the results of ongoing analysis of this issue may lead to the
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9712110234 971205
ADOCK 05000423
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Mr,B.D.Kenyon
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conclusion that the air will have little or no effect on system or pump performance, the failure of
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NNECO's staff to fully analyze the system and understand its performance is, by itself, a
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concom.
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The second principal finding by the inspection was the apparent inadequacy of your Technical
Specification (TS)-required program to minimize leakage outside the containment. Specifically,
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the program addressed leakage from valve stems, piping joints, and other direct leakage
pathways. However, it failed to adequately account for potential valve leakage from systems
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carrying highly radioactive water to the refueling water storage tank following a postulated
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accident. This finding also identifed the apparently inadeq'. sate review (conducted ty NNECO)
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of information on this issue contained in a 1991 NRC Information Notice (IN). The information
contained in the IN, and in the existing calculations concerning post-accident leakage, orovided
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opportunities for the NNECO staff to identify and correct the problems with the program.
The apparent violations discussed above are be'ng considered for escalated enforcement
action in accordance with the " General Stateme'it of Policy and Procedure for NRC
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Enforcement Actions,"(Enforcement Policy), NUREG-1600. No response regarding these two
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apparent violations is required at this time; however, any corrective actions deemed appropriate
should be instituted in i, amely manner Pleat a be advised that the number and
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characterization of apparent violations described in the enclosed inspection report may change -
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as a result of further NRC review or additional information received at a predecisional
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enforcement conference, should the decision be made to hold one. You wil; be advised by
separate correspondence about further actions on these issues.
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The third principal issue identifed duririg the inspection was the inadequacy of the TS which
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requires valve lineup every 31 days for charging flow path valves not locked or otherwise -
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secured in position. While the TS do not require that the lineup be verifed using a single valve
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lineup procedure, the procedure reviewed during the inspection was the only one designated as
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necessary to comply with the TS. That procedure did not identify a complete listing of valves
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required to ensure proper lineup. While your staff was able to demonstrate that all the valves
missing from that lineup were accounted for, either in other lineups or by position alarms, this
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issue raises a question about the rigor and depth of NNECO's configuration management
program.
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The above issues, as well as others described in the report that include inadequate procedures
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and failure to correct FSAR discrepancies, are indicative of potential weaknesses in your CMP
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and have been cited as violations in the enclosed Notice of Violation. Please note that you are
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required to respond to the Notice of Violation and should follow the instructions specified in it
when preparing your response. The NRC will use your response, in part, to determine whether
further enforcement action is necessary to ensure compliance with regulatory requirements.
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Based on our findings, your staffinitiated an evaluation of the effectiveness of the CMP. In
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your response to the Notice of Violation please include a discussion of the scope and results of
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your evaluation of the CMP.
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Mr. B, D. K:ny n
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In accordance with Title 10 of the Code of FederalRegulations, Section 2.790(a), a copy of this
letter and the enclosures will be placed in the NRC's Public Document Room.
Should you have any questions concerning the enclosed inspection report, please contact the
project manager, Mr. J. Andersen at (301) 4151437, or the inspection team leader,
Mr. J. Luehman, at (301) 415-3150.
Sincerely,
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Eugene V. Imbro, Deputy Director
ICAVP Oversight
Special Projects Office
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Office of Nuclear Reactor Regulation
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Docket No.: 50-423
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Enclo'.ures:
2. Inspection Report 50-423/97-206
cc w/ enclosures: see next page
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DOCUMENT NAME:P:Millston.JI
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To receive a copy of this document, Indicate in the box "C" copy w/o attach /enci "E" copy wIattach/enci "N" no
copy
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OFFICE
ICAVP:SPO
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DATE
12/ 6/97
10/16/97
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NAME
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DATE
1213 /97
OFFICIAL RECORD COPY
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Mr. B. D. Kenyon
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cc w/ enclosures:
{
M.H. Brothers, Vice President . Millstone Unit 3
D.M. Goebel, Vice President, Nuclear Oversight
J.K. Thayer, Recovery Officer, Nuclear Engineering and Support
P.D. Hinnenkamp, Director, Unit Operations
F.C. Rothen, Vice President, Work Services
J.Stankiewicz, Training Recovery Manager
R. Johannes, Director, Nuclear Training
L.M. Cuoco, Esquire
J.R. Egan, Esquire
V.Juliano, Waterford Library
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J.Buckingham, Department of Public Utility Control
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S.B. Comley, We The People
State of Connecticut SLO Designee
D.Katz, Citizens Awareness Network (CAN)
R.Bassilakis, CAN
J.M. Block, Esquire, CAN
S.P. Luxton, Citizens Regulatory Commi',sion (CRC)
Representative T. Concannon
E. Woollacott, Co-Chairman, NEAC
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Distribution for Memorandum to B.D. Kenyon dated:
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Distribution w/ enclosures:
Region l Docket Room (with rapy of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
FILE CENTER, NRR (with oriainal concurrences)
SPO R/F
NRC Resident inspector
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W.Axelson, DRS (Inspection Reports)
S. Collins
W. Travers
W.Lanning
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M.Callahan, OCA
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W. Dean, OEDO
E. Imbro
P. McKee
P. Kottay
J. Luehman
S.Tingen
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J. Nakoski
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D. Mcdonald
S. Dembek
S. Reynolds
J. Andersen
D.Screnci, PAO
Inspection Program Branch (IPAS)
B. Jones, PIMB/ DISP
DOCDESK (Inspection Reports Only)