ML20203K576

Provides Preliminary Results of NRC Special Projects Office Tier 1 Inscope Sys Design & Licensing Bases Insp of Independent Corrective Action Verification Program Oversight Activities for Millstone Unit 3

ML20203K576
Person / Time
Site:	Millstone
Issue date:	02/18/1998
From:	Imbro E NRC
To:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9803050144
Download: ML20203K576 (6)

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UNITED 8TATES

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NUCLEAR REGULATORY COMMISSION

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WASHINsTON, D.C. 3e086 4001 February 18, 1998

- i Mr.' Martin L. Bowling b

Recovery Officer - Millstone Unit 2

- c/o Ms. Patricia Loftus Director-Regulatory Affairs F

Northeast Nuclear Energy Company l_

P.O. Box 128 Waterford, CT 06385-0128 L

Dear Mr. Bowling:

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- This lettst provides the prollminary results of the NRC Special Projects Office (SPO) Tier 1 j-inscope system design and lhensing bases inspection of the Independent Corrective Action Veilfication Program (ICAVI) oversight activities for Millstone Unit 3 as described in SECY g7-

- 003, " Millstone Restart Review Process." These activities included inspection of portions of the recirculation spray system (RSS), quench spray system (QSS), emergency diesel generator (EDG) sequencer, and the supplemental leak collection and retsase system (SLCRS); and a comparison of the inspection team's findings with the ICAVP Tier 1 findings made by Sargent &

Lundy (S&L), the contractor responsible for implementing the ICAVP at Millstone Unit 3. The NRC's Tier 1 inspection was a functionally based design and licensing bases inspection similar

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to a safety system functional inspection (SSFI) of portions of RSS, QSS, EDG sequencer, and

_ SLCRS, while S&L's Tier 1 review encompassed all of the design and licensing bases aspects l:

of the.15 systems included within the scope of the ICAVP Tier 1 review. The subject inspection period was from lanuary 5 through February 6,1998. The detailed findings for the NRC's Tier

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1 Inscope inspection activities will be documented in inspection report number (IR No.) 50-423/g7-210. The team continues to review information provided by you since the end of the inspection that may change the content of the inspection report from the issues discussed in this letter The inspection team provided you periodic upostes of the inspection findings 4

throughout the inspection period and will provide you with the results of the inspection at a i

public exit meeting on Februaiy 24,1998.

i Preliminary As asment of S&L's Tier 1 Activities g

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Based on the inspection, the team determined that S&L needed to augment its review -

several areas. :The team requested that S&L perform the following additional reviews:

,(1) rereview electrical control circuits that have control inputs from the redundant train for single failure vulnerabilities; (2) a review by the System Review Group of the discrepancy reports (DRs) issued by the Operations and Maintenance Rcview Group and DRs associated with 1

temporary modifications to determine whether there were any desi n weaknesses that were C

L being resolved by temporary modifications or operator work arounds; (3) review the structural calculations for fans 3HVR*FN12A & B in the auxiliary building heating, ventilation, and air 1

b(,%0i conditioning system; (4) verify that all of the required Tier 1 associated intermediate structural support steel calculations were included within the scope of the Tier i review; (5) review the

additional modifications to RSS that had not been included because the modification packages 7

had not been completed and provided to S&L; and (6) perform a system-based, multidisciplined.

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2-I M. L Bowling i

review of confirmed DRs to identify potentia! programmailc issues and to ensure that -

- appropriate consideration, by each discipline, was included in the closure process for each confirmed DR. In each instance, S&L was responsive to the team's firdings and developed I

appropriate corrective actions to address the team's concerns. S&L is currently performing -

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.these additional reviews and will incorporate any additional findings int 3 its lissessment and conclusions regarding the ICAVP Tier 1.ystems.

l The NRC Tier 1 Inscope inspection identified issues, discussed below, that are currently being

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evaluated by the NRC and, as such, are considered preliminuy findings. Although the NRC team's preliminary findings have identified potential instances of noncompliance with the Unit 3

- design and licensing bases, none of the team's findings raise questiont, regarding the ability of e

RSS, QSS, EDG sequencer, or SLCRS to perform their specified safety functions. As such, i

these findings have been preliminarily categorized as ICAVP Significance Level 3 issues.' The j

- team's preliminary assessment of S&L's Tier 1 activities is that they satisfied the NRC's i

expectations, as described in SECY-g7-003, and the results of S&L's Tier 1 reviews can provide l

valuab.e input to the NRC's assessment of the effectiveness of your Configuration Management F

Plan (CMP) in assuring compliance with your design and licensing bases.

Preliminary findings identified by the NRC Inspection Team at Millstone Unit 3 L

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- Our preliminary evaluation indicates that the following findings, some of which we would have expected to have been identified during your CMP reviews, are being considered as potential l

violations that require corrective action before restart. Each finding has been characterized as J

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a potential ICAVP Significance Level 3 issue in accordance with the ICAVP Significance Level criteria.

1. Electrical In reviewing the diagrams for auxiliary building fans 3HVR*FN14A & B and 3HVR*13A & B (12179 ESK-6SD, SSE, SSF,6SG) the staff noted that the control circuitry for the FN14A & -

_ B fans is such that following a loss of power to both trains, the fan interlocks could result in i

each fan prohibiting the other from restarting; Specifically, with train A or B supply and -

exhaust fans running, a loss of power will doenergize the 62/TDC relay in each fan circuit. If

. before restoring power to the fan motor control centers, the 62/TDC relay for the fan that was _ running resets, upon restoring power,- both sets of fans would start and subsequently

- shut each other down. With both fans shut down, each of the fans would again attempt to start and then would agkn shut themselves down. The cycle could repeat until one fan successfully started or the thermal overload devices in the fan circuits trioped.

2. Mechanical V

- The fire protection system piping for the safety-related SLCRS charcoal bed is of nonsafety design, therefore the fire protection system valves are not includsd in a leakage test prograrr. This creates the potential for wetting the charcoal filter bed and reducing the lodine removal capability of the filter beds.

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3. Instrumentation and Controls '

A design modification of the RSS motor oporstod valves MOV 38 and MOV 20 created an unrecognized interaction between be valves that couki result in the cycling of MOV 38. The cycling of MOV 38 would cause a reduction of flow to the containment spray system.

4. Operations, Maintenance, and Surveillance Your procedures allow for the periodic opening of the RSS pump seal cooling water tank fill valve, creating a direct path from the containment building to the auxiliary building. This operation creates a breach of containment integrity during plant power operations that is contrary to the requirements of ANSI N271-1976, " Containment isolation Provisions for Fluid Systems."

- Your procedure for operating the auxiliary building heating, ventilation, and air conditioning system p* ovides instructions for shifting trains of operating charging and reactor plant -

component cooling water (RPCCW) pump area ventilation fans (3HVR*FN13A/B and 3HVR*FN14A/B) during testing following maintenance withcut entering the limiting conditions for operation (LCO) specified in Technical Specifcation 3.0.3. Tne procedure specifies a manual operator action for an automatic safety function and maintains the syctem operable. The team determined that this was an inappropriate use c: an operator action as a compensatory measure during testing and that it would be appropriate to enter the LCO for Technical Specification 3.0.3.

While the NRC's Tier 1 Inscope inspection team did not identify any issues that raise questions with the ability of RSS to perform its safety functions, the team identified a number of issues f

with RSS that are required to be resolved before restart. These issues include: (1) training of operators on the system as reconfigured, including verification of simulator fidelity; (2) an assessment of any new insights revealed by the Individual Plant Examination for the reconfigured system; and '3) the determination of the cause and the development of corrective actions to address the excessive vibration experienced during post modification testing that 3'

resulted in damage to the RSS pump casing vent line.

The SPO staff will include these findings, along with the findings of other inspection activities and issues identified by S&L, in its assessment of the effectiveness of your efforts to re-

- establish the design and licensing bases of Millstone Unit 3. No response to the issues 9

discussed in this letter a:3 required. NRC IR No. 50-423/97 210 will provide the final inspection observations, findings, and any enforcement actions to which you will be required to respend based on the results of the subject inspection.

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4 M. L. Bowling

- Sho61d you have any questions or comments regarding the issues discussed in this letter, please contact me at (301) 415-2951.

Sincerely, L9piginalSigny4 byi Eugene V. Imbro Deputy Director, ICAVP Oversight Spacial Projects Office Office of Nuclear Reactor Regulation Docket No. 50-423 ccf See next page Distribution:

Docket PUBLIC SPO 9F SCollins FMiraglia JLieberman BBoger WTravers PMcKee SReynolds HEichenholz BMcCabe PKo'tay RArchitze!

JLuehman

- JNakoski RMcIntyre JAndersen CMarco (OGC)

• See previous concurrence page DOCUMENT NAME: G:\\NAKOSKl\\TilNR3.QUK To_ receive a copy of this document. Indicate in the box "C" copy w/o attach /enci"E" copy w/ attach /enci"N" no copy _

SPdh OFFICE icAVP:SPO ICAVP;SPO DRPE1Ag ICAVP;SPO SPO.DD WTdh NAME-JNakosk JLuehman*

LBerrr SReynolds*

Elmoro s

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% /f 3/98 7 // T /98 2/ n/98

,2/ h48 DATE Z IM /98-7- /

/9 OFFICIAL RECORD COPY r

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Northe: t Nucle:r Energy Company Millstone Nucle:r Power Station Unit 3 i

cc:

Lillian M. Cuoco, Esquire tar. William D. Meinert Senior Nuclear Counsel Nuclear Engineer j

- Northeast Utilities Service Company Massachusetts Municipal '.Wolesale P. O. Box 270 Electric Company Hartford, CT 06141-0270 P.O. Box 426 l

2 Ludlow, MA 01056 Mr. Kevin T. A. McCarthy, Director Monitoring and Radiation Division Joseph R.- Egan Esquire Department of Environmental Protwion Egan & Associates, P.C.

79 Elm Street 2300 N Street, NW j

Hartford, CT 06106-5127 Washington, DC 20037 L

Regional Administrator, Region l Mr. F. C. Rothen U.S. Nuclear Regulatory Commission Vice Pn,sident - Work Services Northeast Utilities Service Company 475 Allendale Road '

i King of Prussia, PA 19406 P O. Box 128 Waterford, CT 06385 i

First Selectmen j

Town of Waterford Ernest C. Hadley, Esquire j-Hall of Records 1040 B Main Street i

200 Boston Post P.oad P.O. Box 549 -

Waterford, CT 06385 West Wareham, MA 02576 Mr. Wayne D. Lanning Mr. John Buckingham Deputy Director ofInspections Department of Public Utility Control Special Projects Office Electric Unit 475 Allendale Road 10 Liberty Square

- King of Prussia, PA 19406-1415 New Britain, CT 06051 Mr. M. H. Brothers Mr. James S. Robinson, Manager Vice President - Operations Nuclear investments and Administration -

Northeast Nuclear Energy Company New England Power Company P.O. Box 128 25 Research Drive Waterford, CT 06385 Wostborough.MA 01582 Mr. M. R. Scully, Executive Director -

Mr. D. M. Goebel Conn 6cticut Municipal Electric Vice President - Nuclear Oversight Energy Cooperative Northeast Utilities Service Company 30 Stott Avenue P. O. Box 128 Norwich, CT 06360 Waterford, CT 06385 Mr. David Amerine Deborah Katz, President Vice Presiderit - Nuclear Engineering '

Citizens Awareness Network and Support P.O. Box 83

- Northeast Utilities Service Company Shelburne Falls, MA 03170 -

P. O. Box 128

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Waterford, CT 06385

a Northeast Nuclear Energy Company Millstone Nuclear Power Station -

Unit 3 cc:

l Mr. Allan Johanson, Assistant Director Mr. Don Schopier Office of Policy and Management Verification Team Manager Policy Developmern and Planning Sargent & Lundy Division 55 E. Monroe Street 450 Capitol Avenue - MS# 52ERN Chicago, IL-60603 P. O. Box 341441 Hartford, CT 061341441 Mr. J. P. McElwain Vice President (Acting) - Millstone 3 Citizens Regulatory Commission Northeast Nuclear Energy Company ATTN: Ms. Susan Perry Luxton P.O. Box 128 180 Great Neck Road Waterford, CT 06385 Waterford, CT 06385 Mr. G. D. Hicks The Honorable Terry Concannon Unit Director-Millstone Unit 3 l

2 Nuclear Energy Advisory Council Northeast Nuclear Energy Company

' Room 4035 P.O. Box 128 Legislative Office Building Waterford, CT 06385 4

Capitol Avenue Hartford, CT 06106 Senior Resident inspector Millstone Nuclear Power Station j

Legislative Office Building clo U.S. Nuclear Regulatory Ccmmission Captiol Avenue P. O, box 513 Hartford, CT 06106 Niantic, Connecticut 06357 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office o

P.O. Box 0630

- Niantic CT 06357-0630 Mr. B. D. Kenyon Chief Nuclear Officer-Millstone Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 -

Mr, Daniel L. Curry Project Director Parsons Power Group Inc.

2675 Morgantown Road

? Reading, PA 1g607.-

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