ML20207M761

Provides Preliminary Results of multi-phased Insp of Corrective Action Activities Associated with CMP & Icavp. Team Examined Technical Resolutions,Assessment of Root Cause & Assessment of Extent of Adverse Condition

ML20207M761
Person / Time
Site:	Millstone
Issue date:	03/17/1999
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Bowling M, Miller H NORTHEAST NUCLEAR ENERGY CO.
References
50-336-98-205, NUDOCS 9903190179
Download: ML20207M761 (4)

Text

,- . . -. - - . - - . - -... - - . - ~. .- . . . - . . . _ - - . - --

1. p!

p;- y*

\ UNITED STATES  !

4

]'

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20006 00M

.r -

• • • • • March 17, 1999 4

i i

Mr. Martin L. Bowling, Jr. .

Recovery Officer - Technical Services

' c/o Mr. Harry Miller Northeast Nuclear Energy Company .

' P.O. Box 128  !

Waterford, CT 06385-0128

Dear Mr. Bowling:

This letter provides the preliminary results of the multi-phased inspection of your corrective action activities associated with your Configuration Management Program (CMP) and the independent Corrective Action Verification Program (ICAVP). The scope of the inspection included reviewing (1) corrective actions for issues identified during your CMP; (2) corrective .

actions for confirmed Level 3 discrepancies identified by the ICAVP contractor, and '

(3) corrective actions taken in response to findings identified by the NRC inspections associated i' with the NRC oversight of the ICAVP. The inspection was a part of the ICAVP oversight

activities for Millstone Unit 2 as described in SECY-97-003, " Millstone Restart Review Process." l

The team examined your technical resolutions, assessment of root cause, and assessment of the extent of the adverse condition. The team also looked at your resolutions for some technical issues identified by Parsons such as the High Energy Line Break analysis in containment, electrical separation issues, fuse control, configuration management process changes to assure that accident analysis inputs were consistent with plant operating procedures, and your methods of tracking the cumulative effects of design changes on design margins. The inspection was f performed during the periods of December 14-18,1998, January 26-29, February 8-12, O February 16-19, and March 1-5,1999. The detailed findings of the team will oe documented in inspection report No. 50-336/98-205. The report is scheduled to be issued on or about April 19, p 1999. The inspection team leader provided you with the results of the inspection at a public exit

. meeting held on March 18,1999. b j '

Preliminary Assessment of Corrective Action Activities.:

Generally, the team found that your corrective actions were adequate. The root causes appeared reasonable, the extent of the problem was explored, and the corrective actions matched the root causes and the extent of condition. We identified a few cases where documentation of the root cause and the extent of condition were not adequate but the corrective actions taken were adequate. In response to the team's observations, your staff

( initiated condition reports to assess methods to enhance the applicable areas of the corrective action process.

9903190179 990317 PDR 7' e ADOCK 05000336 pg . .

y

[

p I .Y q

The team identified one instance of ineffective corrective action. The original inspection finding,  !

Violation No. 50-336/98-202-05, was issued because the sampling flow to the Reactor Building Closed Cooling Water system radiation monitors was not adequately controlled by operations l

{

and did not match the assumptions for flow used in the radiation monitor alarm setpoint  !

calculation. The team reviewed the corrective action that consisted of reperforming the radiation monitor's setpoint calcuistion. The team determined that the new calculation did not resolve the deficiency in that the calculation did not address dilution time and the offsite dose consequences

)

for that extended dilution time. The team observed that the lack of interface between offsite engineering personnel performing the calculation, onsite engineering, and operations contributed to the repeated calculation deficiencies and consequent inadequate corrective action. The interface between the offsite engineering personnel performing accident analyses and site engineering and operations personnel was identified as a weakness by Parsons and I the NRC. The NRC team reviewed your process changes to address this weakness and found them acceptable. Although it is our understanding that the new calculation was performed prior .

to the configuration control process revisions, this area requires continued management  !

attention to assure proper implementation, i The team verified

• hat your subsequent actions corrected the subject calculation and

~

. implemented chhnges that will strengthen interdisciplinary reviews of calculations and condition report closure actions. Because you had corrected the deficiency before the conclusion of the inspection that identified the inadequate corrective action, no response will be required.

Based on additional information that was provided regarding unresc!ved items (URis) identified i in inspection reports Nos. 50-336/98-201and 203, the following URis are baing evaluated for potential enforcement action in accordance to with the revised enforcement policy.

1 o URI 98-201 Failure to update the Final Safety Evaluation Report (FSAR) to describe the reduced number of Post-Accident Monitoring instrumentation channels, e URI 98-203 Failure to account for instrument inaccuracies in Auxiliary Feedwater (AFW) system tests.

e URI 98-203 Failure to have adequate procedures for operation of the turbine-driven AFW pump. The existing operating procedure did not require the pump to be declared -

inoperable if the main steam supply valve was closed.

During the inspection the team evaluated your corrective actions for the above URis and found them to be adequate.

The following issues could not be closed because of outstanding actions that require additional evaluation: .

1. . Violation No. 50-336/202-02, regarding failure to revise an operating procedure to prevent pressure spiking during Reactor Building Closed Cooling Water system pump starts. The procedure had not been revised.

. , + . .u,,; ,,, w.m*

+- * - -~=-

J v *

2. Parsons Discrepancy Report (DR) 785, regarding Main Control Board separation issues, is open pending the issuing of the FSAR Change Request (FSARCR) to describe the actual separation criteria used.

Should you have any questions or comments regarding the issues discussed in this letter, please contact Paul Narbut at (301) 415-2962.

Sincerely, Eugene V. Imbro, Director Independent Corrective Action Verification Program Associate Director for Technical Review Office of Nuclear Reactor Regulation Docket No. 50-336 cc: See next page l

i i

)

c

• e ,

. . >+-m_. 3

p G <

L ,,,

3

3. Parsons Discrepancy Report (DR) 785, regarding Main Control Board separation issues, is open pending the issuing of the FSAR Change Request (FSARCR) to describe the actual separation criteria used.

Should you have any questions or comments regarding the issues discussed in this letter, please contact Paul Narbut at (301) 415-2962.

Sincerely, . -

Original signed by

• Eugene V. Imbro, Director  !

Independent Corrective Action

Verification Program Associate Director for Technical Review Office of Nuclear Reactor Regulation Docket No. 50-336 cc: See next page DISTRIBUTION:

Docket File /PUBLIC ICAVP RF B Sheron E imbro '

J Houghton J Luehman J Andersen j P Koltay 1 S Tingen J Nakoski

' R Perch l S Dembek I

DOCUMENT NAME:A:Narbut.QK1' l

Ta vecchre a cow of this documeest, inacote in the box: "C" = Copy without attachment / enclosure *E* = Copy with attachment / enclosure *N" = No copy I- OFFICE ICAVP: C:lCAVP D:lCAVP NAME PNarbut&/V PKottay qV, - Elmbro /c:L 7 _

DATE- 03/15/99 03 4 /99 03py/99 er 1 n .,

+ v t i h.y- }

i l

u .

g. ,