ML20216G078

Forwards Tier 2/Tier 3 Special Insp Rept 50-423/97-209 on 971027-980128 & Nov.Insp One Part of Ongoing,Multifaceted, NRC Effor to Evaluate Sargent & Lundy Conduct of Independent Corrective Action Verification Program

ML20216G078
Person / Time
Site:	Millstone
Issue date:	04/01/1998
From:	Imbro E NRC
To:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20216G083	List: IR 05000423/1997209 ML20216G078 ML20216G092
References
50-423-97-209, EA-98-084, EA-98-085, EA-98-84, EA-98-85, NUDOCS 9804170334
Download: ML20216G078 (4)

See also: IR 05000423/1997209

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Mr. Martin L. Bowling

Recovery ONicer- Millstone Unit 2

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Director- Regulatory Affairs

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Northeast Nuclear Energy Comp, any

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P.O. Box 126

Waterford, CT 06385

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SUBJECT:

NOTICE OF VIOLATION AND INDEPENDENT CORRECTIVE ACTION

VERIFICATION PROGRAM TIER 2/ TIER 3 SPECIAL INSPECTION OF

MILLSTONE UNIT 3 (NRC INSPECTION REPORT NO. 50-423/97-209)

Dear Mr. Bowling:

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During the period from October 27,1997, to January 28,1998, a team from the U.S. Nuclear

Regulatory Commission's (NRC') Special Projects Office, Office of Nuclear Reactor Regulation

in accordance with guidelines outlined in SECY-97-003, " Millstone Restart Review Process,"

performed a Tier 2/ Tier 3 special inspection of your Millstone Unit 3 facility. This inspection was

one part of an ongoing, multifaceted NRC effort to evaluate Sargent and Lundy's (S&L)

conduct of the Independent Corrective Action Verification Program (ICAVP) and the

effectiveness of your configuration management plan. The results of the ICAVP will provide

insights that will be used by the NRC in assessing the effectiveness of your configuration

management plan and to determine your readiness for the restart of Unit 3. Using appropriate

risk-insights, the team selected key change processes and a large sample of recent changes t

the facility and developed a functional inspection of the lossef-coolant accident and steam

generator tube rupture accident mitigation systems. The selected change processes were

evaluated to determine if they met regulatory requirements and were capable of maintaining th

facilities design and licensing bases. A large sample of recent changes made to the facility

were evaluated to determine the effectiveness of your ongoing configuration management

efforts. The review of selected accident mitigation systems was to assess S&L's Tier 2 review

and verify the ability of these systems to perform their intended safety functions during

postulated accidents, and to evaluate if the accident analysis assumptions were properly

translated into instructions, procedures, and drawings.

The NRC determined that S&L successfully implemented the Tier 2 verification of critical d

characteristics and the Tier 3 evaluation of change processes controlling plant configuration in

accordance with the NRC-approved audit plan and applicable project instructions. Based on

observations during the inspection, the team requested that S&L expand their review efforts in

several areas including instrumentation and control surveillances, operations and verification of

dose assessment calculations. The expanded reviews did not result in additional findings.

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Mr. M.L. Bowling

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Based on the results of this inspection, apparent violations were identified and are being

considered for escalated enforcement action in accordance with NUREG-1600, " General

Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy).

The first apparent violation represented a failure of your configuration management plan (CMP)

to identify inadequacies in your program to reduce coolant leakage sources outside

containment following a loss-of-coolant accident, which was required by plant Technical Specification 6.8.4. The second apparent violation involved inadequate corrective actions

following identification of a potential single-failure vulnerability of the control room ventilation

during the CMP.' The examples in the second apparent violation and other team' findings

indicated that your dose assessment group did not fully appreciate the regulatory significance of

maintaining the design and licensing bases.

The ciircumstances surrounding these apparent violations, the significance of the issues, and

the need for lasting and effective corrective action were discussed with members of your staff at

the inspection exit meeting on January 28,1998. As a result,it may not be necessary to

conduct a predecisional enforcement conference in order to enable the NRC to make an

enforcement decision. However, a Notice of Violation is not presently being issued for these

inspection findings. Before the NRC makes its enforcement decision, we are providing you an

opportunity to either (1) respond to the apparent violations addressed in this inspection report

within 30 days of the date of this letter, or (2) request a predecisional enforcement conference.

Please contact me within 7 days of the date of this letter at (301) 415-2951 to notify the NRC of

yourintended response.

Your response should be clearly marked as a " Response to Apparent Vdations in Inspection

Report No. 50423/9-209," and should include for each apparent violation (1) the reason for the

apparent violation, or, if contested, the basis for disputing the apparent violation, (2) the

corrective steps that have been taken and the results achieved, (3) the corrective steps that will

be taken to avoid further violations, and (4) the date when full compliance will be achieved.

In addition, please be advised that the number and charactetization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review. You

will be advised by separate correspondence of the results of our deliberations on this matter.

During this inspection a number of issues, in addition to the apparent violations discussed

above, were identified that have been cited as violations in the enclosed Notice of Vdation.

Please note that you are 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.

The violations and apparent violations contained in this report have been categorized as being

_ equivalent to ICAVP significance level 3 findings. ICAVP level 3 findings have been defined by

the NRC to occur if a system is outside its licensing and design bases while still able to perform

its intended funchon. In a January 30,1998, letter to you from the Director of the Special

Projects Office the NRC's criteria for determining whether to expand the scope of the ICAVP

was described. An important factor in making this determination is the NRC's assessment of

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Mr. M.L. Bowling

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the effectiveness of the <arrective actions taken to address the finding. Your conective actions

taken in response to these findings will be assessed by the NRC as part of our review of the

implementation of ICAVP-related corrective actions.

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- As noted earlier, this inspection was part of the NRC's ongoing assessment of the effectiveness

of your CMP and S&L's ICAVP. The findings of this inspection will be combined with the results

of other NRC inspections to make an overall determination of the restart readiness of Unit 3 and

your configuration management practices. However, the results from this inspection provide a

measure of confidence that the Unit 3 accident mitigation systems are adequately designed and

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tested and will perfonn as assumed in accident analyses.

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!n accordance with Title 10 of the Code of federa/ Regulations, 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 concoming the enclosed inspection report, please contact the

project manager, Mr. James Andersen at (301) 415-1437, or Mr. Peter Kottay (301) 415-2957.

Sincerely,

Eugene V. Imbro, Deputy Director

ICAVP Oversight

Special Projects Office

Office of Nuclear Reactor Regulation

Docket No. 50-423

Enclosures:

1. Notice of Violation

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2. Inspection Report 50-423/97-206

cc w/ enclosures: see next page

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Mr. M. L Bowling

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oc w/ enclosures:

M. Brothers, Vice President - Millstone, Unit 3

J. Streeter, Vice President, Nuclear Oversight

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J. Thayer, Recovery ONicer, Nuclear Engineering and Support

P. Hinnenkamp, Director, Unit Operations

F. Rothen, Vice President, Work Services

J. Stankiewicz, Training Recovery Manager

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- R. Johannes, Director, Nuclear Training

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L. Cuoco, Esquire

J.~ Egan, Esquire

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V. Juliano, Waterford Library

J. Buckingham, Department of Public Utility Control

S. Comley, Wie The Peqple

State of Connecticut SLO Designee

D. Katz, Citizens Awareness Network (CAN)

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R. Bassilakis, CAN

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J. Block, Esquire, CAN

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S. Luxton, Citizens Regulatory Commission (CRC)

Representative T. Concannon

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E. Woollacott, Co Chairman, Nuclear Energy Advisory Council

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