ML20216H713
| ML20216H713 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/11/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Luxton S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20216H717 | List: |
| References | |
| NUDOCS 9803230150 | |
| Download: ML20216H713 (7) | |
Text
aeg%
UNITED STATES y
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 0001
- g * * * '
March 11, 1998 Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton -
180 Great Neck Road Waterford, CT 06385
Dear Ms. Luxton:
I am responding to your letter of January 7,1998, to Chairman Shirley Ann Jackson of the U.S.
Nuclear Regulatory Commission (NRC), regarding your concems including: an apparent " fast track" towards a favorable vote on Millstone Unit 3 restart; the large number of Deficiency Reports (DRs) initiated by the third-party contractor and its implication on the validity of the Millstone Unit 3 Configuration Management Plan (CMP); your perception that Sargent & Lundy (S&L) is operating "... In much the same fashion as other NU contract personnel; discovering problems, and working with NU to provide recommended fixes.*; and that little apparent action
{
has been taken by the NRC staff to notify the public of the significant findings from the NRC out-of-scope system review.
With regard to the process being used by the NRC staff in providing a restart recommendation to the Commission, NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," establishes the guidelines for approving the restart of a nuclear power plant after a j
shutdown resulting frem a significant event, complex hardware problem, or one for which serious management deficiencies have been identified. The NRC staff is applying the guidelines of MC 0350 to the restart approvals of Millstone Units 1,2, and 3 because of NRC concems regarding the overall effectiveness of the licensee's management. The NRC staff has developed a Restart Assessment Plan (RAP) for each of the Millstone units to incorporate the appropriate aspects of MC 0350 and to address site-specific and unit-specific issues. The RAP consists of several major elements, related to the root causes for the decline in licensee performance, that must be completed prior to restart.
The NRC staff, consistent with the Confirmatory Order dated August 14,1996, is driven not by schedule, but by the primary task of determining whether the Millstone licensee has effectively carr;ed out a comprehensive, broad-scope program to identify and correct its weaknesses. In addition, the Commission has consistently indicated that their decisions on restart do not presuppose that any of the three plants will restart by any certain date.
You have indicated a concem with the large number of Deficiency Reports (DRs) initiated by the third-party contractor and its implication on the validity of the Millstone Unit 3 CMP. The third-party contractor has reviewed 15 of the 88 risk-significant or safety-related systems, as j
categorized by the Maintenarice Rule, in conducting its Tier 1 review at Unit 3. Additionally, i
portions of another 22 systems were reviewed as part of the Tier 2 review.
I\\
9803230150 980311 PDR ADOCK 05000423 h,
m,
O Susan Perry Luxton The large number of DRs that you have referenced are preliminary in that they have not been reviewed by NU. NU may provide additional information to the contractor that may demonstrate that the discrepar cy was: (a) previously discovered during CMP; or (b) that it is not an issue and the plant is in conformance with its licensir'g and design bases. In these two cases, the DRs are categorized respectively as "previously identified" and "nondiscrepant." NU may also agree with the contractor that the DR is a true nonconformance which was not previously identified. These are called "confirme f DRs and these are what are reported by the staff and trended. The number of confirmed DRs, as of February 27,1998, is 184 for Unit 3. Of 937 DRs issued as preliminary, as of February 27,1998, only 301 have been " closed." (" Closed DRs are those that are either " confirmed,' 'nondiscrepant," or "previously identified.") Thus far, the contractor review has confirmed six findings which involves a nonconformance with the licensing bases (Level 3). With such a small percentage of DRs closed, it is premature to draw meaningful conclusions. However, the NRC staff has developed a listing of likely or potential NRC actions corresponding to each significance level, as discussed in the January 30,1998, letters to the Connecticut Nuclear Energy Advisory Council, NU, and the ICAVP contractors.
The NRC's existing process for performing these reviews, relying on established regulatory requirements and risk insights, provides for a broad consideration of possible ICAVP findings and is consistent in its use of the licensing and design bases as the regulatory standard for measuring the licensee's performance.
With regard to confirmed Level 4 findings, these findings involve minor errors that do not result in nonconformance. These findings, none'heless, are being evaluated by the NRC staff to identify any possible trends which should be further exam'ned. This assessment will continue through the completion of the ICAVP program.
j Your perception that S&L is operating in much the same fashion as other NU contract personnel, discovering problems, and working with NU to provide recommended fixes, is incorrect. The contractors have not been working with the licensee to develop solutions.
Rather, they review colutions developed by NU for technical acceptability, to verify the solution is in conformance with the licensing and design bases, and appropriately addresses the identified problem. In order to assure ladependence of the ICAVP contractor reviews, the NRC established a communications protocol that is included in the NRC approved ICAVP audit plan.
Additionally, the Connecticut Nuclear Energy Advisory Council (NEAC) has been observing the interactions among the ICAVP contractors, NU, and the NRC.
With regard to the actions that have been taken by the NRC staff to notify the public of the significance of the findings from the NRC out-of-scope system review, the following information is provided. As you have indicated in your letter, the NRC staff identified and discussed this issue at a meeting with the public on September 24,1997. This preliminary finding (ICAVP Significance Level 1) was also discussed at the public inspection exit meeting on September 24,1997, and a public Commission meeting held December 12,1997. The Commission was informed at that time that, given the significance of the issue, a pre-decisional enforcement conference with the licensee would take place in January 1998. On January 13, 1998, a public predecisional enforcement conference regarding this preliminary Level 1 finding was held at the M'listone site. During this enforcement conference, the licensee provided the results of its analysis and scale model testing, and their conclusion that the charging and safety injection pumps would be capable of performing their design bases functions during the
f~
s Susan Perry Luxton l l
postulated accident conditions. Based on the information provided by the licensee, the staff i
has preliminarily determined this issue to be an ICAVP Significance Level 3 finding. A final l
NRC determination on this issue will be made following completion of the staffs evaluation.
l Therefore, the NRC staff feels that this preliminary Level 1 finding resulting from the NRC out-l of-scope team inspection was adequately discussed at several public meetings, consistent with our continuing goal of open and honest public communication.
l l
l trust this information is responsive to your concerns.
I Sincerely
- Orig!nalsignedby i
SamuelJ. Collins Samuel J. Collins, Director Office of Nuclear Reactor Regulation Docket No. 50-423 I
cc: See next page Distribution:
Docket File (w/originalincoming)
EDO r/f l
l PUBLIC EDO -G980011 SPO R/F NRR Mailroom (w/ incoming)
WTravers Elmbro l
PMcKee PEselgroth SReynolds l
Collins /Miraglia RZimmerman BSheron JRoe JCallan, EDO AThadani, DEDO HThompson, DEDO PNorry, DEDO l
JBlaha, EDO SBums, OGC HMiller, RI l
JLieberman, OE KCyr, OGC DOCUMENT NAME:A:\\luxton.ltr (*see previous concurrence)
To receive a copy of this document, indicate in the box "c" copy wio attach /enci"E" copy wInttach/enci"N" h
/
OFFICE SPO:TA SPO:D NRR:D EDO OCM 1
v NAME RPerchtsr WTravers SCollins JCallan Is/SCollins DATE 2/5/98*
215/98*
2/11/98*
2/14198*
'ft')/98 M98 OFFICIAL RECORD COPY YY#
a l
Northeast Nuclear En'ergy Company Millstone Nuclear Power Station UnR3 i
cc:
Lillian M. Cuoco, Esquire Mr. William D. Meinert Senior Nuclear Counsel Nuclear Engineer f
Northeast Utilities Service Company Massachusetts Municipal Wholesale P. O. Box 270 Electric Company H:rtford, CT 06141-0270 P.O. Box 426 Ludlow, MA 01056 Mr. Kevin T. A. McCarthy, Director M:nitoring and Radiation Division Joseph R. Egan, Esquire Department of Environmental Protection Egan & Associates, P.C.
79 Elm Street 2300 N Street, NW Hartford, CT 06106-5127 Washington, DC 20037 Regional Administrator, Region 1 Mr. F. C. Rothen U.S. Nuclear Regulatory Commission Vice President -Work Services 475 Allendale Road Northeast Utilities Service Company King of Prussia, PA 19406 P. O. Box 128 Waterford, CT 06385 First Selectmen Town of Waterford Ernest C. Hadley, Esquire H:ll of Records 1040 B Main Street 200 Boston Post Road P.O. Box 549 W;terford, CT 06385 West Wareham, MA 02576 Mr. Wayne D. Lanning Mr. John Buckingham D:puty 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 Vice President - Operations Manager, Nuclear Investments and N:rtheast Nuclear Energy Company Administration P.O. Box 128 New England Power Company W;terford, CT 06385 25 Research Drive Westborough, MA 01582 Mr. M. R. Scully, Executive Director Connecticut Municipal Electric Mr. D. M. Goebel Energy Cooperative Vice President - Nuclear Oversight 30 Stott Avenue Northeast Utilities Service Company Norwich, CT'06360 P. O. Box 128 Waterford, CT 06385 Mr. David Amerine Vice President - Nuclear Engineering cnd Support N:rtheast Utilities Service Company P. O. Box 128 Waterford, CT 06385
I j
~ Northeast Nuclear Energy Company cc:
Mr. B. D. Kenyon Deborah Katz, President Chief Nuclear Officer-Millstone Citizens Awareness Network Northeast Nuclear Energy Company P.O. Box 83 P.O. Box 128 Shelburne Falls, MA 03170 Waterford, CT 06385 Senior Resident inspector Mr. Daniel L. Curry Millstone Nuclear Power Station Project Director c/s U.S. Nuclear Regulatory Commission Parsons Power Group inc.
P.O. Box 513 2675 Morgantown Road Nirntic, CT 06357 Reading, PA 1g607 Mr. Allan Johanson, Assistant Director Mr. Don Schopfer Office of Policy and Management Verification Team Manager Policy Development and Planning Sargent & Lundy Division 55 E. Monroe Street 450 Capitol Avenue - MS# 52ERN Chicago,IL 60603 P. O. Box 341441 Hartford, CT 06134-1441 Mr. J. A. Price Unit Director-Millstone Unit 2 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. J. P. McElwain The Honorable Terry Concannon Vice President (Acting) - Millstone 3 Co-Chair Northeast Nuclear Energy Company Nuclear Energy Advisory Council P.O. Box 128 Room 4035 Waterford, CT 06385 Legislative Office Building Capitol Avenue Mr. G. D. Hicks Hartford, CT 06106 Unit Director-Millstone Unit 3 Northeast Nuclear Energy Company Legislative Office Building P.O. Box 128 Captiol Avenue Waterford, CT 06385 Hartford, CT 06106 Little Harbor Consultants, Inc.
Mr. Evan W. Woollacott Millstone -ITPOP Project Office Co-Chair P.O. Box 0630 Nuclear Energy Advisory Council Niantic, CT 06134-1441 12.8 Terry's Plain Road Simsbury, CT 06070
..m.
ACTION EDO Principal Correspondence Control FROMs DUE: 01/28/98 EDO CONTROL: G980011 DOC DT: 01/07/98 FINAL REPLY:
Su On Perry Luxton Citizens Regulatory. Commission TO:
Chairman Jackson FOR SIGNATURE OF :
MILLSTONE UNIT 3, RESTART Callan Thadani Thompson Norry Blaha Burns
- DATE: 01/14/98-Miller, RI Lieberman, OE
)
ASSIGNED TO:
CONTACT:
Cyr, OGC
_NRR Collins SPECIAL INSTRUCTIONS OR REMARKS:
NRR ACTION: SP0: Travers i
NRR RF.CEIVED: January 14, 1998 ACTIOJ NRR ROUTING: Collins /Miraglia Zimmerman DUE TO NRR DIRECTOR'S OFFi ~ E 1
Sheron i
Roe BY I OS 98 l
Travers NRR Mailroom f
g i
J t.
i.
-OFFICE OF THE SECRETARY CORRESPONDENCE CONTRCT, TICKET PAPER NUMBER:
CRC-98-0013 LOGGING DATE: Jan 12 98 ACTION OFFICE:
EDO AUTHOR:
SUSAN P LUXTON AFFILIATION:
CONNECTICUT ADDRESSEE:
CHAIRMAN JACKSON LETTER DATE:
Jan 7 98 FILE CODE: IDR 5 MILLSTONE
SUBJECT:
MILLSTONE ACTICN:
Direct Reply DISTRIBUTION:
CHAIRMAN, SECY, RF SPECIAL HANDLING: SECY TO ACK CONSTITUENT:
NOTES:
OCM #11543 DATE DUE:
Jan 28 98 SIGNATURE:
DATE SIGNED:
AFFILIATION:
)
i l
)
1 1
j..
l EDO -- G980011 l
]