ML20236L853
| ML20236L853 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/22/1998 |
| From: | Travers W NRC (Affiliation Not Assigned) |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| GL-91-18, NUDOCS 9807130204 | |
| Download: ML20236L853 (1) | |
Text
_ _ _ _ _ _. _ _ _ _.
June 22,1998 MEMORANDUM TO:
L. Joseph Callan Executive Director for Operations THRU:
Samuel J. Collins, Director Office of Nuclear Reactor Regulation pp 3 FROM:
William D. Travers, Director Special Projects Office
SUBJECT:
DEFERRED LEVEL 3 DISCREPANCY REPORT lt has been the NRC's expectation that Northeast Nuclear Energy Company (NNECO), as a j
condition of the requirements of the August 14,1996, Confirmatory Order establishing the requirement for an Independent Corrective Action Verification Program (ICAVP), would complete the corrective actions associated with each Level 3 discrepancy report (DR) identified by the process; This has been NNECO's stated expectation as well. : While a formal commitment was never made, this was a clear expectation stated by the licensee in a number of interactions with the staff, including recent Commission meetings. As noted in the attached i
letter from the licensee dated June 15,1998, NNECO has identified one Level 3 DR that it does not expect to complete its corrective actions by the time it anticipates being ready to restart Unit 3. The issue is related to qualification of the drain lines and valves associated with charcoal filters in the supplemental leak collection and release system (SLCRS) and the auxiliary building ventilation system (ABVS). The piping and valves were originally purchased j
. as nonsafety-related components and were analyzed and installed to withstand the safe 9 g
shutdown earthquake.' The corrective actions include full seismic qualification of the SLCRS and ABVS drain piping to Seismic Category 1 requirements and dedication'of the commercial 4
grade components. It is not anticipated that any physical change to the plant will be necessary 4
as a result of the corrective actions.
As noted in the licensee's letter, an operability determination was performed, which supports operation. The staff has been following this issue c!osely for some time. The staff agrees with the licensee's operability determination and that performing the analysis to qualify these drain lines and valves is not an issue that should delay restart, as it is of minimal safety significance.
This approach is within the guidance of Revision 1 to Generic Letter 91-18.
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The licensee commits in its letter to complete its corrective actions by July 31,1998, but they.
L are endeavoring to complete the actions in a much shorter time frame so that the issue can be resolved and all ICAVP issues closed out. We intend to formally docket our position on this issue by responding to the licensee's letter.
Attachtent: As stated Distribution
- i Docket File l
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WTravers WDean 1
DOCUMENT NAME:P: level 3.Itd (*see previous concurrence) j
' Ti receive a copy of this document indcote in the boa: *C" = Copy without attachme nclosur "E* = Copy with attachment / enclosure
'N' = No copy 1
0FFICE TA/SP0 D:NRR rJA D:6P V l
NAME.
WDean WTravers
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j DATE 06/18/98*
06/18/98*
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06/25/98 l
OFFI$IAL RECORD COPY
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9907130204 990622 I
PDR ADOCK 05000423 P
JUH-18-98 THU 04:03 PM HUCLEAR LICENSING SVCS, FAX N0. 860 440 2001 P.02 s
Northeast Nuclear Energy Rge Twy Rd. % Wh waW c"r Mm u,n Nu n,,s s.,*.an Nud.ar Fg Casspany P.o.uns124 v..-% er um4m (660) 447-1791 F.a (860) 444 4277
'N Nonh.an IMhdu spesus I
i JUN I 5 1998 l
l Docket No. 50-423 B17326 1
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 3 independent Corrective Action Verification Program Disposition of Confirmed Level 3 Discrepancy Reports and SucoleIDentarv Response to April 16.199710 CFR 50.541f) Information Reauest in a letter dated April 20,1998,U1 the Nuclear Regulatory. Commission Staff established an expectation that corrective actions required to restore or re establish design and licensing basis requirements for discrepancies identified as part of the independent Corrective Action Verification Program (ICAVP) in all confirmed Level 3 and higher Discrepa.wy Reports (DRs) would be completed prior to restart.
This letter provides Northeast Nuclear Energy Company's (NNECO's) current status in completing corrective actions for the confirmed Level 3 DRs resulting from the Unit 3 ICAVP.
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QverallICAVP Results The restart required corrective actions for 20 of the 22 confirmed Level 3 DRs have been completed, reviewed by Sargent and Lundy, and have been inspected by the NRC as part of the on-going corrective action inspection.
Required corrective actions and Sargent and Lundy reviews for the remaining two (2) DRs are in progress.
~
E. Im5ro, U.S. Nuclear Regulatory Commission letter to M. L Bowling IU dated April 20,1998,
- u..m aa u.o g odes G=9
JUN-18-98 THU 04'04 Pli NUCl. EAR 1.lCENSING SVCS, FAX NO. 860 440 2091 P,03
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U.S. Nuclear Regulatory Commission s
B17326 \\Page 2 DR-MP3-0670 The restart req'Jlred Corrective actions are complete. The final corrective action results were provided to Sargent and Lundy on June 15,1998 for their review.
DR-MP3-0328 DR-MP3-0328 changed status from " unresolved" to a " confirmed" Level 3 DR on June 9,1998. This DR had been in an " unresolved status" for approximately one month and has been the subject of extensive technical discussions with Sargent and Lundy, the NRC Special Project Office, and NNECO in accordance with the ICAVP communications protocol. The corrective action plan has been submitted to Sargent and Lundy for their review.
However, completion of corrective actions by NNECO and subsequent review by Sargent and Lundy will not be completed prior to NNECO's current forecast of readiness for Mode 2.-
NNECO is committed to completing the corrective actions by July 31,1998 and will verbally advise the NRC Staff when the corrective actions are complete.
In accordance with station procedures, and current regulatory guidance, an W
operability determination was performed for DR-MP3-0328. The results of this determination supports operation of Millstone Unit 3 in Modes 1,2,3, and 4 with the identified discrepancy. It should also be noted that there are no physical plant modifications other than the possibility of equipment retagging associated with these corrective actions.
Aeolication of 50.54(f) Deferral Criteria i
The methodology described in NNECO's responses
, to the NRC's April 16, W "I 199710 CFR 50.54(f)N request was applied to the final corrective action plan l
associated with DR-MP3-0328. Applying the deferral process and rationale resulted in the items in the corrective action plan being categorized as required for restart.
121 00 MP3-076 98 W
N. S. Carns letter to U. S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station. Units Nos.1,2, and 3 initial Information Submittal Regarding 10CFR50.54(f) Information Request," dated May 29,1997, B16488.
W B. D. Kenyon letter t-) U. S. Nuclear Regulatory Commission, " Millstone Nuclear
- Power Station, Unit No. 3 Update Submittal Regarding NRC 10 CFR 50.54(f)
Information Request," dated January 9,1998, 816862.
m S. J. Collins, U.S. Nuclear Regulatory Commission letter to N. S. Carns (NNECO),
dated April 16,1997, l
JUN-18-98 THU 04:04 PM HUCLEAR LICENSlHG SVCS.
FAX NO. 860 440 2091 P.04 U.S. Nuclear Regulatory Commission k
B17326 \\Page 3 4
Therefore, this letter is also a supplemental response to the April 10 CFR 50.54(f) Information Request, item 4 which requires that any resta 16, 1997 required corrective actions be completed or dispositioned prior to entry int Mode 2.
The corrective actions associated.with DR MP3-0328 will not completed prior to restart. provides a table of the regulatory commitments made by NNECO l
in this letter, if there are questions concerning the information contained in this i
letter, please contact Mr. Richard T. Laudenat at (860) 440-5248.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
Bruce D. Kenyon l
President and Chief Executive Officer BY:
Martin L Bowling, Jr.
V Recovery Officer - Technical Services Sworn to and subscribed before me this /[ day of P^T.1998
-Mm b[w y
Notary Pubtl5 My Commission expires BN9 t/./2#0/
ce; See page 4
JUN-18-98 THU 04:04 PM NUCl. EAR 1.10ENSING SVCS.
FAX NO 860 440 2091 P.05 U.S. Nuclear Regulatory Commission B17326 \\Page 4 cc:
H. J. Miller, Region i Administrator J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 W. D. Travers, Ph.D, Director, Special Projects Office P. F. McKee, Deputy Director of Licensing, Special Projects Office W. S. Lanning, Deputy Director of Inspections, Special Projects Office J. P. Durr, Branch Chief, inspections, Special Projects Office E. V. Imbro Deputy Director of ICAVP, Special Projects Office S. A. Reynolds, Branch Chief, ICAVP Oversight, Special Projects Office D. K. Schopfer - Sargent & Lundy D. L. Curry - Parsons Power Group I
JUN-18-98 THU 04:05 PM NUCLEAR LICENSING SVCS.
FAX NO. 860 440 2091 P.06 Docket No. 50-423 B_17326 Attachment i
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Millstone Nuclear Power Station, Unit No. 3 Regulatory Commitments June 1998 i-t-
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U.S. Nuctcr Rrguttory Commission
,. B17326\\ Attachment itPage 1 o
Attachment List of Regulatory Commitments The following table identifies those actions committed to by NNEC NNECO. Please notify the Manager - Regulato Power Station Unit No. 3 of any questions regarding this document o regulatory commitments.
Regulatory Commitment Committed Date or Outage Complete corrective actions to address DR-MP3-0328, and verbally advise the NRC July 31,1998 Staff when the corrective actions are complete.
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