ML20237C128
| ML20237C128 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/13/1998 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-245-98-206, 50-336-98-206, 50-423-98-206, NUDOCS 9808200228 | |
| Download: ML20237C128 (3) | |
See also: IR 05000245/1998206
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August 13,1998
Mr. M. L. Bowling, Recovery Officer - Technical Services
C/o Ms. P. A. Loftus, Director - Regulatory
Affairs for Millstone Station
NORTHEAST NUCLEAR ENERGY COMPANY
PO Box 128
Waterford, CT 06385
SUBJECT:
NRC COMBINED INSPECTION 50-245/98-206,50-336/98-206,50-423/98-
206 - REPLY
Dear Mr. Bowling:
This letter refers to your June 26,1998 correspondence, in response to our May 26,1998
letter.
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Thank you for informing'us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
.Your cooperation with us is appreciated.
Sincerely,
Olginal Signed By: R. J. Urban, for:
Jacque P. Durr, Chief
Inspections Branch
Millstone inspection
Docket Nos. 50-245; 50-336; 50-423
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B. Kenyon, President and Chief Executive Officer - Nuclear Group
M. H. Brothers, Vice President - Operations
J. McElwain, Recovery Officer - Millstone Ur' 2
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- J. Streeter, Recovery Officer - Nuclear Oversight
P. D. Hinnenkamp, Director - Unit 3
' J. A. Price, Director - Unit 2
D. Amerine, Vice President - Human Services
E. Harkness, Director, Unit 1 Operations
J. Althouse, Manager - Nuclear Training Assessment Group
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F. C. Rothen, Vice President, Work Services
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J. Cantrell, Director - Nuclear Training (CT)
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S. J. Sherman, Audits and Evaluation
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cc: w/ copy of Licensee's Response Letter
L L. M. Cuoco, Esquire
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J, R. Egan, Esquire
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V. Juliano, Waterford Library
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J. Buckingham, Department of Public Utility Control
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S. B. Comley, We The People
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' State of Connecticut SLO Designee
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D.' Katz, Citizens Awareness Network (CAN)
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R. Bassilakis, CAN
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~ J. M. Block, Attorney, CAN
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S. P. Luxton, Citizens Regulatory Commission (CRC)
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Representative T. Concannon
E. Woollacott, Co-Chairma 1, NEAC
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Distribution w/cv of licensee response letter:
Region i Docket Room (with sney of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
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FILE CENTER, NRR (with Oriainal concurrences)
SPO Secretarial File, Region i
NRC Resident inspector
B. Jones, PIMB/ DISP
W. Lanning, Deputy Director of Inspections,' SPO, RI
D. Screnci, PAO:
H. Miller, Regional Administrator, RI
M. Callahan, OCA
R. Correia, NRR
B. McCabe, OEDO
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. E. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR
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P. McKee, Deputy Director of Licensing, SPO, NRR
S. Reynolds, Chief, ICAVP Oversight, SPO, NRR
inspection Program Branch (IPAS)
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DOCUMENT NAME: 1:\\ BRANCH 6\\REPLYLTR\\98 206
- To rxelve a copy of this document, indicate in the box:
"C" = Copy without attachment / enclosure
"E" =
Copy with attachment / enclosure
"N" = No copy
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OFFICE
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OFFICIAL RECORD COPY
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Northeast
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Nuclear Energy
waistone Nudar Power Station
Northeast Nuclear Energy Company
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P.o. Box 128
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Waterford, Cr 06335-0128
(860) 447 1791
l'an (860) 444-4277
"Ihe Norticaat Utilities System
'11 ? 6 F "
Docket No. 50-423
B17161
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Millstone Nuclear Power Station Unit No. 3
Response to a Notice of Violation
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Nuclear Regulatory Commission Combined Inspection Report
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50-245/98-206:50-336/98-206:50-423/98-206
By letter dated May 26, 1998 the Nuclear Regulatory Commission Special Projects
Office transmitted the results of the above referenced inspection. The letter included a
Notice of Violation citing three areas where NNECo's activities were not in compliance
with Nuclear Regulatory Commission regulations. Item "A" of the Notice of Violation
pertains to Millstone Unit 2 and will be addressed in separate correspondence. Items
"B" and "C" of the Notice of Violation pertain to Millstone Unit 3. A correction to item "B"
was provided by the NRC on June 15,1998. This correction removed two of the three
examples cited in the original letter on the basis that enforcement discretion had
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previously been exercised.
NNECo's response to items "B" and "C" of the Notice of Violation is provided in
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Attachment 1 to this letter.
Attachment 2 provides a summary of NNECo's
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commitments contained in this submittal.
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B17161\\Page 2.
Should you have any questions regarding the information contained herein, please
contact Mr. David A. Smith at (860) 437-5840.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
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Martin L. Bowling, J5/
Recovery Officer - Technical Services .
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. Attachments (2)
cc: H. J. Miller, Region l Administrator
W. D. Lanning, Deputy Director, Inspections, Special Projects Office
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
E. V. Imbro, Deputy Director, ICAVP Oversight, Special Projects Office
S. A. Reynolds, Branch Chief, ICAVP Oversight, Special Projects Office
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Docket No. 50-423
B17161
Attachment 1
Millstone Nuclear Power Station Unit No. 3
Response to a Notice of Violation
Nuclear Regulatory Commission Combined Inspection Report
50-245/98-206:50-336/98-206:50-423/98-206
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B17161\\ Attachment 1\\Page 2
Nuclear Reaulatory Commission Citation "B" (50-423/98-206-02)
Restatement of the Violation
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10 CFR 50.49 (a) requires each licensee to establish a program for qualifying the
electric equipment important to safety (Millstone Unit 3 EQ program) as defined in 10
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CFR 50.49 (b).10 CFR 50.49 (b) included nonsafety-related electric equipment whose
failure under postulated environmental conditions could prevent satisfactory
accomplishment of safety functions specified in subparagraphs (i) through (iii) of section
(b) (1) of 10 CFR 50.49.
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Contrary to the above, nonsafety-related electrical equipment whose failure could
prevent the accomplishment of safety functions was not qualified as listed in the
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following examples:
1.
As of February 10, 1998, there were 21 nonsafety-related solenoid operated
valves (SOV) in the high pressure and low pressure safety injection systems and
four nonsafety-related SOVs in the reactor coolant system (RCS), and their
associated cables whose failure under postulated environmental conditions could
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prevent satisfactory accomplishment
of safety functions
specified
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subparagraphs (i) through (iii) of section (b)(1) of 10 CFR 50.49, that were not
included in the Millstone Unit 3 EQ program. (This violation was identified by the
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NRC, except for the four SOVs in the RCS system.)
NNECo's Response
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NNECo does not dispute the violation.
Reason for the Violation
The cause of this condition is attributed to misinterpretation of the requirements of 10
- CFR 50.49(d) relating to the required listing of equipment important to safety (i.e.,
Environmental Qualification Master List (EOML)). The decision to not place the 21
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Solenoid Operated Valves (SOV) on the EQML was based on a determination that the
SOV failure modes leading to potential mispositioning were not credible.
The potential for the 21 Solencid Operated Valves (SOV) to disposition as a result of
post-accident environrnental conditions was identified by NNECO on September 10,
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1996 (Ref: Condition Report M3-96-0745) as a result of reviews being conducted under
the Millstone Unit 3 Configuration Management Plan. Engineering Report M3-ERP-97-
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008 documented the results of NNECo's follow-up assessment of 116 safety related air
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U.S. Nuclear Regulatwy Commission
B17161\\ Attachment 1\\Page 3
operated and solenoid valves with non-safety related control circuits. In addition to the
21 valves previously identified, this report identified 23 other valves in various safety
related systems as requiring further qualification assessment. NNECo reported the
original condition and the results of the follow-up investigation to the NRC in Licensee
Event Report 423/96-036-00, dated October 25,1996 and its supplements dated April
18 and July 25,1997. Final disposition for these 44 valves and their associated control
circuits was evaluated under Condition Report M3-97-0742 dated March 7,1997.
Design Changes were implemented to correct the various physical and programmatic
deficiencies identified in Condition Report M3-97-0742.
With regards to the original 21 SOV's and their associated non-safety related control
circuits, components with unacceptable failure consequences (i.e., limit switches) were
upgraded and added to the EQML. The failure modes of the SOV's were evaluated
and determined to be not credible. This determination was based on the valves being
identical to valves currently qualified under the Electrical Equipment Qualification
Program with a 40 year qualified life. The physical arrangement of the SOV's was also
evaluated to ensure that the solenoid housings would not be subject to moisture
collection following an accident. As a result of this evaluation, the classification of the
SOV's was upgraded to Quality Assurance Category 1 to ensure that component
replacement / maintenance activities would maintain the integrity of the SOV's over the
life of the facility. Based on the failure analysis results and the upgrade in classification
of the SOV's, NNECo determined that adding the SOV's to the EQML was not required.
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Corrective Actions and Results Achieved
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Design Change Notice DM3-00-0153-98 incorporated the SOV's into the EQML.
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Corrective Actions to Avoid Future Violations
No additional actions are planned.
Date When Full Compliance Will Be Achieved
Compliance has been restored.
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B17161\\ Attachment 1\\Page 4
Nuclear Reaulatory Commission Citation "C" (50-423/98-206-04)
Restatement of the Violation
10 CFR 50, Appendix B Criterion XVI Corrective Action requires, in part, that measures
shall be established to assure that conditions adverse to quality such as
nonconformances are promptly identified and corrected.
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Contrary to the above, from April 1995 to November 1996, a nonconformance with an
assumption of the accident analysis for a steam generator tube rupture was not
promptly corrected. Operating crews at Millstone 3 were unable to complete actions in
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the Emergency Operating Procedures to isolate a steam generator on tube rupture.
This is a Saverity Level IV Violation (Supplement 1) for Docket No. 50-423.
NNECo's Response
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NNECo agrees with the violation.
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Reason for the Violation
This condition is historical in nature in that the cause is attributed to weaknesses in
NNECo's program for iderttification and tracking of regulatory commitments. NNECo's
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commitment to revalidate operator response times (Ref: B15019, dated November 7,
1994) was not adequately tracked at the time it was transmitted to the NRC. A
subsequent transition to a new commitment tracking database did not reconcile the
discrepancy and the associated tracking item was closed without proper
documentation.
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Corrective Actions and Results Achieved
The re.sults of NNECo's revalidation of operator response times for Steam Generator
Tube Rupture event scenarios were provided to the NRC on December 12,1996 (Ref:
816020).
A review of Millstone Unit 3 commitments has been completed as part of the current
recovery process. This review was conducted in accordance with Project Instruction
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No. 6, " Licensing Reviews." The results of this review provide reasonable assurance
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that commitments related to restoration or maintenance of the Millstone Unit 3 licensing
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basis have been adequately identified, classified and validated.
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Corrective Actions to Avoid Future Violations
No additional actions are planned.
Date When Full Compliance Will Be Achieved
Millstone Unit 3 is in full compliance.
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B17161
Attachment 2
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Millstone Nuclear Power Station Unit No. 3
Response to a Notice of Violation
Nuclear Regulatory Commission Combined Inspection Report
50-245/98-206:50-336/98-206:50-423/98-206
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June 1998
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B17161\\ Attachment 2\\Page 2
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List of Regulatory Commitments
The following table identifies those actions committed to by NNECo in this document.
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Please notify the Manager - Millstone Unit No. 3 Regulatory Compliance at the
Millstone Nuclear Power Station Unit No. 3 of any questions regarding this document or
any associated regulatory commitments.
Commitment
Description
Committed Date
Number
or Outage
None
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