ML20248M205
| ML20248M205 | |
| Person / Time | |
|---|---|
| Site: | Millstone |
| Issue date: | 06/05/1998 |
| From: | Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 1-96-019, 1-96-19, EA-97-026, EA-97-26, EA-98-204, NUDOCS 9806150146 | |
| Download: ML20248M205 (4) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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EA 98-204 EA 97-026 Mr. M. L. Bowling, Recovery Officer - Technical Services C/o Ms. Patricia Loftus, Director - Regulatory Affairs for Millstone Station NORTHEAST NUCLEAR ENERGY COMPANY P.O. Box 128 Waterford, CT 06385
SUBJECT:
NRC OFFICE OF INVESTIGATIONS REPORT NO. 1-96-019 - ALLEGED DELIBERATE VIOLATION OF TECHNICAL SPECIFICATIONS FOLLOWING A FIRE IN THE UNIT 1 DRYWELL
Dear Mr. Bowling:
This letter refers to an investigation conducted at the Millstone Nuclear Power Station by the NRC Office of Investigations (01) Field Office, Region 1. The purpose of the investigation was to determine whether two individuals deliberately violated Unit 1 Technical Specifications (TS) on June 8,1996. The investigation found that the Unit 1 Director and the on-duty Unit 1 Shift Manager deliberately violated TS 3.2.E.2. Specifically, TS 3.2.E.2 required the reactor building ventilation system to be isolated and the standby gas treatment system (SGTS) to be run until certain radiation monitors were declared operable. However, before these radiation-monitors were declared operable, the Unit 1 Shift Manager, with the approval of the Unit 1 Director, directed control room operators to secure the "B" train of the SGTS and restore normal ventilation to the Unit 1 drywell. Additionally, the Unit 1 Director involved in the decision making process did not have the requisite SRO level of training or experience necessary to fill his position, which he held for approximately 15 months. Issues associated with the fire in the Unit 1 drywell are discussed in NRC Combined Inspection Report 50-245/96-06, Section U1.01.3, and issues associated with the qualifications of the Unit 1 Director are discussed in NRC Combined Inspection Report 50-245/96-09, Section U1.06.1.
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Based on the results of this investigation, two apparent violations were identified and are O
being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy),
NUREG-1600. The first issue involves an apparent violation of Technical Specification
'y 3.2.E.2, which required the Unit i reactor building ventilation system to be isolated and the Ig y
SGTS to be run until certain radiation monitors were declared operable. The second issue involves an apparent violation of Technical Specification 6.3.1, " Facility Staff Qualifications,"
which requires that, "each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions." ANSI 18.1-1971, " Selection and Training of Nuclear Power Plant Personnel," section 4.2.1, " Plant Managers," states, the plant manager shall have acquired the experience and training normally required for examination by the Atomic Energy Commission (AEC) for a Senior Reactor Operator's license whether or not the examination is taken. The Unit Director position at Millstone is equivalent to the Plant Manager posiQn referenced by the ANSI standard.
- " O O 1 '7 9806150146 900605 1-*
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.1 Mr. M. L. Bowling 2
Based on the evidence developed during the investigation and the inspection findings discussed in the above noted NRC inspection reports, it may not be necessary to conduct a predecisional enforcement conference in order to enable the NRC to mde an enforcement
. decision. However, a Notice of Violation is not presently being issued for these apparent violations. Before the NRC makes its enforcement decision, we are providing you an opportunity to either (1) respond to the apparent violations addressed in this letter within 30 days of receipt of this letter or (2) request a predecisional enforcement conference. On June 4,1998, in a telephone discussion with me, Mr. Brothers stated that NNECO preferred not to have an enforcement conference.
Our request for a written response or a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. The purpose of our request is to allow you to provide further information, such as a basis for disputing the apparent violations or providing a common understanding of the root causes and significance of the issues, to enable the NRC to make an enforcement decision.
In addition, this is an opportunity for you to provide any information concoming your perspectives on: 1) the severity of the violations,2) the application of the factors that the L NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in eccordance with Section Vll. Your written response should be clearly marked as a " Response to Apparent Violations in Office of Investigations Report No. 1-96-019." If you choose not to contest the apparent violations, your response should also include for each apparent violation: (1) the reason for 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. Your response should be submitted under oath or affirmation and may reference or include previous docketed correspondence, if the correspondence adequately addresses the required resoonse. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a predecisional enforcement conference.
In addition, please be advised that the number and characterization of apparent violations 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.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, propnetary,' or safeguards information so that it can be placed in the PDR without redaction.
Sincere Wa e. Lanning Deputy Director of Ins ns Millstone Special Proje ice - NRR Docket No. 50-245 License No. DPR-21
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Mr. M. L. Bowling 3
. cc:
B. Kenyon, President and Chief Executive Officer - Nuclear Group M. H. Brothers, Vice President - Operations J. McElwain, Unit 1 Recovery Officer J. Streeter, Recovery Officer - Nuclear Oversight G. G. Hicks, Unit Director - Millstone Unit 3 J. A. Price, Unit Director - Millstone Unit 2 D. Amerine, Vice President - Human Services E. Harkness, Director, Unit 1 Operations J. Althouse, Manager - Nuclear Training 3.4sessment Group F. C. Rothen, Vice President, Work Services l
S. J. Sherman, Audits and Evaluation l
L. M. Cuoco, Esquire J. R. Egan, Esquire
.V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Corfrol S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN J. M. Block, Attomey, CAN
. S. P. Luxton, Citizens Regulatory Commission (CRC)
Representative T. Concannon
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E. Woollacott, Co-Chairman, NEAC l
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1 Mr. M. L. Bowling 4
Distribution:
Region i Docket Room (with coov of concurrences)
Nuclear Safety Infonnation Center (NSIC)
PUBLIC FILE CENTER, NRR (with Oriainal concurrences)
SPO Secretarial File, Region l NRC Resident inspector OE (2)
B. Jones, PIMB/ DISP W. Lanning, Deputy Director of Inspections, SPO, RI D. Serenci, PAO W. Travers, Director, SPO, NRR B. Letts, 01, RI K. Monroe, 01, RI D. Holody, ORA D. Vito, ORA (File RI-96-A-0147)
J. Durr, SPO, RI R. Urban, SPO, RI T. Walker, OE, RI B. Fewell, ORA Distribution: (VIA E-MAIL)
J. Andersen, PM, SPO, NRR M. Callahan, OCA R. Correia, NRR B. McCabe, OEDO S. Dembek, PM, SPO, NRR E. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR D. Mcdonald, PM, SPO, NRR P. McKee, Deputy Director of Licensing, SPO, NRR S. Reynolds, Chief, ICAVP Oversight, SPO, NRR D. Screnci, PAO Inspection Program Branch (IPAS)
J. Lieberman, OE (OEMAIL)
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