ML110690794

Summary of Meeting with Dominion Nuclear Connecticut, Inc. Discussing Millstone Power Station, Units 2 and 3 Licensing Activities

ML110690794
Person / Time
Site:	Millstone
Issue date:	05/10/2011
From:	John Hughey Plant Licensing Branch 1
To:
Sandeers, Carleen, NRR/DORL, 415-1603
Shared Package
ml110690723	List: ML110690794
References
Download: ML110690794 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 10, 2011 LICENSEE: DOMINION NUCLEAR CONNECTICUT, INC.

FACILITY: MILLSTONE POWER STATION, UNIT NOS. 2 AND 3

SUMMARY

OF FEBRUARY 15, 2011, MEETING WITH DOMINION NUCLEAR CONNECTICUT, INC., DISCUSSING MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 LICENSING ACTIVITIES On February 15, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Dominion Nuclear Connecticut, Inc.

(DNC or the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss licensing activities at Millstone Power Station, Unit Nos. 2 and 3 (Millstone). A list of attendees is provided as Enclosure 1.

DNC representatives presented information regarding the self-assessment that was performed on licensing activities at Millstone. The NRC staff queried the licensee about the DNC team that performed the assessment and any outreach performed. DNC stated that the assessment was an internal self-assessment. DNC also stated that they reached out to Florida Power and Light and Exelon for benchmarking purposes. The NRC staff asked about licensing issues identified at the other Dominion Fleet sites (North Anna Power Station, Unit Nos. 1 and 2; Kewaunee Power Station; and Surry Power Station, Unit Nos. 1 and 2), and questioned how the other site's activities compared to the activities at Millstone. DNC stated that the type of licensing issues are similar, but the number of issues have not been compared. DNC said they will address this at a future Dominion Fleet public meeting.

Proposed actions were provided by DNC (Agencywide Documents Access and Management System Accession No. ML110750462) and are included as Enclosure 3. The NRC asked DNC about the time frame for implementing the proposed changes. DNC stated that implementation has begun with incorporation into Millstone procedures and that they intend to convert to Dominion Fleet level procedures for licensing activities over the next several years.

The NRC staff inquired about the role of the Safety Review Committee with regard to submittals to the NRC. The NRC staff wanted to understand why the Safety Review Committee did not identify any of these licensing issues during their review. DNC stated that only a sub-set of documents go through the Committee and that the Committee's focus is technical evaluation.

DNC also went over, in detail, their process for submitting documents to the NRC. The NRC staff questioned the licensee about the percentage of licensing activity-related condition reports that were self-revealing and NRC-identified vice DNC-indentified. DNC did not have the requested information available at the meeting. DNC stated that condition report thresholds are being developed for regulatory correspondence.

- 2 The NRC staff asked about apparent cause or root cause analysis performed for the licensing issues and whether DNC's program is properly categorizing conditions that result from a failure to meet a regulatory requirement. DNC stated that they looked for a common cause, but did not consider the licensing issues to be a condition adverse to quality in accordance with industry guidance; therefore DNC did not perform a root cause analysis. NRC staff suggested that DNC review their quality assurance program in this area, since these programs typically require any condition that results in a violation of NRC regulations to be categorized as a significant condition adverse to quality, which requires a root cause analysis.

The NRC staff asked DNC to discuss their process for design changes with respect to updating the Updated Final Safety Analysis Report (UFSAR) and usage of 10 CFR 50.59. DNC stated that they have a new electronic system to ensure that all design changes are reviewed with respect to the UFSAR. DNC affirmed that they understand that the intent of a technical specification cannot be altered, without prior NRC staff approval, by a technical specification basis or UFSAR change. Changes that would alter the intent of the technical specification must receive prior NRC approval.

Although the actions proposed by DNC appeared appropriate, the NRC staff expressed that they remained concerned about the conduct of DNC's licensing activities for Millstone. The NRC staff will be monitoring the effectiveness of DNC's proposed actions.

Members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-3204, or John.Hughey@nrc.gov.

pD~

John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Licensing Regulation Office of Nuclear Reactor Regulation Docket Nos. 50-336 and 50-423

Enclosures:

1. List of Attendees

2. List of Background Information including the ADAMS Accession numbers

3. DNC's assessment cc w/encls: Distribution via Listserv

LIST OF ATTENDEES FEBRUARY 15, 2011 MEETING WITH DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 LICENSING ACTIVITIES NAME ORGANIZATION Carleen Sanders NRC Harold Chernoff Jeff Whited John Hughey Wanda Craft William D. Bartron I O:iniOn Dominion Chris Funderburk Dominion Kewaunee Tom Breene Kewaunee Jeff Hanson Exelon Ma lou Calderone Dominion abi Dominion Craig Sly Dominion Tom Shaub Dominion Jim Connolly FPL Bill Cummings Connecticut Post Nancy Burton Connecticut Coalition Against Millstone Bill Brown Dominion Richard MacManus Dominion Enclosure 1

LIST OF BACKGROUND INFORMATION INCLUDING THE AGENCYWIDE DOCUMENTS ACCESS AND MANGEMENT SYSTEM ACCESSION NUMBERS

1. "Update to the Final Safety Analysis Report for Millstone Power Station, Unit Nos. 1, 2, and 3," dated June 22,2009 (Dominion Nuclear Connecticut, Inc. (DNC)) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092380495).

2. "Millstone Power Station, Unit Nos. 1, 2, and 3 - Review of Update to the Final Safety Analysis Report," dated June 30, 2010 (Nuclear Regulatory Commission (NRC))

(ADAMS Accession No. ML101800008).

3. "Millstone Power Station Unit 2, Alternative Request RR-89-67 for the P40A RCP

[reactor cooler pump] Seal Cooler Return Tubing," dated September 22,2009 (DNC)

(ADAMS Accession No. ML092710151).

4. "Millstone Power Station, Unit No.2 - Issuance of Relief Request RR-89-67 Regarding the Repair of Reactor Coolant Pump Seal Cooler Return Tubing and Weld," dated April 26, 2010 (NRC) (ADAMS Accession No. ML093570237).

5. "Millstone Power Station Unit 2, Alternative Request RR-89-68 for use of Code Case N 722-1 for Bare Metal Visual Examination of the RPV [reactor pressure vessel] Flange Seal Leak-off Line Welds Made of Alloy 600/82/182 Materials," dated October 1, 2009 (DNC) (ADAMS Accession No. ML092740662).

6. Federal Register Notice (73 FR 52739).

7. "Millstone Power Station, Unit NO.2-Issuance of Relief Request RR-89-68 Regarding Use of American Society of Mechanical Engineering Code Case N-722-1 ," dated October 27,2010 (NRC) (ADAMS Accession No. ML102780086).

8. "Millstone Power Station Unit 3, Relief Request IR-3-01 Response to Request for Additional Information Regarding Snubber Inspection and Testing for Third 10 Year Interval," dated December 16, 2009 (DNC) (ADAMS Accession No. ML102780086).

9. "Millstone Power Station Unit 3, Request for Additional Information Regarding Relief Requests for Limited Coverage Examinations Performed in the Second 10-year Inspection Interval," dated January 20, 2011 (DNC) (ADAMS Accession No. ML110250259).

10. "Millstone Power Station Units 1, 2, 3, and ISFSI [independent spent fuel storage installation], 10 CFR 50.59, 10 CFR 72.48, and Commitment Change Report for 2008,"

dated June 30, 2009 (DNC) (ADAMS Accession No. ML091900371).

Enclosure 2

-2

11. "Millstone Power Station Unit 3, License Amendment Request to Revise Technical Specification 6.8.4.g, "Steam Generator (SG) Program," and TS 6.9.1.7, "Steam Generator Tube Inspection Report" for the One-Time Alternate Repair Criteria (H*),"

dated November 23, 2009 (DNC) (ADAMS Accession No. ML093620085).

12. "Request for Withholding Information from Public Disclosure for Millstone Power Station, Unit No.3," dated September 22,2010 (NRC) (ADAMS Accession No. ML102160749).

13. "Millstone Power Station Unit 3, Response to Request for Additional Information Regarding 2008 Steam Generator Tube Inspections," dated November 23, 2009 (DNC)

(ADAMS Accession No. ML093350528).

14. "Millstone Power Station, Unit No.2 - Issuance of Relief Request RR-04-02 Regarding Alternative VT-2 Pressure Testing Requirements for the Lower Portion of the Reactor Pressure Vessel," dated December 3, 2010 (NRC) (ADAMS Accession No. ML102940440).

15. "Millstone Power Station, Unit NO.3 - Request for Additional Information Regarding the Update to the Risk-Informed Inspection Program for the Third 10-Year Inspection Interval," dated November 29,2010 (NRC) (ADAMS Accession ML102940492).

16. "Millstone Power Station Unit 3, License Amendment Request to Revise Technical Specification (TS) 6.8.4.g, "Steam Generator (SG) Program," and TS 6.9.1.7, "Steam Generator Tube Inspection Report," for Temporary Alternate Repair Criteria (H*)," dated January 20,2011 (DNC) (ADAMS Accession No. ML110280208).

DOMINION NUCLEAR CONNECTICUT, INC.

ASSESSMENT OF MILLSTONE POWER STATION. UNIT NOS. 2 AND 3 LICENSING ACTIVITIES Summary of Dominion Regulatory Correspondence Self-Assessment Dominion performed an internal self-assessment of NRC regulatory correspondence.

The purpose of the self-assessment was to determine what timeliness, quality, and procedure compliance issues have contributed to less than optimal regulatory submittals for the Dominion nuclear fleet.

The raw data for the self-assessment was a list of outgOing NRC correspondence from January 1, 2009, to October 20,2010. Evaluation criteria were developed to assess correspondence for timeliness and quality issues.

The results were tabulated and analyzed to identify the most frequent problems and attributes associated with correspondence deficiencies.

A summary of planned actions to address the identified problems with regulatory correspondence was developed.

Appropriate procedural changes are expected to be completed by the end of second quarter 2011. Fleet implementation and change management activities will occur on a schedule commensurate with site resources and work schedules.

Enclosure 3

-2 The NRC staff asked about apparent cause or root cause analy~is performed forthe licensing issues and whether ONC's program is properly categorizing conditions that result from a failure to meet a regulatory requirement. ONC stated that they looked for a common cause, but did not consider the licensing issues to be a condition adverse to quality in accordance with industry guidance; therefore ONC did not perform a root cause analysis. NRC staff suggested that ONC review their quality assurance program in this area, since these programs typically require any condition that results in a violation of NRC regulations to be categorized as a significant condition adverse to quality, which requires a root cause analysis.

The NRC staff asked ONC to discuss their process for design changes with respect to updating the Updated Final Safety Analysis Report (UFSAR) and usage of 10 CFR 50.59. ONC stated that they have a new electronic system to ensure that all design changes are reviewed with respect to the UFSAR. ONC affirmed that they understand that the intent of a technical specification cannot be altered, without prior NRC staff approval, by a technical specification basis or UFSAR change. Changes that would alter the intent of the technical specification must receive prior NRC approval.

Although the actions proposed by ONC appeared appropriate, the NRC staff expressed that they remained concerned about the conduct of ONC's licensing activities for Millstone. The NRC staff will be monitoring the effectiveness of ONC's proposed actions.

Members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-3204, or John.Hughey@nrc.gov.

IRN John O. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Licensing Regulation Office of Nuclear Reactor Regulation Docket Nos. 50-336 and 50-423

Enclosures:

1. List of Attendees

2. List of Background Information including the ADAMS Accession numbers

3. ONe's assessment cc w/encis: Distribution via Listserv DISTRIBUTION PUBLIC RidsOgcRp Resource JHughey. NRR Branch Reading RidsRgn1 MailCenter Resource JWhited, NRR RidsAcrsAcnw_MailCTR Resource CSteger, NRR HChernoff, NRR RidsNrrDorlLpll-2 Resource RidsNrrLAABaxter Resource Miller, EDO Region 1 RidsNrrMilistone Resource ADAMS Accession No. PKG: ML110690723 Meeting Notice ML110180091/Revised Meeting Notice: ML110310682 Summa : ML110690794

• via email DORULPLI-2/PM DORULPLI-2/BC DORULPLI-2/PM JHughey 5/10/2011