ML20135C974

Forwards Insp Repts 50-245/96-08,50-336/96-08 & 50-423/96-08 on 960827-1025 & Notice of Violations

ML20135C974
Person / Time
Site:	Millstone
Issue date:	12/03/1996
From:	Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20135C977	List: ML20135C974 ML20135C995 ML20135D007
References
EA-96-352, NUDOCS 9612090183
Download: ML20135C974 (5)

See also: IR 05000245/1996008

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December 3,1996

EA 96-352

Mr. Bruce D. Kenyon

President and Chief Executive Officer

Northeast Nuclear Energy Company

c/o Terry Harpster

P. O. Box 128

Waterford, Connecticut 06385-0128

Dear Mr. Kenyon:

SUBJECT: NRC COMBINED INSPECTION 50-245/96-08; 50-336/96-08; 423/96-08 and

NOTICE OF VIOLATION

On October 25,1996, the NRC completed an inspection at your Millstone 1,2 & 3 reactor

facilities. The enclosed report presents the results of that inspection.

During the two-month period covered by this inspection, the performance of your staff at

the Millstone facilities was generally characterized by a deliberate approach to assuring the

proper consideration of shutdown risk in the conduct of operational activities, and by

significant management attention to recovery planning and reorganization in each unit.

However, we remain concerned about the continuing violations of NRC requirements. At

Unit 2, we identified one violation and six apparent violations. In addition, three apparent

violations were identified at Unit 1, and are being considered for escalated enforcement

actions in accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions" (Enforcement Policy), NUREG-1600. In addition, your continued

failures to fulfill commitments made to the NRC are of particular concern. We are

disappointed to find that corrective actions were not completed which further erodes our

confidence in your organization and is indicative of management weaknesses that require

irnmediate attention.

One of the apparent violations at Unit 2 is inadequate corrective actions, which had three I

examples. As stated previously in NRC Combined Inspection Report 96-04 for all three

units, the corrective action program had not been effective in correcting identified

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deficiencies; therefore, this program must be demonstrated effective before the restart of

any of the Millstone units. The apparent violation illustrates that Unit 2 has not yet

attained a level of performance to show that the corrective action program is improving. ({

A fourth apparent violation, which occurred at Unit 2, was a technical specification

violation due to both trains of containment air hydrogen monitors being inoperable. The

fifth apparent violation was a Unit 2 concern in which the NRC found that due to an

9612090183 961203

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Mr. Bruce D. Kenyon 2

inadequate review of the steam generator replacement modification, it was not identified

that the design basis and licensing basis time periods for placing the hydrogen monitors in

service and taking a containment atmosphere sample could not be met. The sixth apparent

violation at Unit 2 is a concern in which the NRC found that the Final Safety Analysis

Report had not been updated to reflect the licensing basis regarding the amount of time

following an accident that the hydrogen monitors would be placed in service.

A violation at Unit 2 involved the failure to adequately perform the monthly technical l

specification required valve line up of containment isolation valves because not all the

required valves were specified in the procedure and operators had been documenting as

"not applicable" those valves located inside containment. This violation is cited in the

enclosed Notice of Violation, and the circumstances surrounding the violation are described

in detail in the enclosed report. Please note that you are required to respond to this letter ,

and should follow the instructions specified in the enclosed Notice when preparing your i

response. The NRC will use your response, in part, to determine whether further

enforcement action is necessary to ensure compliance with regulatory requirements.

The first apparent violation at Unit 1 involved the failure to provide a troubleshooting plan

and troubleshooting guidelines with the work order package associated with the repair of a

travelling screen differential pressure transmitter. The second apparent violation at Unit 1

involved the failure to maintain the standby gas treatment system operable under all

conditions. Specifically, if actuation of the standby gas treatment system had occurred

during the time period that the outside ambient temperature was less than 45 F,

coincident with a loss of normal power and a single failure in one train, the required

negative pressure may not have been maintained throughout the secondary containment.

The third apparent violation at Unit 1 concerned a corrective action issue involving the

failure to implement the design modifications necessary to bring the control rod drive

system into design compliance within the NRC specified time period.

Accordingly, no Notice of Violation is presently being issued for the nine apparent

violations. Please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

You will be informed by separate correspondence of the results of our deliberations on this

matter. No response regarding the apparent violations is required at this time; however,

corrective actions deemed appropriate should not be delayed.

Following a review of your plans for entering Mode 6 at Unit 2, the NRC had concerns

regarding your intent to perforn: a core offload using systems which, although operable,

had known discrepancies that were contrary to the current operating license. Although no

violations of NRC requirements were identified, this is considered to be a significant

weakness in light of the recent attention given to compliance with the current design and

licensing basis.

Although no violations were cited against the Millstone Unit 3 docket, two inspection

issues discussed in this report merit additional licensee management attention. The first

issue involved a concern affecting all three Millstone units, i.e., the identification of fuses

with cracked ferrules in the safety-related warehouse stock supply, initial licensee actions

to address this concern were inadequate until the Nuclear Oversight Organization

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Mr. Bruce D. Kenyon 3

conducted follow up activities and identified concerns. Even then, the licensee

investigation to ensure that the suspect fuses were capable of performing their safety

function was implemented without evidence of a timely review of installed fuse conditions.

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The second issue related to the numerous inservice testing program deficiencies  !

documented in licensee event reports (LER) 50-423/96-21 and 96-24. Similar to the {

problem in the handling of the cracked fuse ferrules, licensee corrective actions in

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addressing the programmatic concerns documented in the applicable adverse condition

report were found to be less than comprehensive. Given the programmatic nature of the

identified inservice testing program problems, as well as the lack of specificity provided in

LER 50-423/96-21, we request that you inform us in writing within 60 days of the receipt

of this letter of your plans to address the inservice testing program deficiencies. This

response should include your position on the need for the development of a more

comprehensive approach to corrective action controls for such reportable programmatic

concerns.

Finally we have determined that your fire protection program lacks appropriate direction for

resolving and prioritizing identified issues. Quality assurance audits of fire protection were i

limited in scope, sometimes incorrectly categorized the significance of findings, and failed I

to followup on previously identified issues. Your staff failed a fire drill during the

inspection, requiring you to conduct a remedial drill. Given the large number of design

deficiencies that could affect the safe shutdown capability of safety systems, e.g., cable

separations, and fire mitigation weaknesses, we believe that your fire protection program

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needs more attention. Therefore, we will need to meet with you to discuss your resolution

of program oversight concerns, including Appendix R issues, prior to any unit start-up.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures will be placed in the NRC Public Document Room (PDR). l

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Sincerely,

ORIGINAL SIGNED BY: {

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Wayne D. Lanning l

Deputy Director of Inspections i

Special Projects Office

Docket Nos. 50-245

50-336

50-423

Enclosures: i

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1. Notice of Violation

2. NRC Combined Inspection Report 50-245/96-08;50-336/96-08;50-423/96-08  :

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Mr. Bruce D. Kenyon 4

cc w/ encl:

T. C. Feigenbaum, Executive Vice President - Chief Nuclear Officer

J. McElwain, Unit 1 Recovery Officer

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M. Bowling, Jr., Unit 2 Recovery Officer i

J. Cowan, Unit 3 Recovery Officer

D. M. Goebel, Vice President, Nuclear Oversight

J. K. Thayer, Recovery Officer, Nuclear Engineering and Support

P. D. Hinnenkamp, Director, Unit Operations

H. F. Haynes, Director, Nuclear Training

P. M. Richardson, Nuclear Unit Director, Unit 2

M. H. Brothers, Nuclear Unit Director, Unit 3

J. F. Smith, Manager, Operator Training

F. C. Rothen, Vice President, Work Services l

P. Olson, General Accounting Office

L. M. Cuoco, Esquire

J. R. Egan, Esquire

V. Juliano, Waterford Library

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J. Buckingham, Department of Public Utility Control '

S. B. Comley, We The People

State of Connecticut SLO Designee ,

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Mr. Bruce D. Kenyon 5

Distribution w/ encl:

Region i Docket Room (with concurrences)

W. Lanning, Deputy Director of Inspections, SPO, Rl

M. Kalamon, SPO, RI

NRC Resident inspector

Nuclear Safety Information Center (NSIC)

PUBLIC

D. Screnci, PAO

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Distribution w/enci (VIA E-MAIL): j

W. Travers, SPO, NRR I

D. Screnci, PAO  :

N. Sheehan, Field-Public Affairs Officer, RI

J. Andersen, PM, SPO, NRR

W. Dean, OEDO

P. McKee, Director, Deputy Director of Licensing, SPO, NRR  !

G. Imbro, Deputy Director of ICAVP, Oversight, SPO, NRR

L. Plisco, Chief, SPO, NRR

V. Rooney, PM, SPO, NRR

D. Mcdonald, SPM, SPO, NRR

M. Callahan, OCA

R. Correia, NRR

R. Frahm, Jr., NRR

inspection Program Bratich, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 6\96-08.123

To receive a copy of this document,Indicete in the boa: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure

• N' = No copy

OFFICE Rl/SPO Rl/SPO / /

NAME DURR [ G LANNING R,OL

DATE 12/2/96 1A/3/96

OFFICIAL RECORD COPY

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