IR 05000336/1996013

Ack Receipt of 970307 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-336/96-13 on 961112-22

ML20147G311
Person / Time
Site:	Millstone
Issue date:	03/20/1997
From:	Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harpster T, Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9703280080
Download: ML20147G311 (3)

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March 20, 1997 Mr. Bruce President and Chief Executive Officer Northeast Nuclear Energy Company I c/o Terry Harpster l P. O. Box 128 Waterford, Connecticut 06385-0128 i

SUBJECT: NRC INSPECTION REPORT NO. 50-336/96-13 (REPLY)

Dear Mr. Kenyon:

This refers to your March 7,1997 correspondence, in response to our letter, dated on February 3,1997. This correspondence dealt with the Notice of Violation. Millstone Nuclear Power Station, Unit No. 2 did not establish and implement procedures required by Section 6.8 of the Technical Specification to verify ventilation system performance as ,

described in Section 9.9.9.4.2 of the Unit 2 UFSAR (HEPA test within the Main Exhaust System). We have reviewed this matter in accordance with NRC Inspection Manual l Procedure 92904, " Plant Support." i We reviewed your corrective actions, taken or planned, which included: (1) developing test procedures for Main Exhaust System HEPA filter units; (2) subsequent testing of all 1 three HEPA filter units; (3) updating the Preventive Maintenance Management System 1 (PMMS) to include post maintenance testing of the filter units; and (4) establishing I corrective steps to avoid further violations. We found that your corrective actions were l appropriate. j We concur with your assessment that the root cause involved a misinterpretation of i UFSAR Section 9.9.9.4.2. We consider the actions you have taken to be acceptable and l will review the effectiveness of these actions in a future inspection.

We appreciate your cooperation.  !

Sincerely, John R. White, Chief Radiation Safety Branch Division of Reactor Safety i

Docket No. 50-336

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

M. Bowling, Jr., Unit 2 Recovery Officer D. M. Goebel, Vice President, Nuclear Oversight J. K. Thayer, Recovery Officer, Nuclear Engineering and Support l P. D. Hinnenkamp, Director, Unit Operations j l

H. F. Haynes,_ Director, Nuclear Training P. M. Richardsoni Nuclear Unit Director, Unit 2

- J. F. Smith, Manager, Operator Training l F. C. Rothen, Vice President, Work Services L. M. Cuoco, Esquire  ;

J. R. Egan, Esquire  !

V. Juliano, Waterford Library  ;

Department of Public Utility Control S. B. Comley, We The People State of Connecticut SLO Designee Citizens Awareness Network l

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Bruce Distribution w/ encl:

Region i Docket Room (with concurrences)

W. Lanning, Deputy Director of Inspections, SPO, RI M. Kalamon, SPO, RI NRC Resident !nspector Nuclear Safety Information Center (NSIC)

PUBLIC D. Screnci, PAO N. Sheehan, Field-Public A f fairs Officer, RI J. Anderson, PM, SPO, NRM W. Dean, OEDO P. McKee, Director, Deputy Director c' Licensing, SPO, NRR G. Imbro, Deputy Director of ICAVP Oversight, SPO, NRR L. Plisco, Chief, SPO, NRR S. Dembek, PM, SPO, NRR D. Mcdonald, SPM, SPO, NRR M. Callahan, OCA R. Correia, NRR R. Frahm, Jr., NRR inspection Program Branch (IPAS)

DRS Fife DOCUMENT NAME: G:\RSB\JANG\MS29613. REP To recche a copy of this document, indicate in the bou:

"C" = Copy without attachmenvenclosure

• E" = Copy with attachment / enclosure OFFICE Rl/DRS /yg .c Rl/DRhgg/jjg Rl/ Rl/

"N" = No copy NAME JJang t/Qu Q)/ l l Rll JWhite V(/jJ7 ,)

DATE 03/18/97/ ~ / 03/a6/97 03/ /97 03/ /97 03/ /97

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Northemat Nuclear I:ncrp Coinpany P.O. Box 128 Waterford. CT 0o3850128 i (860) 447-1741

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rax (860) 444-427 The Nonheast Utihties Spiern March 7,1997 i Docket No. 50-336 B16290 Re: 10CFR2.201

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 )

Millstone Nuclear Power Station, Unit No. 2 Facility Operating License No. DPR-65 Reply to Notice of Violation 336/96-13-03 Insoection 50-245/96-13: 50-336/96-13: 50-423/96-13 in a letter dated February 3,1997,* the NRC-transmitted the results of an inspection conducted at the Millstone Station from November 12-22,1996. The NRC inspection Report concluded that certain of our activities at Millstone Unit No. 2 were not in compliance with NRC regulations, it was determined that Northeast Nuclear Energy Company (NNECO) did not establish and implement procedures, required by Technical Specification 6.8, to verify ventilation system performance as described in the Unit 2 Updated Final Safety Analysis Report (UFSAR). Section 9.9.9.4.2 of the UFSAR describes tests and inspections for

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the air cleaning system, High Efficiency Particulate Air (HEPA) Filter within the l Main Exhaust System.

l On behalf of Millstone Unit No. 2, Attachment 1 provides NNECO's reply to the l Notice of Violation pursuant to the provisions of 10CFR2.201.

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Commitn),ents )

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i l The following are NNECO's subsequent actions which are committed to by this l

response:

B16290-1 The UFSAR section 9.9.9.4.2 will be changed to add a requirement clearly stating that the Main Exhaust System HEPA filters shall be tested in accordance with Regulatory Guide 1.14, " Design Testing and Maintenance

! * John R. White letter to Bruce D. Kenyon, "NRC Combined Inspection 50-

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i 245/96-13; 50-336/96-13; 50-423/96-13 and Notice of Violation," dated February 3,1997.

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U.S. Nuclear Regulatory Commission

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. B16290\Page 2

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Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." This change will be l prepared and approved through the Station intamal review process by April 15, 3 1997, and will be included in the next update to the UFSAR.

B16290-2 The UFSAR is Deing reviewed for other systems (including ventilation) in response to the NRC request for information

, pursuant to 10CRF50.54 (f). The response will include the results j

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of the review and will include any licensing basis issues that were

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l identified. The response will be submitted to NRC Staff prior to i restart of Millstone Unit No. 2.

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Should you have any questions regarding this submittal. please contact Mr. Ravi I

, Joshi at (860) 440-2080.

Very truly yours, i

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NORTHEAST NUCLEAR ENERGY COMPANY

. M. L. Bowling V l i

Millstone Unit No. 2 Recovery Officer l

Attachments (1)

i cc: H. J. Miller, Region i Administrator Dr. W. D. Travers, Director, Special Projects Office W. D. Lanning, Director, Millstone Assessment Team D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 J. P. Durr, Chief, Project Branch No. 6 l

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I Docket No. 50-336 B16290

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Attachment 1 l Millstone Unit No. 2 Facility Operating License No. DPR-65 l

Reply to Notice of Violation 336/96-13-03 l

NRC Combined inspection Report 50-245/96-13,50-336/96-13 and 50-423/96-13

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March 1997 l

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B16290\ Attachment 1\Page 1 Millstone Unit No. 2  ;

Facility Operating License No. DPR45 I Reply to Notice of Violation 338/96-1343 Restatement of Violation Section 6.8 of the Unit 2 TS requires, in part, that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33 (RG 1.33), February 1978. Appendix A of the RG 1.33, " Typical Procedures for Pressunzed Water Reactors and Boiling Water Reactors," describes typical procedures for the control of radioactivity, including procedures involving ventilation systems relative to limiting personnel exposure and releases to the environment.

Section 9.9.9.4.2 of the UFSAR describes tests and inspections for the air cleaning system, High Efficiency Particulate Air Filter (HEPA), of the Main Exhaust System.

Section 6.7.4.2 describes that the HEPA filter bank is to be tested, in place, periodically.

Contrary to the Section 6.8 TS requirement, as of November 22,1996, the licensee had failed to establish and implement procedures sufficient to test the HEPA lilter of the Main Exhaust System, in the manner describe 2 by the UFSAR, since commencement of operations at the facility.

This is a Severity Level IV violation (Supplement IV).

Reason for the Violation Northeast Nuclear Energy Company (NNECO) does not dispute the cited Technical Specification (TS) violation. Procedures were not established to sufficiently implement tests of the Main Exhaust System, High Efficiency Particulate Air (HEPA) Filters in the manner described in the USFAR. This is contrary to Technical Specification 6.8 and Regulatory Guide 1.33.

The cause and contributing fac' ors resulting in the failure to establish and implement procedures to test the Main Exhaust System HEPA filters are:

Cause:

The cause of the Technical Specification violation is a misinterpretation of UFSAR,

. section 9.9.9.4.2, " Tests and inspections," which led to an oversight of periodic testing j necessary to assure the Main Exhaust System HEPA filter performed as designed. The

UFSAR, section 9.9.9.4.2 did not specify any test requirements for the Main Exhaust !

l System HEPA filters. Instead, Section 9.9.9.4.2 " Tests and inspection," refers to i subsection 6.7.4.2 for filter design, and did not clearly provide guidance for testing the i

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j. B16290%ttachment 1\Page 2 i Main Exhaust System HEPA filters. Section 6.7.4.2 provided guidance for testing l filters, but states only " individual components of the Enclosure Building Filtration L l system are tested to assure performance * This led to a misunderstanding that testing ,

l was not required for the Main Exhaust System HEPA filters. Consequently, procedures '

! were not developed to implement tests that would assure filter performance. i l

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Contributina Factors

. Technical Specification 6.8 requires, in part, that written procedures shall be [

l established, implemented and maintained covering the activities recommended in '

} Appendix A of RG 1.33. RG 1.33 further describes typical procedures for the control of i radioactivity, including procedures involving ventilation systems relative to limiting i personnel exposure and release to the environment The fact that the Main Exhaust i System is a non-safety related system was a contributor to the oversight of the need to j have procedures for testing the HEPA filters with the same requirements as the l Enclosure Building Filtration System. Procedures were not written and subsequently l testing was not performed. '

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j Corrective Steps Taken and Results Achieved l

l A test procedure has been developed for three Main Exhaust System HEPA filter units.

This procedure accomplishes in-place testing to the filter units. This testing is 3 scheduled on an 18 month frequency and is performed whenever the filter units are changed or following any structural maintenance.

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! All three HEPA filter units in the Main Exhaust System have subsequently been l performance tested with acceptable results.

i l The Preventive Maintenance Management System (PMMS) has been updated to

! include post maintenance testing of the filter units.

l l Procedures developed to perform routine surveillance testing of the Main Exhaust System HEPA filters have been included in PMMS and the Non-Technical Specification tracking program for scheduling purposes.

l l Other systems where HEPA filters are used to control radioactivity and limit personnel l exposure were reviewed for RG 1.33 compliance. Procedures were found to be in-j place and periodic filter testing is being performed on a periodic frequency.

! The Corrective Steps That Will be taken to Avoid Further Violations

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I The UFSAR Section 9.9.9.4.2 will be changed to add a requirement clearly stating that

! the Main Exhaust System HEPA filters shall be tested in accordance with RG 1.14, l " Design Testing and maintenance Criteria for Normal Ventilation Exhaust System Air i Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants."

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U.S. Nucl:ar Regul: tory Commission  ;

. B16290%ttachment 1\Page 3  !

This change will be prepared and approved through the Station intemal review process by April 15,1997, and will be included in the next update to the UFSAR.

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l The UFSAR is being reviewed for other systems (including ventilation) in response to l

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the NRC request for information pursuant to 10CRF50.54 (f). The response will include the results of the review and will include any licensing basis issues that were identified.

The response will be submitted to NRC Staff prior to restart of Millstone Unit No. 2.

l Date When Full Compliance will be Achieved i

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NNECO is currently in full compliance with the requirements of Technical Specification l 6.8.1a, for the Main Exhaust System.

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