IR 05000245/1996008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/96-08, 50-336/96-08 & 50-423/96-08

ML20141E442
Person / Time
Site:	Millstone
Issue date:	06/19/1997
From:	Durr J NRC (Affiliation Not Assigned)
To:	Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
50-245-96-08, 50-245-96-8, 50-336-96-08, 50-336-96-8, 50-423-96-08, 50-423-96-8, NUDOCS 9707010061
Download: ML20141E442 (3)

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June 19, 1997

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Mr. Bruce D. Kenyon President and Chief Executive Officer Northeast Nuclear Energy Company P. O. Box 128 Waterford, Connecticut 06385-0128 SUBJECT: COMBINED INSPECTION 50-245/96-08;50-336/96-08;50-423/96-08 Daar Mr. Kenyon:

This letter refers to your December 27,1996 correspondence, in response to our December 3,1996 lette Thank you forinforming us of the corrective and preventive actions documented in your lette These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely, ORIGINAL SIGNED BY: R. Urban Tv Jacque P. Durr, Chief Special Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50-245;50-336;50-423 cc:

N. S. Carns, Senior Vice President and Chief Nuclear Officer M. H. Brothers, Vice Preside it - Millstone, Unit 3

.l. McElwain, Unit 1 Recover / Officer M. Bowling, Jr., Unit 2 Recovery Officer D. M. Goebel, Vice President, Nuclear Oversight J. K. Thayer, Recovery Officer, Fluclear Engineering and Support

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P. D. Hinnenkamp, Director, Una Operations F. C. Rothen, Vice President, V.'ork Services J. Stankiewicz, Training Recovery Manager

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R. Johannes, Director - Nuclear Training 010001 9707010061 970619 lllll1llllllllllOllllllll'llll1BlIll ii>a i PDR ADOCK 05000245 G PDR

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i Mr. Bruce D. Kenyon 2 cc w/cy of Licensee's Response Letter:

' L. M. Cuoco, Esquire J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control S. B. Comley, We The People State of Connecticut SLO Designee D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN J. M. Block, Attorney, CAN

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S. P. Luxton, Citizens Regulatory Commission (CRC) ,

Represer)tati'/e T. Concannon

E. Wool!acott, Co-Chairman, NEAC i l

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i i- Mr. Bruce D. Kenyon 3 l Distribution w/cv of Licensee's Response Letter:

Region i Docket Room (with copy of concurrences)

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Nuclear Safety Information Center (NSIC)

! PUBLIC l FILE CENTER, NRR (with Oriainal concurrences)

NRC Resident inspector j M. Kalamon, SPO, RI W. Lanning, Deputy Director of Inspections, SPO, RI D. Screnci, PAO

W. Travers, Director, SPO, NRR j S. Reynolds, Technical Assistant, SPO, NRR

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D. Screnci, PAO

inspection Program Branch (IPAS)

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DOCUMENT NAME: 1:\ BRANCH 6\REPLYLTR\MS9608.RPY To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE NRR/Syg / l NAME DURR7 f)CL DATE 06//797 d OFFICIAL RECOR) COPY

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Nzrthesst * * Off= * Role Ferry Rd Waterford, CT

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Utilities System P.o.aos128 Taterford, CT 0638 3-0128 (203) 447-1791 I

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! December 27,1996 Docket No. 50-245

. 50-336

50-423

! B16076

! Re: 10CFR2.201 i

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U.S. Nuclear Regulatory Commission l Attention: Document Control Desk

Washington, DC 20555

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l Millstone Nuclear Power Station, Unit Nos.1,2, and 3 j Facility Operating License Nos. DPR-21, DPR-65, and NPF-49

Reply to Notice of Violation 336/96-08-07 and

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Process For Preparation of Corrective Action Completion Packages insoection 50-245/96-08: 50-336/96-08 50423/96-08 in a letter dated December 3,1996,W the NRC transmitted the results of an inspection conducted at the Millstone Station from August 27,1996 through October 25,199 The NRC Inspection Report concluded that certain of our activities at Millstone Unit N appeared to be in violation of NRC requirements. It was determined that Northeast Nuclear Energy Company (NNECO) did not ' perform monthly surveillances in accordance with Technical Specificrution 4.6.1.1.a to insure valves that are classified as containment isolation boundaries are maintained in the closed positio On behalf of Millstone Unit No. 2, Attachment 1 provides NNECO's reply to the Notice of Violation pursuant to the provisions of 10CFR2.20 The NRC has also requested that NNECO provide a description of the process for completing Corroctive Action Completion Packages for NRC inspection issues and reportable events to be submitted to the NRC for review and closure. The process for completing the Corrective .A: tion Completion Packages is provided in Attachment M W. D. Lanning letter to Bruce D. Kenyon, "NRC Combined inspection 50-245/96-08; 50-336/96-08; 50-423/96-08 and Notice of Violation," dated December 3,199 ""'" " "5 g y 1 ,(

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U.S. Nucl=r RegulItory Commission B16076\Page 2 f

p Commitments

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The following are NNECO's commitments associated with this response:

! B16076-1 Procedure changes for Millstone Unit No. 2 were made to add valves to the i

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surveillance form for those valves found to require the 31 day surveillance !

in accordance 'ith Tecnnical Specification 4.6.1.1.a. Other Technical l Specification survell'ances containing requirements to verify valve position j have been reviewed to identify any valves that were potentially not included i within appropriate surveillance procedures. Surveillance procedures that j did not contain requirements to verify valve position required in accordance with Technical Epocifications have been revised.

i B16076-2 Technical Specification surveillance procedures will be reviewed to ensure j

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compliance with Technical Specification surveillance requirements as part ;

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of the Millstone Unit No. 2 Operational Readiness Plan. The review v;ii ;

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initially focus on Technical Specification surveillance procedures requ' red

, for mode 6 and defueled. Surveillance procedures required for subsequent j mode changes will be reviewed prior to mode entr l

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B16076-3 Each Millstone Unit will develop an outline of management expectations for 3 development of Corrective Action Completion Packages. The outlines will

! be completed no later than January 3,199 Should you have any questions regarding this submittal, please contact Mr. William J. Temple at (860) 437-590 Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY D

David M. Goebel '

Vice President - Nuclear Oversight Attachments (2)

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. U.S. Nucicar Regulatory Commission B16076\Page 3 i.

cc- H. J. Miller, Region 1 Administrator l Dr. W. D. Travers, Director, Special Projects Office

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W. D. Lanning, Director, Millstone Assessment Team

S. Dombek, NRC Project Manager, Millstone Unit No.1

T. A. Easlick, Senior Resident inspector, Millstone Unit No.1

D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 l D. P. Beaulieu, Senior Resident inspector (Acting), Millstone Unit No. 2 i J. W. Andersen, NRC Project Manager, Millstone Unit No. 3

A. C. Corne, Senior Resident inspector, Millstone Unit No. 3

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Docket No. 50-336

' B16076 -t

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Millstone Unit No. 2

I i Facility Operating License No. DPR-65

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l Reply to Notice of Violation 336/96-08-07 I NRC Combined Inspection Report

50-245/96-08; 50-336/96-08;50-423/96-08

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December 1995

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U.S. Nucl:ar RegulItory Commission B16076\ Attachment 1\Page 1

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Restatement of Violation  !

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Technical Specification 4.6.1.1.a requires that valves that are classified as containment i isolation boundaries receive a monthly verification to insure they are in the closed

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f Contrary to the above, all valves that are classified as containment isolation boundaries

did not receive a monthly verification to insure they are in the closed position because

l Monthly surveillance Procedure OPS Form 2605A-1, " Verifying Containment l Integrity," failed to include all of the required containment isolation boundaries, and;

! Containment isolation valves inside containment were listed as "not applicable" l while at power even though the technical specificatiori did not allow for this i exemption.

l This is a Severity Level IV Violation (Supplement I) against DN 50-336.

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Reason for the Violation i

Northeast Nuclear Energy Company (NNECO) does not dispute the Technical

Specification (TS) violation, parts 1 and 2 cited above. Certain valves, classified as

! containment isolation boundaries, did not receive monthly verifications to ensure they a were in the closed position. This is contrary to Technical Specification 4.6.1.1.a. The i monthly surveillance procedure did not include some valves listed in Updated Final

! Safety Analysis Report (UFSAR), Table 5.2-11, that lists the containment structure l

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isolation valve information. In addition, manual valves located inside containment were listed as "not applicable" on the surveillance forms. These forms are utilized to perform Technical Specification surveillances to insure the manual isolation valves located inside containment are maintained in the closed position while at power. Technical Specifications 4.6.1.1.a,4.5.2.a.7, and 4.7.3.1.a.5 do not allow this exemptio Violations 1 and 2 cited above were reported to the NRC in Licensee Event Reports (LER) 96-023-00* dated May 24,1996 and 96-026-00* dated June 3,199 The causes and contributing factors resulting in the failure to implement the surveillance requirements of Technical Specification sections 4.6.1.1.a,4.5.2.a.7, and 4.7.3.1.a.5 are:

• P. M. Richardson letter to USNRC dated May 24,1996, " Licensee Event Report 96-023-00."

• P. M. Richardson letter to USNRC ;iated June 3,1996, " Licensee Event Report 96-026-00."

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U.S. Nuclear Regulctory Commission i

B16076\ Attachment 1\Page 2

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Cause: I i The cause of Technical Specification violation 1 above is an inadequate procedure that

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did not include several valves that must be verified as closed to maintain containment l integrity as contained in UFSAR Table 5.2-11. The valves were not listed as a result of l errors made during the development or subsequent revisions of the surveillance  !

j procedure. The errors wore the result of not maintaining surveillance procedures

consister t with the licensing basis requirements contained in the UFSAR.

l The cause of Technical Specification violation 2 above was a non-conservative l i management decision / historical interpretation of the UFSAR that resulted in an J

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operating practice that was not consistent with the surveillance requirements of J

! Technical Specification sectivts 4.6.1.1.a, 4.5.2.a.7, and 4.7.3.1.a.5. The operating l practice was to complete the surveillance form, and note that the requirements were not l applicable for those manual valvas located inside containment during plant operation.

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I Contributina Factors:

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Tech')ical Specification surveillance 4.6.1.1.a, " Containment integrity," requires that a l

! verification be performed at least once per 31 days, to ensure that all r anetrations, not

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i capable of being closed by OPERABLE containment automatic isolation valves and

required to be c40 sed during accident conditions, "are closed by valves, blind flanges or l ' deactivated automatic valves secured in their positions." UFSAR section 5.2.8.4.2, l " Containment !aolation System - Tests and Inspections," states, "The containment

isolation valves located outside the containment are accessible for maintenance and

! inspection during normal plant operation. The isolation valves located within

, containment are accessible during normal plant shutdown for maintenance and i inspection." The operating practices leading to the omission of these valves were

! supported by an interpretation of the UFSAR description that indicated that manual

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containment isolation valves located inside containment need only be inspected during j plant shutdowns. The UFSAR interpretation was subsequently utilized, during i operation, as the basis for exempting from the 31 day Technical Specification i surveillance those valves located inside containment and identifying those valves as i "Not Applicable" on OPS form 2605A-1. There is no exemption provided for Technical

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Specification 4.6.1.1.a. Therefore, this operating practice is not acceptabl I

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l . U.S. Nuclear Reguirtory Commission

! B16076\ Attachment 1\Page 3 l

l The surveillance requirements for TS sections 4.5.2.a.7, and 4.7.3.1.a.5 require

! verifying the correct position of valves that are "not locked, sealed or otherwise secured J

in position." It was the operating practice to consider the va!ves located inside !

l containment to be exempt from the 31 day surveillance, since the containment i personnel hatch was locked and sealed. Although the valves were not individually i sealed, the valves were considered 'otherwise secured," and therefore, were not j verified in position. This interpretation was incorrect resulting in the violation of the

requirements of Technical Speedication sections 4.5.2.a.7, and 4.7.3.1.a.5.

l Corrective Steps That Have Been Taken and Results Achieved

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! The containment isolation valves that had not been inspected in accordance with

! Technical Specification 4.6.1.1.a were subsequently inspected and verified to be in the closed position. These valves were 3/4 inch and smaller vent and drain valves, a two-i inch isolation valve (2-CH-517) located on the pressurizer auxiliary spray line, and two j eight-inch main steam line atmospheric dump valves (MS-190 A & B).

l j A shift briefing was prepared by the operations manager informing operators that the

! practice of entering "N/A" for certain valos on the valve lineups is unacceptable and j that the practice had reso!ted in not fulfilling TS surveillance requirements.

j Procedure changes were made to add valves, found to require the 31 day surveillance,

! to the surveillance forms.

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! Those valves required to be verified by Technical Specifications 4.5.2.a.7 and i 4.7.3.1.a.5 have been verified in the correct position per current Technical Specification l requirements.

l Other TS surveillances containing requirements to verify valve position have been j reviewed to identify any valves that were potentially not included within appropriate j surveillance procedures. An Adverse Condition Report (ACR) was initiated on i December 17,1996 to document the results of this review that identified several valve l position surveillances that were not included within surveillance procedures. Revisions

to correct the surveillance procedures have been completed.

! In response to Generic Letter 91-08, which provides guidance for removal of j component lists from the TS, a license amendment request was submitted to the NRC i Staff on January 22,1996. The proposed change will modify TS surveillance 4.6.1.1 to

! be consistent with the FSAR section 5.2.8.4.2. The proposed change will require that the valve positions be verified prior to changing from mode 5 to 4, but will not require visual verification while at powe The Unit 2 management organization has been strengthened by the formulation of a l Recovery Tea . . _ - - . _ . .. . . . = - . - . -- - . .- .- - - - . . -. -

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U.S. Nuclear Regulatory Commission

B16076\ Attachment 1\Page 4

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s Corrective Actions That Will Be Taken '

j Technical Specification surveillance procedures will be reviewed to ensure compliance

with Technical Specification surveillance requirements as part of the Operational j Readiness Plan. The review will initially focus on Technical Specification surveillance

{ procedures required for mode 6 and defueled. Surveillance procedures required for

, subsequent mode changes will be reviewed prior to mode entry.

l Date When Full Compliance Will Be Achieve #1

NNECO is currently in full compliance with the requirements of Technical Specification j sections 4.6.1.1.a,4.5.2.a.7, and 4.7.3.1.a.5.

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i Docket No. 50-245

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l 50-336 i 50-423 i,

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i B16076

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$ Attachment 2

Millstone Unit Nos.1,2, and 3 j

Facility Operating License Nos. DPR-21, DPR 65, and NPF-49 j

i Process For Preparation of Corrective Action Completion Packages i

i December 1996

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. . U.S. Nuclear Reguirtory Commission l l B16076\ Attachment 2\Page 1

l PROCESS FOR PREPARATION OF l

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CORRECTIVE ACTION COMPLETION PACKAGES }

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j BACKGROUND  ;

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The NRC has requested that Northeast Nuclear Energy Company (NNECO) provide a

! process for completing Corrective Action Completion Packages for NRC inspection j issues and reportable events (e.g., Notices of Violations (NOVs), Unresolved items,

inspector Follow-up items (IFis) and Licensee Event Reports (LERs)) that require NRC j evaluation and closure. The process will ensure that documentation to support closure

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of NRC inspection related findings and reportable events are consistently presented, l the information presented is complete and accurate, and required corrective actions t l and actions to prevent recurrence have been completed.

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SCOPE

} Corrective Action Completion Packages will be prepared for NRC inspection Report

! findings that include Notices of Violations (NOV), Unresolved items (URI) and inspector

! Follow-up items (IFI). . In addition, Corrective Action Completion Packages will be

developed for LERs and 10CFR21 issues that require NRC evaluation and closure.

! DISCUSSION

! AftL M^df l The Corr ion Completion Package, where applicable, will include information i that the could reasonably be expected to rely upon to reach the conclusion that

! root causes have been identified, corrective actions to resolve the concem are

, completed, and appropriate actions to prevent recurrence of the issue have been l identified and completed. Reports will be initiated, as appropriate, in accordance with

! the Station Procedure for processing adverse conditions, and will be utilized as the l controlling corrective action document when developing the Corrective Action j Completion Package. The Corrective Action Completion Package documentation will i include:

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i Copy of Initiating Document.

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j Applicable Correspondence between the NRC and NNECO.

I i Supporting documentation providing evidence that corrective actions have i

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been completed. For long term corrective actions that are not complete, provide evidence that the item is tracked and the basis for it's deferral.

i i Supporting documentation for statements of fact contained in NNECO letters to the NRC.

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. U.S. Nucl:ar R:gul tory Commission i B16076\ Attachment 2\Page 2

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l The information that is gathered for the validation of outgoing correspondence to the i j NRC should be included in the Corrective Action Completion Packag APPROVAL OF CORRECTIVE ACTION COMPLETION PACKAGES

! The Corrective Action Completion Package will be reviewed and approved by the

responsible unit line management and Licensing Manager prior to submittal to the NRC for review and closure.

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IMPLEMENTATION

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i Each Millstone Unit will develop an outline of the above management expectations for

development of Corrective Action Completion Packages. The Unit outlines will be

completed no later than January 3,1997,

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