ML20141E283

Forwards Insp Repts 50-245/97-02,50-336/97-02 & 50-423/97-02 on 970311-0519 & Notice of Violation.Violation Involved Failure to Translate Correctly Plant Design Basis Into Drawings & to Implement Appropriate Administrative Controls

ML20141E283
Person / Time
Site:	Millstone
Issue date:	06/24/1997
From:	Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kenyon B NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20141E286	List: ML20141E283 ML20141E310 ML20141E341
References
50-245-97-02, 50-245-97-2, 50-336-97-02, 50-336-97-2, 50-423-97-02, 50-423-97-2, EA-97-205, EA-97-206, EA-97-304, NUDOCS 9707010020
Download: ML20141E283 (4)

See also: IR 05000245/1997002

Text

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June 24,1997

EA Nos.97-205

97-206

97-304

Mr. Bruce D. Kenyon

President and Chief Executive Officer

Northeast Nuclear Energy Company

P.O. Box 128

Waterford, Connecticut 06385

Dear Mr. Kenyon:

SUBJECT: NRC COMBINED INSPECTION 50-245/97-02; 50-336/97-02; 423/97-02 and ,

NOTICE OF VIOLATION

All three units remained in cold shutdown status throughout this inspection period. NU

management changed the recovery strategy to shift from three units in parallel to a lead

plant concept. Unit 3 was designated as the lead unit, and on May 27,1997, the unit was

declared ready for independent Corrective Action Verification Process. Recovery managers

for Units 1 and 2 assumed responsibility for Unit 3 physical plant readiness and regulatory

readiness, respectively. Processes and management changes continued during this period.

Although we have observed progress in the configuration management program, the NRC

staff continued to identify violations of NRC requirements during this inspection period.

We are particularly concerned about the repetitiveness and number of examples where

radiation workers fail to wear dosimetry in the radiation protection areas. In addition, we

remain concern about the effectiveness of the correction action program, and the

reluctance of some staff to document deficiencies.

At Unit 1, a violation involved failure to translate correctly the plant design basis into

drawings and to implement appropriate administrative controls on the positions of certain

containment isolation valves in the main feedwater system. Additionally, NRC inspectors

identified that corrective actions were inadequate to address a Unit 2 single failure

vulnerability associated with an enclosure building damper. Finally, five examples of  ;

unauthorized radiological workers or workers lacking proper dosimetry entering or working l

in the radiologically controlled areas, one each in Units 1 and 3, and three in Unit 2, were

identified since the conclusion of our last inspection of this area. This is of particular

concern as it is a repetitive violation.

These violations are cited in the enclosed Notice of Violation, and the circumstances

surrounding the violations are described in detail in the enclosed report. Please note that k

you are required to respond to this letter and should follow the instructions specified in the j

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Mr. Bruce D. Kenyon 2

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enclosed Notice when oreparing your response. The NRC willme your response, in part,

to determine whether further enforcement action is necessary to ensure compliance witn

regulatory requirements.

This report also discusses several apparent violations of NRC requirements at Unit 1

pertaining to the conduct of containment leakage rate testing, extended operation beyond

the plant licensing basis without performing a safety evaluation foi the torus water

temperature, inoperability of the low pressure coolant injection (LPCI) systGm, failure to

trend condition reports, and failure to identify and correct significant conditions adverse to

quality associated with containment leak rate testing and fouling of LPCI system heat

exchanger tubes.

Over the last six months, NRC inspection reports have discussed 17 licensee event reports

at Unit 2 involving inadequate surveillances. These appear to be repetitive violations nd

are being considered collectively as an apparent volation.

These apparent violations at Units 1 and 2 are being considered for escalated enforcement

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

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Enforcement Actions" (Enforcement Policy), NUREG-1600. You will be advised by

separate correspondence of the results of our deliberations on these matters. No response

regarding these seven apparent violations is required at this time; however, any corrective

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actions deemed appropriate should be instituted in a timely manner. Please be advised that

the number and characterization of apparent violations descrit,ed in the enclosed inspection

report may change as a result of further NPC review.

Furthermore, the Unit 1 staff planned to perform a test of the core spray system in the

recirculation mode using normal surveillance procedures. An evaluation had not been

performed to verify that an unreviewed safety question did not exist in accordance with 10

CFR 50.59. Since a 50.59 review / screening had not been performed in preparation for this

test, the intervention of the NRC prevented a potential violation of NRC requirements. The

NRC is concerned that a weakness exists, which would have allowed the performance of

an unreviewed test to occur. This performance demonstrated a lack of send.vity for the

regulatory framework under which Millstone must operate. Consequently, we request that

you inform us in writing within 30 days of the receipt of this letter of your completed

corrective actions to address this issue.

This report further discusses a review of the corrective action program at Unit 1, which

indicated that overall, the implementation of procedure RP-4, " Corrective Action Program,"

revision 4 has resulted in only limited improvements in the corrective action process. The

revision of the condition report (CR) process was poorly implemented in that, specific

guidelines were not put in place to ensure the initiation and appropriate processing of CRs

for conditions adverse to quality. Additionally, there appears to be some reluctance on the

part of some Unit 1 staff to initiate condition reports.

At Unit 3, NRC followup of a licensee condition report identified an event reportable in

accordance with 10 CFR 50.73, and further NRC questions were raised regarding the

acceptability of the most limiting failure serving as the design basis for the Unit 3 steam

generator tube rupture analysis. Also, some design control weaknesses are documented in

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this report, which merit your continued attention to ensure that past programmatic

weaknesses in design control are not reflected in your current efforts to restore proper

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configuration management to the unit. Finally, while general improvements in the

radwaste program at Unit 1 were observed, clear lines of management responsibility for

] the liquid radwaste systems at Unit 3 still do not exist.

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

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

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Sincerely,

ORIGINAL SIGNED BY:

Wayne D. Lanning

l Deputy Director of inspections

l Special Projects Office, NRR

i

j Docket Nos 50-245

50-336

50-423

Enclosures:

1. Notice of Violation

2. NRC Combined Inspection Report 50-245/97-02; 50-336/97-02;50-423/97-02

cc w/enci:

N. S. Carns, Senior Vice President and Chief Nuclear Officer

M. H. Brothers, Vice President - Millstone, Unit 3

J. McElwain, Unit 1 Recovery Officer

M. Bowling, Jr., Unit 2 Recovery Officer

-D. M. Goebel, Vice President, Nuclear Oversight

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

P. D. Hinnenkamp, Director, Unit Operations

F. C. Rothen, Vice President, Work Services

J. Stankiewicz, Training Recovery Manager

R. Johannes, Director - Nuclear Training

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

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

Representative T. Concannon

E. Woollacott, Co-Chairman, NEAC

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Mr. Bruce D.' Kenyon 4

Distribution w/ encl-

Region 1 Docket Room (with copy of concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC

l FILE CENTER, NRR (with Oriainal concurrences)-

I

NRC Resident inspector

W. Axelson, DRA

,

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l

M. Kalamon, SPO, RI

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

D. Screnci, PAO  ;

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W. Travers, Director, SPO, NRR

Distribution w/ encl (VIA E-MAIL):

J. Andersen, PM, SPO, NRR l

M. Callahan, OCA j

R. Correia, NRR )

W. Dean, OEDO

S. Dembek, PM, SPO, NRR

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

D. Mcdonald, PM, SPO, NRR

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

S. Reynolds, Chief Assistant, SPO, NRR J

D. Screnci, PAO  ;

Inspection Program Branch (IPAS) l

DOCDESK I

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DOCUMENT NAME: G:\ BRANCH 6\ 97-02. ALL

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

'N' = No copy

0FFICE SP0(RJ lE SP0/f% _ l / l l

NAME DURIN V LANMhG ,

DATE 06/9 /97 6/24 06/'Lo /97 06/ /97 06/ /97 )

0FFICIAL RECORD COPY I

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