View source for B16495, Responds to NRC Re Violations Noted in Insp Rept 50-423/97-80.Corrective Actions:Revised Integrated Maint Program Manual Program Instruction PI-1.1, Phase 1 Scoping & Conducted Evaluation Using New Instructions

{{Adams
| number = ML20140D244
| issue date = 06/06/1997
| title = Responds to NRC Re Violations Noted in Insp Rept 50-423/97-80.Corrective Actions:Revised Integrated Maint Program Manual Program Instruction PI-1.1, Phase 1 Scoping & Conducted Evaluation Using New Instructions
| author name = Brothers M
| author affiliation = NORTHEAST NUCLEAR ENERGY CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000423
| license number = 
| contact person = 
| document report number = 50-423-97-80, B16495, NUDOCS 9706100304
| title reference date = 05-08-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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Docket No. 50-423                    )
B16495 Re: 10CFR2.201 U.S. Nuclear Regulatory Commission j                                Attention: Document Control Desk 4
Washington, DC 20555                                                                                                    ,
l 1                                                            Millstone Nuclear Power Station, Unit No. 3 Reply to Notice of Violation 50-423/97-80-01 j                                                                     Maintenance Rule Inspection 3
.                                 In a {{letter dated|date=May 8, 1997|text=letter dated May 8,1997}}, the NRC transmitted the results of their Maintenance l          ,                      Rule Program implementation inspection conducted at the Millstone Station on March 17-21,1997. The NRC Inspection Report concluded that ten systems at Millstone Unit j                                 No. 3 were omitted from the scope of our Maintenance Rule Program contrary to 10CFR50.65(b)(1) and (2), which required implementation by July 10,1996.
Our review of the inspection Report identified two items which differ from the results of j                                 our investigation and the inspection exit meeting results. The items are related to the i                                scoping decision for the radiation monitoring panel, and the safety classification of the                              ,
:                                 emergency lighting' battery pack supports. These items were subsequently discussed with members of the NRC Staff from Region 1 and the Millstone Unit No. 3 Resident inspectors during two conference calls held on May 29 and June 3,1997. It was agreed that the details presented in the conference call should be addressed in our response to the Notice of Violation. Our interpretation of these two items is discussed in our reply to the violation contained in Attachment 2.
NNECO's commitments associated with the response are contained within Attachment i to this letter.                                                                                            ,
Attachment 2 provides our reply to the Notice of Violation pursuant to the provisions of                               i 10CFR2.201.
9706100304 970606 PDR       ADOCK 05000423 IllI!.IlI!.IS.$I
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U.S. Nucl=r R gulatory Commission l           B16495\Page 2 L
          , Should you have any questions regarding this submittal, please contact Mr. David Smith (860) 437-5840.
i NORTHEAST NUCLEAR ENERGY COMPANY AfN            .
M. H. Brothers      '"                ^
Vice President - Millstone Unit No. 3 6
Attachments (2) cc:   H. J. Miller, Region i Administrator J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 W. D. Travers, PhD, Director, Special Projects Office i
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Docket No. 50-421
"                                                                                                          16495 3
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i Attachment 1 i
Millstone Nuclear Power Station, Unit No. 3 NNECO's Commitments in Response To NRC Combined inspection Report 50-245/97-80,50/336/97-80, and 50-423/97-80 June 1997

U.S. Nucl:cr Regulatory Commission                                                                 l l
B16495\ Attachment 1\Page 1 l
Enclosure List of Regulatory Commitments
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The following table identifies those actions committed to by NNECO in this document.
Please notify the Manager - Nuclear Licensing at the Millstone Nuclear Power Station,              ;
Unit No. 3 of any questions regarding this document or any associated regulatory                    !
commitments.
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Number                                             Commitment                  Due B16495-01      issue the guidelines and instructions currently used for implementation of the Maintenance Rule Prograrn           July 15,1997          ,
as controlled instructions.                                                          !
B16495-02      Complete the remaining activities associated with the                                j implementation of the Maintenance Rule (risk                                        j significance determination, performance criteria              July 15,1997 development, historical performance assessment, and                                  !
development of system basis documents) for the new systems added to the scope.                                                          I l

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                   -                                                                                Docket No. 50-423 B16495 l
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Attachment 2 Millstone Nuclear Power Station, Unit No. 3 Reply to Notice of Violation 50-423/97-80-01 NRC Combined Inspection Report 50-245/97-80,50-336/97-80 and 50-423/97-80 L
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U.S. Nuclear Regulttory Commission l                      B16495%ttachment 2\Page 1 i                                   -
l Restaternent of the Violation During an NRC inspection conducted March 17-21, 1997, violations of NRC
;                      requirements were identified. In accordance with the "Gensral Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
: 1.                 10CFR50.65(b)(1) and (2) require, in part, that the scope of the monitoring program specified in Section (a)(1) shall include safety-related and non-safety related structures, system, and components (SSCs), as follows: (a) safety-related SSCs and (2) non-safety related SSCs: (i) that are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs): or (ii) whose failure could prevent safety-related SSCs from fulfilling their safety- related function; or (iii) whose failure could cause a reactor scram or actuation of a safety-related system.                                                    I l
Contrary to the above, as of November 18,1996 for Millstone Unit No.3, the               I facility failed to include the following SSCs within the scope of the maintenance        ;
rule:
J e          fuel assemblies - safety-related                                              '
                                          .          fuel handling system - safety-related e          alternate shutdown panel - safety-related e          radiation monitoring panel - safety-related e          emergency lighting battery pack support - safety-related e          tunnel under the service building - safety-related e          fire protection - mitigate accidents or transients e          post accident sampling - used in EOPs e          communication - used in EOPs e          emergency lighting - used in EOPs This is a Severity Level IV violation.
Reason for the Violation:
NNECO agrees with this violation, with the exceptions noted belew, that Millstone Unit No. 3 failed to include the above SSCs within the scope of t'ne Maintenance Rule Program requirements by July 10,1996.
                       .        Our review indicates that the radiation monitoring panel was in-scope and safety-related at the time of the inspection. The radiation monitoring pane! is not listed as             j a separate system within the scoping documentation but is a component within the                   !
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l                     U.S. Nucleer Regulatory Commission
                    - B16495\ Attachment 2\Page 2 l                   .       Radiation Monitoring System which was in-scope and safety-related at the time of                1 l                           the inspection. During the November 1996 inspection, the inspectors identified that the Main Control Board system was not in-scope although this system is not listed in the violation. The Main Control Board system was added to scope subsequent to l                           the inspection.
                      . The emergency lighting battery pack supports are listed in FSAR Table 3.2-1, " List of QA Category 1 and Seismic Category i Structures, Systems, and Components,"
which does not clearly delineate the difference between which SSCs are QA Category 1 (safety related) and Seismic Category 1. Master Equipment and Parts                   ,
List (MEPL) Determination No.1143, the document which defines the safety related functions of plant equipment, indicates that the emergency lighting SSCs are not
!                           safety related. The Emergency Lighting System was added to the Maintenance Rule scope due to the EOP scoping criterion, but not the safety-related criterion.
Between November 1996 and the March 1997 Baseline inspection, Millstone Unit No. 3 issued two Adverse Condition Reports (ACRs M3-96-1211- and M3-96-1212) to document this condition, evaluate the causes and perform a review of the initial scoping effort. The results of this effort identified other systems in addition to those identified during the NRC inspection, which were required to be added to the Maintenance Rule Program scope. Millstone Unit No. 3 revised the initial decision documentation associated with these systems and included them in scope as of January 30,1997.
However, this was after the July 10,1996 rule implementation date.
The causes which contributed to this event are:
: 1.          Inadeauate Procedure Guidance The instructions for performing the Maintenance Rule Program scoping review for the " Safety Related" scoping criterion only relied on the data contained in the NU Production Maintenance Management System (PMMS) data base and did not include a review of appropriate sections of the FSAR.
: 2.          Inadeauste Procedure Comoliance The instructions related to the " Safety Related" scoping criterion state that "The basis for removal of a system from scope must be documented." Contrary to this statement, systems contained Category 1 components or identification Numbers without any justification or documentation stating why the SSCs did not need to be included in scope.
: 3.          Inadeouate Response to Industry Data                                                         '
l The original scoping decision process was developed consistent with industry l                                 practices at the time. However, expectations changed as indicated in the initial l                                 baseline inspections conducted at other utilities and discussed in the Nuclear l                                 Energy Institute (NEI) conference held in late October,1996. The pre-baseline inspection conducted in November 1996 occurred prior to NU taking action to j                                 address the scoping issues identified in the industry baseline inspection results.
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U.S. Nucle:r R:gulatory Commission B16495\ Attachment 2\Page 3 Corrective Steps Taken and Results Achieved:
                .       The Integrated Maintenance Program (IMP) Manual Program instruction PI-1.1,
                        " Phase 1 Scoping," for performing the Maintenance Rule scoping decisions was revised. This Manual now addresses the specific technical weaknesses identified and the overall philosophy or intent of the scoping process.            l
                .       A complete scoping evaluation was conducted using the new instructions            j
.                       resulting in numerous systems being added to the rule scope including those        l
.                       identified in the violation.                                                      1
               ' Corrective Steps That Were/Will Be Taken to Avoid Further Violations:
l               .       Millstone Unit No. 3 conducted " stand-down" meetings in which all work was stopped to discuss and stress the importance of procedure compliance. This l                       was done as a generic concern related to procedure compliance and was not specifically related to this violation.
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                .       The guidelines and instructions currently used for Maintenance Rule Program implementation will be issued as controlled instructions.
* The remaining activities associated with the implementation of the Maintenance Rule (i.e. risk significance determination, performance criteria development, historical performance assessment, and development of system basis documents) for the new systems added to the rule scope are in progress.
Date When Full Compliance Will Be Achieved:
Millstone Unit No. 3 will be in full compliance by July 15,1997 when all Maintenance      i Rule activities for the systems added to scope are complete and the implementing          !
guidelines and instructions are issued as controlled instructions.
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