IR 05000423/1998207

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-423/98-207 Issued on 980619.Ltr Provided Partial Response for Unit 3 Violation;Units 1 & 2 to Be Provided Separately

ML20237C136
Person / Time
Site:	Millstone
Issue date:	08/13/1998
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO.
References
50-423-98-207, NUDOCS 9808200239
Download: ML20237C136 (3)

Text

SUBJECT:

NRC INSPECTION REPORT NO. 50-423/98-207 - REPLY

Dear Mr. Bowling:

This letter refers to your July 17,1998 correspondence, in response to our June 19,1998 letter and Notice of Violation. Your letter provided a partial response for a Unit 3 violation; Units 1.and 2 are to be provided separately.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, Original Signed by: R. J. Urban, for:

Jacque P. Durr, Chief Inspections Branch Millstone Inspections

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Docket Nos. E0-245; 50-336; 50-423

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Mr. M. cc:

B. Kenyon, President and Chief Exec.tive Officer Nuclear Group M. H. Brothers, Vice President - Operations J. McElwain, Recovery Officer - Millstone Unit 2 l

J. Streeter, Recevery Officer - Nuclear Oversight I

P. D. Hinnenkamp, Director - Unit 3 J. A. Price, Director - Unit 2 D. Amerine, Vice President - Human Services E. Harkness, Director, Unit 1 Operations J. Althouse, Manager - Nuclear Training Assessment Group F. C. Rothen, Vice President, Work Services J. Cantrell, Director - Nuclear Training (CT)

S. J. Sherman, Audits and Evaluation cc: wicopy of Licensee's Response Letter L. M. Cuoco, Esquire J. R. Egan, Esquire

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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 l

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Mr. M. ') distribution w/cv of licensee resconse ltr:

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Region 1 Docket Room (with ragy of concurrences)

Nuclear Safety Information Center (NSIC)

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SPO Secretarial File, Region 1 NRC Resident inspector

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H. Miller, Reional Administrator, RI B. Jor:es, PIMB/ DISP

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W. Lanning, Deputy Director of Inspections, SPO, Ri D. Screnci, PAO J. Andersen, PM, SPO, NRR M. Callahan, OCA R. Correia, NRR t3. McCabe, OEDO S. Dembek, PM, SPO, NRR E. Imbro, SPO, NRR D. Mcdonald, PM, SPO, NRR W. Dean, Project Directorate, NRR S. Reynolds, Chief, ICAVP Oversight, SPO, NRR inspection Progrcm Branch DOCUMENT NAME: 1:\\ BRANCH 6\\REPLYLTR\\98-207.RPY To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure

"N" = No copy

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NAME NJBLUMBERG/dtQ7'b JPDURR Cf,

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gg gg hope Ferry Rd. (Route 156), Waterford, CT 06385

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Nuclear Energy En. tone Nuclear Power Station

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Northeast Nuclear Energy Company

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P.O. Box 128 Waterford, CT 06385-0128 (860) 447-1791 Fax (860) 444-4277 The Northeast Utilities System I

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JUL l 71998 Docket No. 50-423 B17361 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

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t Millstone Nuclear Power Station Unit No. 3 Response to a Notice of Violation Nuclear Regulatory Commission Inspection Repon 50-423/98-207 By letter dated June 19, 1998, the Nuclear Regulatory Commissica (NRC) Special Projects Office transmitted the results of the above referenced combined inspection report. The letter included a Notice of Violation (NOV) citing seven areas where NNECo's activities were not in compliance with Nuclear Regulatory Commission regulations. Six of the seven citations contained in the Notice of Violation pertain to Millstone Units 1 and 2 and will be adiressed in separate correspondence.

Item "G" of the Notice of Violation pertains to the Millstone Unit 3 Materials, Equipment and Parts List (MEPL) Program. NNECo's response to this violation is provided in Attachment 1 to this transmittal.

Attachment 2 provides a summary of NNECo's (

commitments contained in this submittal.

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i in addition to responding to the Unit 3 Notice of Violation, the NRC requested that NNECo provide its plan and schedule for bringing MEPL related

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degraded /nonconform'ng items into full compliance with 10 CFR 50, Appendix B i

requirements in accordance with the guidance provided in Generic Letter 91-18, I

Revision 1.

In summary, NNECo has completed its review of safety related components to ensure properly qualified replacement parts were installed during

maintenance activities. Operability reviews have been completed as required where unqualified parts were installed. The noted discrepancies did not result in any loss of l

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U.S. Nuclear Regulatory Commission B 17361\\Page 2

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functional capability and will be reconciled by upgrading the parts classifications in accordance with existing plant procedures. Final disposition of outstanding deficiencies documented under Operability Determinations MP3-047-98, MP3-048-98, MP3-070-98

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will be completed by March 31,1999. Additionally, administrative controls have been established to ensure that non-safety related parts are not issued for use in safety related components until the appropriate evaluations are documented.

l Should you have any questions regarding the information contained herein, please contact Mr. David A. Smith at (860) 437-5840.

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Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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Martin L. Bowling, Jr.

J Recovery Officer - Technical Services i

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cc: H. J. Miller, Region l Administrator W. D. Lanning, Deputy Director, inspections, Special Projects Office J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 W. D. Travers, Ph.D., Director, Special Projects Office E. V. Imbro, Deputy Director, ICAVP Oversight, Special Projects Office S. A. Reynolds, Branch Chief, ICAVP Oversight, Spe.cial Pmiects Office

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Docket No. 50-423 B17361

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Attachment 1 Millstone Nuclear Power Station Unit No. 3 Response to a Notice of Violation Nuclear Regulatory Commission Inspection Report 50-423/98-207

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July 1998

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U.S. Nuclear Regulatory Commission B17361\\ Attachment 1\\Page 2 Nuclear Reaulatory Commission Citation "B" (50-423/98-207-15)

Restatement of the Violation

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I 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," requires in part, that measures be established to assure that conditions adverse to quality, such as defective material and equipment, and nonconformances, are promptly identified and corrected.

I 10 CFR 50 Appendix B, Criterion Vil, " Control of Purchased Material, Equipment, and Services," requires in part, documentary evidence that shows purchased material or equipment met specific requirements, such as codes, standards or specifications.

Licensee Specification SP-ST-ME-944, " Standard Specification;. Material, Equipment, and Parts Lists for in-Service Nuclear Generation Facilities (MEPL Program)," Revision 4, dated May 21,1997, states, in part, that a nonconformance report (NCR) is required for certain MEPL classification upgrades and that the past maintenance work history and purchase histoiy are to be evaluated by the NCR.

NRC Information Notice 88-95, " Inadequate Procurement Requirements imposed by Licensees on Vendors," dated December 8, 1988, discusses the handling of functionally important parts in ASME Code components as safety related; and indicates that compliance with the ASME Code is not always sufficient to ensure compliance with 10 CFR 50, Appendix B.

Contrary to the above, as of February 9,1998, NCR 397-010 had been approved for the MEPL upgrade of parts in 2431 safety-related components, without the performance of specific part or component maintenance work history and purchase history reviews and evaluation. Furthermore, this NCR did not adequately consider the l

functional importance of certain parts installed in ASME Code components and thus i

tailed to identify that non-safety related parts had been procured and installed in 29 of j

thase ASME components.

NNECo's Response l

NNECo agrees with the violation.

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U.S. Nuclear Regulatory Commission B17361\\ Attachment 1\\Page 3 Reason for the Violation

~~he cause of the violation is attributed to human error (i.e., inappropriate judgment).

.co decision to waive the specific component work history reviews was based on the invalidated assumption that re lacemeat parts for the affected c'omponents had been procured to the original equipment vendor / supplier technical standards thereby maintaining the integrity of the original component design basis.

Corrective Actions and Results Achieved Work history reviews have been conducted for compon.ents associated with NCR 397-010 as well as the remaining scope of unreviewed, Millstone Unit 3, maintained safety related components.

These maintenance and procurement history reviews have identified administrative deficiencies associated with approximately eighty safety related components. Five Condition Reports (M3-98-1806, M3-98-1807, M3-98-1828, M3-98-1855, and M3-98-2667) were written to identify the deficiencies and track resolution of the issues. Three operability determinations (MP3-047-98, MP3-048-98, MP3-070-98)

documented as a result of the Condition Reports concluded that the affected components are operable without operating mode restrictions.

Personnel involved with the determination of non-applicability of work history reviews associated with NCR 397-010 have been counseled.

Corrective Actions to Avoid Future Violations Procedures supporting implementation of tne Millstone Unit 3 Material, Equipment and Parts List (MEPL) Program requirements have been upgraded. Additional controls have been established for the issuance of parts in support of plant maintenance

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activities. Non-safety grade parts are not issued for use in safety related equipment 3 (,

until parts evaluations to current standards have been documented.

Date When Full Compliance Will Be Achieved Final disposition of outstanding deficiencies documented under Operability Determinations MP3-047-98, MP3-048-98, MP3-070-98 will be completed by March 31, 1999.

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Docket No. 50-423 B17361

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l Attachment 2 Millstone Nuclear Power Station Unit No. 3 Response to a Notice of Violation Nuclear Regulatory Commission inspection Report 50-423/98-207

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U.S. Nuclear Regulatory Commission B17361\\ Attachment 2\\Page 2 List of Reg' latory Commitments u

The following table identifies those actions committed to by NNECo in this document.

Please notify the Manager - Millstone Unit No. 3 Regulatory Compliance at the Millstone Nuclear Power Station Unit No. 3 o' f any questions regarding this document or any associated regulatory commitments.

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Commitment Description Committed Date Number or Outage B17361-01 Final disposition of outstanding deficiencies March 31,1998 documented under Operability Determinations I

MP3-047-98, MP3-048-98, MP3-070'98 will be

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completed by March 31,1999.

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