ML20153F765
| ML20153F765 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/22/1998 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-245-98-207, 50-336-98-207, 50-423-98-207, NUDOCS 9809290239 | |
| Download: ML20153F765 (2) | |
See also: IR 05000245/1998207
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September 22, 1998
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Mr. . M. L. Bowling, Recovery Officer - Technical Services
c/o Ms. P. A. Loftus, Director - Regulatory
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' Affairs for Millstone Station
NORTHEAST NUCLEAR ENERGY COMPANY
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PO Box 128
.Waterford, CT 06385
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SUBJECT:
COMBINED NRC INSPECTION NO. 50-245,336,423/98-207
Dear Mr. Bowling:
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This letter refers to your July 20,1998 correspondence, in response to our June 19,1998
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letter. We note that this letter only addresses corrective actions for several violations
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identified at U lit 2: and, that corrective actions for violations identified at Units 1 and 3
were addressed in separate correspondence to the NRC.
Thank you for informing us of the corrective and preventive actions for Unit 2 violations
documented in your letter. These actions will be examined during a future inspection of
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1your licensed program.
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Your cooperation with us is appreciated.
Sincerely,
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ORIGINAL SIGNED BY:
Jacque P. Durr, Chief
Inspections Branch
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Millstone Inspection Directorate
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Docket Nos. 50-245:50-336;50-423
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9809290239 980922
ADOCK 05000245
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Mr. M. L. Bowling
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cc:
B. Kenyon, President and Chief Executive Officer - Nuclear Group
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M. H. Brothers, Vice President - Operations
J. McElwain, Recovery Officer - Millstone Unit 2
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J. Streeter, Recovery Officer - Nuclear Oversight'
P. D. Hinnenkamp, Director - Unit 3
J. A. Price, Director - Unit 2
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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-
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J. Cantrell, Director - Nuclear Training (CT)
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S. J. Sherman,' Audits and Evaluation
cc w/ cv of Licensee Response Ltr.
L. M. Cuoco, Esquire
-J.'R Egan Esquire
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V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Centrol
' 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
Distribution w/cv of licensee resoonse ltr:
Region i Docket Room (with ggs.y of concurrences)
Nuclear Safety Information Center (NSIC).
PUBLIC
FILE CENTER, NRR (with Oriainal concurrences)
Millstone inspection Directorate Secretarial File, Region l
NRC Resident inspector
H. Miller, Regional Administrator, R1
B. Jones, PIMB/ DISP
W. Lanning, Director, Millstone inspection Dirsetorate, R1
D. Screnci, PAO
DOCUMENT NAME: I:\\ BRANCH 6\\REPLYLTR\\98207U2.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
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DATE.
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OFFICIAL RECORD COPY
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Nortlicast
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Nuclear Energy
waistone Nudear Power Station
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Northeast Nudear Energy Company
P.o. Box 128
Waterford, Cr 06385-0128
(860) 447 1791
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Faz (860) 444-4277
'Ihe Nortleast Utilities System
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JUL 2 01998
Docket No. 50-336
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B17350
Re: 10CFR2.201
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555
s
Millstone Nuclear Power Station, Unit No.'2
Facility dperating License No. DPR-65
Reply to Notice of Violation
insoection 50-245/98-207: 50-336/98-207: 50-423/98-207
In.a letter dated June 19, 1998,(U the NRC transmitted the results of an inspection
conducted at the Millstone Nuclear Power Station from March 1,1998, to April 27,1998.
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The NRC Inspection Report concluded that certain activities at Millstone Unit No. 2 were
not in compliance.with NRC regulations, it was determined.that Northeast Nuclear
Energy Company (NNECO), in five instances at Millstone Unit No. 2, was not in
compliance with NRC regulations. Inspectors identified (1) the failure to establish
procedures for' draining safety-related systems, as required by technical specifications;
(2) the failure to measure instrument minimum accuracies for wind speed channels as
- part of the meteorological monitoring program,' as required by technical specifications;
(3) the failure to test four digital ~ liquid and gaseous effluent radiation monitors in a
manrer consistent with the technical specification definition for a Channel Functional
Test,, (4) the failure to adequately implement a reactor building closed cooling water
(RBCCW) system operating procedure, in that an RBCCW valve was placed in service
before operability of the valve was established through post-maintenance testing, which
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- contributed to the temporary loss of the RBCCW system; and (5) an instance in which a
proposed revision to the final safety analysis report provided in our September 3,1997,
submittal contained incomplete information regarding our ability to replenish fuel oil to
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- th a supply tanks for the emergency diesel generators.
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Wayne D. Lanning to M. L Bowling, "NRC COMBINED INSPECTION 50-245/98-
(4
207; 50-336/98-207; 50-423/98-207 and NOTICE OF VIOLATION," dated June 19,
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1998.
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U.S. Nuclear Rcgulatory Commis: ion
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B17350\\Page 2
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NNECO's commitments associated with the response are contained within Attachment 1
to this letter.
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Attachment 2 provides our reply to the Notice of Violation pursuant to the provisions of
Should you have any questions regarding this submittal, please contact Mr. Ravi Joshi at
(860)440-2080.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
Martin L. Bowling, Jr.
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Recovery Officer - Technical Services
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Attachments (2)
cc:
H. J. Miller, Region I Administrator
D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2
D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2
W. D.' Travers, Ph.D., Director, Special Projects Office
W. D. Lanning, Deputy Director, Inspections, Special Projects Office
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J. P. Durr, Branch Chiefilnspections, Special Projects Office
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Docket No. 50-336
B17350
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Attachment 1 -
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Millstone Nuclear Power Station, Unit No. 2
NNECO's Commitments
- In Response To
inspection 50-245/98-207; 50-336/98-207; 50-423/98-207
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July 1998
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U.S. Nuclear R@gulatory Commission
B17350\\ Attachment 1/Page 1
Enclosure
List of Regulatory Commitments
The following table identifies those actions committed to by NNECO in this document.
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Please notify the Manager - Regulatory Compliance at the Millstone Nuclear Power
Station, Unit No. 2 of any questions regarding this document or any associated regulatory
commitments.
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Number
Commitment
Due
B17350.01
Notice of Violation, item B, pertaining to 10CFR50.9, and
August 31,1998
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the surrounding situation, will be discussed with Millstone
Unit No. 2 management personnel involved in the
preparation of licensing submittals.
B17350.02
Establish procedures for draining various safety.related
December 31,1999
systems as identified in RG 1.33, Attachment A,
Paragr:
3, as required, to support system operation.
B17350.03
During
.e current cycle of operator requalification,
August 28,1998
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Opera'ic .s Department personnel will discuss the issues
and corrective actions associated with the violation
pertaining to not having all the procedures established for
draining various safety-related systems as identified in RG 1.33, Attachment A, Paragraph 3 and will discuss the
violation pertaining to not issuing an individual clearance
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in accordance with procedure OP 2330A, "RBCCW
System."
B17350.04
Perform
Surveillance
Procedure
C
400.2,
Completed
" Meteorological
Instruments
Calibration,"
for
the
May 6,1998
meteorolcgical wind speed loops.
B17350.05
Implement procedure changes and radiation monitor
August 31,1998
testing for the Clean Liquid Radwaste Effluent Monitor,
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Aerated Liquid Radwaste Effluent Monitor and the
Condensate Polishing Facility Waste Neutralizing Sump
Monitor.
B17350.06
Implement procedure changes and radiation monitor
Prior to entry into
testing for the Millstone Unit No. 2 Stack Noble Gas
Mode 4 from the
Effluent Monitor (High Range).
current outage
B17350.07
Perform post maintenance testing on valve 2-RB-4.1E.
Completed
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September 12,1997
B17350.08
Revise procedure OP 2265 to ensure that a drain
August 31,1998
procedure is developed when required.
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Docket No. 50-336 -
B17350
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Attachment 2
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Millstone Nuclear Power Station, Unit No. 2
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Reply to Notice of Violation
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Inspection 50-245/98-207; 50-336/98-207; 50-423/98-207
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July 1998
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U.S. Nuclear Regulatory Commission
B17350\\ Attachment 2\\Page 1
Milatone Unit No. 2
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Facility Oper ting License No. DPR-65
Reply to Hotice of Violation
Inspection 50-245/98-207; 50-336/98-207; 50-423/98-207
Restatement of Violation
B.
Paragraph (a) of 10CFR50.9, " Completeness and accuracy of information,"
requires that "Information provided to the Commission by an applicant for a
license or by a licensee or information required by a statute or by the
Commission's regulations, orders, or license conditions to be maintained by the
applicant or the licensee shall be complete and accurate in all material respects."
Contrary to the above, the licensee's submittal to the NRC dated September 3,
1997, which involved a proposed revision to the final safety analysis report to
address the fact that the emergency diesel generators (EDG) fuel oil supply
tanks did not have the required 7-day capacity, provided information that was not
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complete with respect to the following statement: "However, replenishment of
fuel oil could be accomplished via an offsite sourca."
This statement was
incomplete in that the methods to directly replenish the fuel oil via an offsite
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source had not been determined and that the licensee planned to utilize the site
emergency response organization to determine how to refill the fuel oil storage
tanks following an event. The September 3,1997, submittal did not describe the
fact that the fill connection to the fuel oil storage tanks had not been formally
established, necessary pumps and hoses had not been staged, and procedures
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and training had not been provided to replenish the supply tanks from a fuel oil
delivery truck.
This is a Severity Level IV violation (Supplemerit 1) for Docket No. 50-336.
Response to the Violation
NNECO does not dispute this violation.
Basis for the Response to the Violation
Although additional information could have been provided to the NRC, NNECO's
submittal of September 3,1997 accurately stated: "However, replenishment of fuel oil
could be accomplished via an offsite source." The basis for our licensing submittal was
that certain features of the fuel oil system were understood and that there was an
acceptable basis on which to conclude that further detailed discussion of, or procedures
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on, how the tanks would be replenished was not necessary. The Emergency Plan
procedures provide sufficient instruction to evaluate the need to order additional fuel oil
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U.S. Nucl::ar Regulatory Commission
B17350\\ Attachment 2\\Page 2
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from offsite within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a Loss of Coolant Accident (LOCA) or a Loss of Normal
Power (LNP). Sufficient time, based on utilizing the Technical Specification fuel oil
volume in the supply tanks, will be available for the Technical Support Center staff to
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provide load shedding recommendations, monitor the delivery of the fuel oil to the site,
and determine the best method to transfer the fuel oil to the supply tanks. Therefore,
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NNECO concluded that it was not necessary to include all the details in the operating or
Emergency Plan procedures. As a result, the licensing submittal did not include the
details of replenishment of fuel oil to the supply tanks from an offsite source. The NRC
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approved the license amendment application on January 23,1998.
After submittal but approximately the time the submittal was before the NRC for review,
Conditien Report M2-97-2007 was laitiated which identified that currently there are no
provisions to directly fill the fuel oil supply tanks. The investigation of the CR confirmed
that replenishment by a tank truck from offsite will be handled via recommendations
made by the Site Emergency Response Organization. It was also determined that
since conditions during or after a seismic event may change, it is not practical to
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attempt to document, via procedures, all possible conditions that may arise due to a
seismic event. In addition, it was verified that if the fuel oil is purchased from a local
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vendor, a delivery truck could pump the oil to the tank using the flame arrestor as a fill
connection.
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Corrective Steps Taken and Results Achieved
To increase awareness, this issue, and the surrounding situation, has been discussed
with the personnel directly involved in the preparation of the this licensing submittal.
This has also increased sensitivity to understand the details of how a task can or wi!! be
accomplished.
Corrective Steps That Will be Taken to Avoli Further Violations
in addition to the action noted above, this issue, and the surrounding situation, will be
discussed with the Millstone Unit No. 2 management personnel involved in the
preparation of licensing submittals. This will also increase the sensitivity to understand
the details of how a task can or will be accomplished.
Date When Full Compliance will be Achieved
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NNECO believes that based on the response to this violation we are currently in full
compliance with 10CFR50.9(a) relative to our September 3,1997 submittal which
involved a proposed revision to toe Final Safety Analysis Report to address the fact that
the emergency diesel generators (EDG) fuel oil supply tanks did not have the required
7-day capacity.
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B17350\\ Attachment 2\\Page 3
Restatement of Violation
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C.
Unit 2 Technical Specification 6.8.1.a requires that written procedures shall be
established, implemented, and maintained covering the activities recommended
in Appendix "A" of Regulatory Guide (RG) 1.33, " Quality Assurance Program
Requirements (Operation)."' RG 1.33, Appendix "A", Paragraph 3, recommends
procedures for draining various safety-related systems. An example would be
the Emergency Core Cooling Systems.
Contrary to the above, as of March 13,1998, with the exception of the Reactor
Coolant System, procedures had not been established for draining various
safety-related. systems listed in RG 1.33, Appendix "A", Paragraph 3.
One
' example was the Low Pressure Safety injection System.
This is a Severity Level IV Violation (Supplement 1) for Docket No. 50-336.
Reason for the Violation
NNECO does not dispute this violation and agrees with the assessment that
procedures have not been established for draining various safety-related systems listed
in RG 1.33, Appendix "A", Paragraph 3. Procedure OP 2265, " Requirements for
Draining and Filling Activities," was developed to ensure a series of activities, including
performance of procedure steps, were performed in a planned, sequenced and
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controlled manner. Due to lack of management o /ersight, the use and format of fill and
drain plans expanded to encompass steps which should have been incorporated into
formal procedures.
Corrective Steps Taken and Results Achieved
1. Operations Department management has reaffirmed expectations for department
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personnel relative to the development of procedures for drain and fill activities.
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2. A Required Reading Briefing has been issued to Operations personnel on this issue.
The above two items have heightened the awareness of Operations Department
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personnel relative to the requirements for having ' approved procedures when
performing drain and fill activities on systems identified iri RG 1.33, Appendix A,
Paragraph 3.
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Corrective Steps That Will be Taken to Avoid Further Violations
1., During the current cycle of operator requalification training Operations Department
personnel will discuss the issues and corrective actions associated with this
violation.
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B17350\\ Attachment 2\\Page 4
2. Procedures will be developed, as required, to support system operation.
An
example is the procedure developed recently to drain a portion of the Service Water
System to facilitate piping inspection and repairs.
Historically, this has been
performed using a drain plan.
3. Procedure OP 2265 will be revised to ensure that a drain procedure is developed
when required.
Date When Full Compliance will be Achieved
For draining evolutions,'which require procedures, a procedure will be developed prior
to the associated draining evolution. Therefore, NNECO is in full compliance with RG 1.33, Attachment A, Paragraph 3, pertaining to havirig procedures established for
' draining various safety-related systems.
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B17350\\ Attachment 2\\Page 5
Restatement of Violation
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D.
Table 3.3-8 of Unit 2 Technical -Specification 3/4.3.3.4 requires that the
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instrument minimum accuracies of the meteorological monitoring instrumentation
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channels (wind speed, wind direction, and delta temperature) be measured
semiannually.
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Contrary to the above, prior to April 24,1998, the instrement minimum accuracy
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of the wind speed channels were not measured as required by Table 3.3-8 of the
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Unit 2 TS 3/4.3.3.4.
This is a Severity Level IV violation (Supplement IV) for Docket No. 50-336.
Reason for the Violation
NNECO does not dispute this violation. The cause of this violation was inappropriate
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review in that the procedure was not reviewed and approved through the processes at
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Millstone Station. The previous method for calibrating the Meteorological Tower wind
speed loops should have been given closer scrutiny to verify compliance with the
Technical Specification definition for channel calibration.
Corrective Steps Taken and Results Achieved
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Common Surveillance Procedure, C SP 400.2, " Meteorological Instruments
Calibration," has been created. This surveillance includes the following checks for the
Meteorological Tower wind speed loops: 1) a verification of the anemometer starting
threshold (i.e. less than 1 MPH); and 2) rotation of the anemometer on the tower to a
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known RPM and readout of wind speed at the plant process computer (full loop check).
These changes bring the wind speed loop calibration into compliance with the
Technical Specification definition for channel calibration.
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Creation of Surveillance Procedure C SP 400.2 provides the guidance to perform the
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required calibration for the Meteorological Tower wind speed loops.
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Corrective Steps That Will be Taken to Avoid Further Violations
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None required.
Date When Full Compliance will be Achieved
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'NNECO was in full compliance with Table 3.3-8 of the Millstone Unit No. 2 Technical
Specifications 3/4.3.3.4, regarding the wind speed loop calibration, on May 6,1998.
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B17350\\ Attachment 2\\Page 6
Restatement of Violation
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E.
Unit 2 Technical Specification 3.3.3.9 states that the radioactive liquid effluent
monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE
with applicable alarm / trip setpoints set to ensure the limits of Specification
3.11.1.1 are not exceeded. The setpoints shall be determined in accordance
with methods and parameters as described in the Offsite Dose Calculation
Manual (OCDM).
Unit 2 Technical Specification 4.3.3.9 states that each
radioactive _ liquid effluent monitoring instrumentation channel shall be
demonstrated operable by performance of a channel functional test at the
frequency specified in Table 4.3-12. Unit 2 Technical Specification Table 4.3-
12(1) requires a quarterly channel functional test of the gross radioactivity
monitors for the Clean Liquid Radwaste Effluent Line, the Aerated Liquid
Radwaste Effluent Line, and the Condensate Polishing Facility Waste
Neutralizing Sump.
Unit 2 Technical Specification 3.3.3.10 states that the radioactive gaseous
effluent monitoring instrumentation channels shown in Table 3.3-12 shall be
OPERABLE with applicable alarm / trip setpoints set to erfhure the limits of
Specification 3.11.2.1 are not exceeded. Unit 2 Technical Specification 4.3.3.10
requires that each radioactive gaseous effluent monitoring instrumentation
channel shall be demonstrated operable by performance of a channel functional
test at the frequency specified in Table 4.3-13. Unit 2 Technical Specification
Table 4.3-13(2) requires a quarterly channel functional test of the Millstone 1
Main Stack Noble Gas Activity Monitor.
Unit 2 Technical Specification 3.3.3.1 states that the radiation monitoring
instrumentation channels shown in Table 3.3-6 shall be OPERABLE with
their alarmitrip setpoints within the specified limits.
Unit 2 Technical Specification 4.3.3.1
requires
that
each
radiation
monitoring
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instrumentation channel shall be demonstrated operable by performance
of a channel functional test at the frequency specified in Table 4.3-3. Unit 2
Technical Specification Table 4.3-3 requires a monthly channel functional
test of the Millstone 2 Main Stack Noble Gas Effluent Monitor (High Range).
Technical Specification 1.11, states that "A channel functional test shall be the
injection of a simulated signal into the channel as close to the primary sensor as
practicable to verify operability including alarm and/or trip functions."
Contrary to the above since 1996, each liquid and gaseous effluent monitoring
instrumentation channel was not demonstrated operable by performance of a
channel functional test in that: (1) for the gross radioactivity monitors for the
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Clean Liquid Radwaste Effluent Line, the Aerated Liquid Radwaste Effluent Line,
and the Condensate Polishing Facility Waste Neutralizing Sump, the monitors'
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B17350\\ Attachment 2\\Page 7
setpoints were lowered below background radiation levels rather than raising a
simulated signal to the monitors' setpoint values that were determined in
accordance with methods and parameters established in accordance with the
ODCM; and (2) for the Millstone 1 [2] Main Stack Noble Gas Activity [ Effluent]
Monitor [High Range], a simulated signal, which consists of changing the Rad
Conversion Factor to increase the count rate signal above the established
setpoint, is inserted into the digital portion of the circuit rather than "as close to
the primary sensor as practicable." As a result, the operability of the liquid and
gaseous digital radiation monitors was not fully tested because the ability of the
amplifiers and/or analog-to-digital conversion circuitry to process the count rate
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signal et the higher pulse frequency was not verified.
This is a Severity Level IV Violation (Supplernent 1) for Docket No. 50-336.
Reason for the Violation
NNECO does not dispute this violation. The cause of this violation was inattention to
detail during the procedure revision process.
Although the current method of
performing the channel functional test does verify the monitors will respond to a change
in radiation levels and the alarms will function, it does not meet the literal wording of the
definition in the Millstone Unit No. 2 Technical Specifications. Specifically, the current
method does not include the injection of a simulated signal into the channel as close to
the primary sensor as practicable to verify OPERABILITY including alarm and/or trip
functions.
In addition, the reason for restating the second paragraph of Notice of Violation, item 'E'
is that the paragraph as written refers to Technical Specification 3.3.3.10 which is for
the low range, analog, MP2 stack, Noble Gas Activity Monitor. Technical Specification 3.3.3.1 is for the high range, hital, MP2 stack, Noble Gas Effluent Monitor. The
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violation is only applicable to the digital liquid and gas effluent monitors.
Corrective Steps Taken and Results Achieved
The following instruments have been declared INOPERABLE and the unit has logged
into the appropriate action statements:
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Clean Liquid Radwaste Effluent Monitor
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Aerated Liquid Radwaste Effluent Monitor
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Condensate Polishing Facility Waste Neutralizing Sump Monitor
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Millstone Unit No. 2 Stack Noble Gas Effluent Monitor (High Range)
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B17350\\ Attachment 2\\Page 8
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Corrective Steps That Will be Taken to Avoid Further Violations
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The channel functional test procedures for the instruments identified above will be
revised to simulate a test signal into the channel as close as practicable to the primary
sensor to verify operability including alarm and/or trip functions. The instruments will be
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tested and returned to an OPERABLE status.
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Date When Full Compliance will be Achtsved
1. NNECO is currently in the ACTION statement for Technical Specification 3.3.3.9.
Based on this, procedure changes and radiation monitor testing will be implemented
for the Clean Liquid Radwaste Effluent Monitor, Aerated Liquid Radwaste Effluent
Monitor and the Condensate Polishing Facility Waste Neutralizing Sump Monitor
and NNECO will be in full compliance with Millstone Unit No. 2 Technical Specification 3.3.3.9 and Surveillance Requirement 4.3.3.9 by August 31,1998,
2. The Millstone Unit No. 2 Stack Noble Gas Effluent Monitor (High Range) is not
required to be operable until Mode 4.
Based on this, procedure changes and
radiation monitor testing will be implemented for the Millstone Unit No. 2 Stack
Noble Gas Effluent Monitor (High Range) and NNECO will be in full compliance with
Millstone Unit No. 2 Technical Specification 3.3.3.1 and Surveillance Requirement 4.3.3.1 prior to entry into Mode 4 from the current outage.
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B17350\\ Attachment 2\\Page 9
Restatement of Violation
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Unit 2 Technical Specification 6.8.1.a requires that written procedures be
established, implemented, and maintained for activities referenced in Appendix A
of Regulatory Guide 1.33, " Quality Assurance Program Requirements
(Operation)," Revision 2, February 1978. Item 3.e., " Procedures for Startup,
Operation, and Shutdown of Safety-Related PWR Systems," recommends that
instructions for energizing, filling, venting, draining, startup, shutdown, and
changing modes of operation should be prepared, as appropriate, for the
component cooling water system.
Procedure OP2330A,"RBCCW System," Rev.17, step 5.14.2 required a review
of automated work orders (AWOs) on the global clearance for draining the
Procedure OP2330A, step 5.14.3 required the
development of necessary individual clearances for AWOs prior to filling and
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venting the Facility 1 RBCCW header.
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Contrary to the above, procedure OP2330A, step 5.14.3 was not adequately
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implemented in that, during filling and venting of the Facility 1 RBCCW header
on September 2,1997, a necessary individual clearance was not developed for
an open AWO (M2-97-0207) [M2-97-02707] that governed replacement of the
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solenoid controlled actuator for valve 2-RB-4.1E, which was originally assigned
to the global clearance for draining the Facility 1 RBCCW header. An individual
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clearance was necessary because the retest for AWO NI2-97-0207 [M2-97-
02707] had not been performed to establish operability of the actuator for valve
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2-RB-4.1E, and this valve was performing the safety function of separating the
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operating Facility 2 RBCCW header from the non-operational Facility 1 RBCCW
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This is a Severity Level IV violation (Supplement 1) for Docket No. 50-336.
Reason for the Violation
Nr4ECO does not dispute this violation and agrees that work practices related to
preparing systems for post maintenance testing were deficient. The provisions of
Section 5.2.6, " Equipment Control," of ANSI N18.7, which require that until suitable
documentary evidence of tests is available equipment shall not be relied upon to fulfill
its intended safety function, were not appropriately implemented. The cause of this is
that expectations regarding this provision were not adequately established or
communicated.
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U.S. Nucinar Rcgulatory Commission
B17350\\ Attachment 2\\Page 10
Corrective Steps Taken and Results Achieved
1. Operations Department instruction 2-OPS-1.21b, Revision 0, " Work Control SRO
and Work Control Operator Responsibilities," which establishes the guidance
provided in Section 5.2.6 of ANSI N18.7, has been issued.
2. A Required Reading Briefing has been issued to Operations personnel on the
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lessons learned from the condition described in this violation. The Briefing includes
identifying equipment which provides facility separation and ensuring that it is not
used in this capacity unless post maintenance testing is satisfactorily completed.
Item 1 documents the expectations on post-maintenance testing activities and item 2
has heightenod the awareness of Operations Department personnel relative to post-
maintenance testing of components that can be considered a separation boundary.
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Corrective Steps That Will be Taken to Avoid Further Violations
1. During the current cycle of operator requalification training, Operations Department
personnel will discuss the issues and corrective acSons associated with this
violation.
Date When Full Compliance will be Achieved
NNECO was in full compliance with Millstone Unit No. 2 Technical Specification 6.8.1.a,
relative to this violation, on September 12,1997, which was the date when valve 2-RB-
4.1E was successfully tested.
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B17350\\ Attachment 2\\Page 11
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Additional Information
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Following the detailed discussion of violation (VIO 98-207-06) in Section U2 M8.1 of
inspection report, "NRC COMBINED INSPECTION 50-245/98-207; 50-336/98-207; 50-
423/98-207 and NOTICE OF VIOLATION," the NRC stated, "In the violation response,
the licensee is asked to address the concern that procedure WC 10 does not provide
instructions on the transfer of lifted lead markings from an original component to a
replacement component. This is a concern because this event was caused by the
incorrect transfer of lead markings and no independent verification was performed
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which could have identified the error. ANSI N 18.7-1976, paragraph 5.2.6, states that
lifted leads shall be controlled by an approved procedure which shall include a
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requirement for independent verification."
The following provides our response to the above request:
Lifted leads are currently addressed in WC 10, " Temporary Modifications," and WC 6,
" Independent and Dual Verification." NNECO plans to revise WC 10 to clarify that work
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on components (such as wim labeling), that could affect the installation configuration,
obtain review as required by WC 6.
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