ML20249B081
| ML20249B081 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20249B079 | List: |
| References | |
| 50-423-97-82, EA-98-293, NUDOCS 9806220046 | |
| Download: ML20249B081 (3) | |
Text
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A ENCLOSURE 1 NOTICE OF VIOLATION l
1 Northeast Nuclear Energy Company Docket No. 50-423 1
Millstone Nuclear Power Station, Unit 3 License No. NPF-49
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EA 98 293 During an NRC inspection conducted from February 9, through February 20,1998, violations of NRC requirements were identified. In accordance with the "Genen)
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, tne violations are listed below:
A.
Criterion XVI of 10 CFR 50, Appendix B, requires, in part, that measures must be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. For significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
1)
- Contrary to the above, between 1992 and 1998, appropriate corrective actions were not taken to prevent a recurring air binding problem for the boric acid transfer pumps. The boric acid transfer pumps are part of Technical Specification required reactivity control systems and provide a boron injection flow path to the Reactor Coolant System. There has been a chronic air binding problem with the pumps that periodically rendered the.
sub-system inoperable. The condition had been identified six times, but had not been corrected.
This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.
2)
Contrary to the above, appropriate corrective actions were not completed prior to closing an automated work order (AWO) associated with a modification to correct flow indication anomalies on service water instrumentation. Specifically, final setpoint calibrations for flow indicators 3SWP-Fl-059 A, B and C had not been accomplished prior to closing the AWO.
This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.
B.
Technical Specifications 6.2.3.1 and 6.5.2.6 require the Site Operations Review Committee (SORC) to review independent Safety Engineering Group (ISEG) procedures.
Contrary to the above, some ISEG procedures were not reviewed by the SORC. For example, on November 11,1997, Condition Report M3-97-3974 documented an audit finding that NOOP 3.04, Nuclear Safety Engineering Group Functions and Responsibilities -ISEG and OE Assessment, had not been reviewed by the SORC.
l This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423, 9906220046 990611 PDR ADOCK 05000423 G
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. Enclosure'1 2
C.
Criterion V of 10'CFR 50, Appendix B, requires, in part, that activities affecting
- quality be prescribed by instructions or procedures of a type appropriate to the
-circumstances. Further, it requires that these activities be accomplished in accordance with these instructions or r ocedures, 1)
Contrary to the above, written procedures for design bases documents were -
not adhered to in the following instances:
A)
PI 29, Development of Millstone Unit 3 Design Bases Summary-Documents, requires Design Basis Summaries (DBS) for Maintenance Rule (MR) Group 1 and 2 systems. However, in the summer of 1997 when the Emergency Lighting System was moved from MR Group 3 to 2, a DBS was not developed. Additionally, the Chemical & Volume Control System, a MR Group 1/2 system, was not completely included in a DBS.
B)
NGP 5.28, Design Basis Documentation Packages, Rev. 3,10/15/97, Step 1.1.2, requires documenting changes to the Safety Functional Requirements (SFR) Manual as Design Change Notices (DCN) and then entering the DCN numbers into the Generation Records -
Information and Tracking System (GRITS). As of February 1998, two revisions to the SFR Manual were issued without issuing DCNs or updating the GRITS.
This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.
2)
RP 4, Corrective Actions Program, Rev. 5, Attachment 3, Condition Report (CR) Initiation and Classification Guidelines, includes in the Level 2 guidelines: an external station commitment not adhered to; or a deficiency in material that, if lef'. uncorrected, could affect safe reliable plant operation.
Contrary to the 6bove, in 1997, CR M3-97-4672,which is related to an external station commitment not adhered to (NRC Generic Letter GL 89-13),
and CR M3-97-4346,which is related to'a material deficiency that, if left
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uncorrected,'could affect safe reliable plant operation (inadequate corrosion control), were inappropriately classified as Level 3 CRs.
This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.
D.
Technical Specification 6.2.1.d requires, in part, that those who carry out health physics functions have sufficient organizational freedom to ensure their independence from operating' pressures.
Contrary to the above, the Radiation Protection Manager reports to the Maintenance Manager, which does not ensure independence from operating pressures. Also, Regulatory Guide 8.8, Section C.1.b(3), states in part, that: The Radiation
~ Protection Manager (RPM) (onsite) has a safety function and responsibility to both employees and management that can best be fulfilled if the individual is independent of station divisions, such as operations, maintenance, or' technical support, whose prime responsibility is continuity or improvement of station operability.
1This is a Severity Level IV violation (Supplement il for Docket No. 50-423.
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3-For the violations listed above and pursuant to the provisions of 10 CFR 2.201, Northeast
' Nuclear Energy Company'is hereby required to submit a written statement or explanation x within 30 days of receipt of the letter transmitting this Notice.of Violation (Notice) to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555 with a copy to the Director, Special Projects, Nuclear Reactor Regulation and a copy to the NRC Resident inspector at the facility that is the subject of this notice. This reply should be clearly marked as a " Reply to a Not;ce of Violation" and should include for each violation:- (1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the l
corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. if an adequate reply is not received within the required time specified in this notice, an order or a Demand for information may be issued as to why the license should not be modified, suspended or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to athe Director, Office of Enforcement, United States Nuclear Regulatory Commission, u
Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), it should l
not, to'the extent possible, include any personal privacy, proprietary or safeguards c~
+information so that it can be placed in the PDR without redaction. If personal privacy or -
proprietary information is necessary to provide an acceptable response, then p! ease provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mug specifically identify the portions of your response that you seek to have withheld and provide in detail the bases of your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a
_J request for withholding confidential commercial or financial information). If safeguards R
information is necessary to provide an acceptable response, please provide the level of
. protection described in 10 CFR 73.21.
1 Dated at King of Prussia, Pennsylvania
-this 11th Day of June 1958 i
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