IR 05000245/1985015

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-245/85-15

ML20138Q630
Person / Time
Site:	Millstone
Issue date:	12/04/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Opeka J NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8512270327
Download: ML20138Q630 (2)

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l DEC 4 1985 Docket No. 50-245 Northeast Nuclear Energy Company ATTN: Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:

Subject: Inspection No. 50-245/85-15 This refers to your letter dated November 7,1985, in response to our letter dated October 11, 198 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 progra Your cooperation with us is appreciate

Sincerely,

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"ciiginal Signed I<'t cygrat 3. h deusod Stewart D. Ebs,eter, Director Division of Reactor Safety cc w/ encl:

E. J. Mroczka, Vice President, Nuclear Operations W. D. Romberg, Station Superintendent D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Connecticut 8512270327 851204 E PDR ADOCK 05000245 -

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OFFICIAL RECORD COPY RL MILLI - 0001. a 11/27/85

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L Northeast Nuclear Energy C bcc w/ encl:

, Region I Docket Rocm (with concurrences)

. Management Assistant, DRMA (w/o encl)

' DRP Section Chief M. McBride, RI, Pilgrim

,/ . PSwetland, SRI, Haddam Neck s T. Rebelowski, DRI, Millstone 3 s J. Shea, LPM, NRR af cfh cjcl+)c DRS:RI DRS:RI DRS:RIl0 DRS:II Chung/ca' Anderson Durr Ebneter Y >T7 v/85 Mir /85 1 /;s/85W (~d "/85 tv 10

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e OFFICIAL RECORD COPY RL MILL 1 - 0002.0.0 i

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. NORTHEAST UTILITIES cenere On ce seiden street. Beriin. connect' cut wco*cw -.=o=aa-NEcUE NARTFORD CONNECTICUT 06141-0270 L t Ta Z" ;l " lJ"%',"n (203) ses-sooo November 7,1985 Docket No. 50-245 A05307 Mr. Stewart D. Ebneter, Director Division of Reactor Safety Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Gentlemen:

Millstone Nuclear Power Station, Unit N Inspection No. 50-245/85-15 In October,1985(l) Northeast Nuclear Energy Company was informed of a Notice of Violation which resulted from conditions identified during a special safety inspection conducted June 17 - June 28,1985. The purpose of this letter is to provide responses to Violation A and Violation B as contained in the notic Violation A Technical Specification 6.8.1 states in part: " Written procedures shall be established, implemented and maintained covering activities... recommended in Appendix 'A' of Regulatory Guide 1.33, February, 19 7 8...." This appendix requires that maintenance that can affect the performance of safety-related equipment should be properly performed in accordance with written procedures appropriate to the circumstance Contrary to the above requirements, two examples of a violation were identified as follows: As of June 28, 1985, written calibration procedures were not established for the calibration of safety-related pressure switches PS-2-16, PS-2-20, PS-2-54, and PS-2-56 which provide low suction pressure, start prohibit, interlocks for the safety-related Feedwater Coolant Injection (FWCI) pumps A and . On June 18, 1985, it was identified that the self-aligning rod-end bushing on a mechanical snubber, pipe support ICHR-8, of the safety-related isolat:on condenser had slipped partially out of the rod-end bushing housing, resulting in an inoperable isolation condenser system until repairs were made. A subsequent review of procedure MP 739.6,

" Mechanical Snubber Visual Inspection" revealed that the procedure was incapable of identifying the misaligned rod-end bushin (1) Stewart D. Ebneter letter to 3. F. Opeka, " Inspection Report 50-245/85-15," dated October 11,198 }W l '\\ \ W s

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Response Corrective Steps Which Have Been Taken and the Results Achieved Are:

Written procedures specifying calibration requirements, including setpoints, tolerances and restoration have been developed, reviewed and approved for instrumentation associated with the FWCI system and related equipmen Corrective Steps Which Will be Taken to Avoid Further Violations Are:

Newly developed and approved procedures are being utilized for the FWCI system during the present refueling outage. Reviews are presently being performed to ensure that Technical Specification requirements are met by existing surveillance procedures. These reviews will serve to identify the need for any additional procedure Date When Full Compliance Will be Achieved:

Review of Technical Specification requirements to determine the need for additional procedures will be completed by December 31, 1985. Any required procedures will be implemented by March 31,198 Response Corrective Steps Which Have Been Taken and the Results Achieved Are:

MP 739.6, Mechanical Snubber Visual Inspection, has been reviewed and revised to specifically address the visual inspection of rod-end bushing Additionally, MP 739.5, Inspection of Hydraulic Snubbers, has been revised to include inspection of these bushings. Both procedures have been reviewed by the PORC and have been approve Corrective Steps Which Will be Taken to Avoid Further Violations Are:

In accordance with the revised approved procedures for inspection of mechanical and hydraulic snubbers, visual inspections of rod-end bushings are being performed during the present refueling outag Date When Full Compliance Will be Achieved:

All required actions to ensure full compliance regarding this item have been complete Violation B Technical Specification 6.12.2 states that locked doors shall be provided to prevent unauthorized entry into each high radiation area in which the intensity of radiation is greater than 1,000 mrem /hr. The licensees administrative procedure (SHP) 4906, " Posting Radiological Controlled Areas," Section requires that all high radiation areas with general area dose rates greater than 1,000 mrem /hr shall have all entrances locked or shall be continuously guarded to i prevent unauthorized entry into those areas, l

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Contrary to the above requirement, on June 27, 1985, at approximately 1:00 PM, !

the door to the Scram Discharge Volume (SDV) high radiation area had been left '

unlocked and unattended. This area was posted with signs on the door "High Radiation Area, RWP Required for Entry" and " Door Must be Locked at All Times." A survey of the area disclosed " hot spots" of 2,000 mrem /hr. Further, if a reactor scram occurred the general area radiation would be greater than 1,000 mrem /h Response B

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Corrective Steps Which Have Been Taken and the Results Achieved Are:

Upon discovery of the violation, the door of the SDV high radiation area

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was locked. Personnel who routinely enter this area have been instructed to pay particular attention to locking this door, since it does not have the locked-when-closed feature used in other high radiation area doors throughout the plan Corrective Steps Which Will be Taken to Avoid Further bolations Are:

A plant work request is being prepared for changing the latch on the SDV high radiation area door to a latch that provides automatic locking when the door is closed. This latch design, used in other areas of the plant, requires use of a key for entering the area, but does not affect exit from the are Date When Full Compliance Will be Achieved:

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Installation of a locked-when-closed latch on the SDV high radiation area

door is scheduled to be completed by April 1,198 ,

We believe that the actions and commitments identified above are sufficient to l ensure resolution of the violations identified during the June inspectio Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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6 A. c eub-3. F. Opeka Senior Vice President By: C. F. Sears Vice President