IR 05000245/1990005
| ML20055G139 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/16/1990 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20055G140 | List: |
| References | |
| EA-90-084, EA-90-84, NUDOCS 9007200168 | |
| Download: ML20055G139 (5) | |
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JUL 161990 Docket No. 50-245 i
License No. DPR-21 EA 90-084 i
Northeast Nuclear Energy Company ATTN: Mr. E. Mroczka
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Senior Vice President Nuclear Engineering and Operations Post Office Box 270 Hartford, Connecticut 06140-0270 i
Gentlemen:
I Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $25,000 (NRC Inspection Report No. 50-245/90-05)
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This letter refers to the NRC safety inspection conducted between February 21
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and April 2, 1990 at the Millstone Nuclear Power Station, Waterford, Connecticut.
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The inspection report was sent to you on May 11, 1990.
The NRC inspection included review of the circumstances associated with your failure to meet a condition required by a. technical specification (TS) limiting condition for-operation (LCO),' as well as the failure to properly perform a monthly surveil-lance test in accordance with TS surveillance requirements. There failures, which were identified by your staff and reported to the NRC in March 1990, both i
resulted from errors made in the 1970s, and constituted conditions adverse to qutlity. The failure to promptly identify and correct these conditions which existed for an extended period (while opportunities existed to identify them)
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constitutes a violation of NRC requirements. On May 25, 1990, an enforcement
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conference was held with Mr. W. Romberg and members of your staff to discuss these events, the causes, and your corrective actions.
The violation is described in the enclosed Notice of Violation and Proposed
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Imposition of Civil Penalty.
The first condition adverse to quality involved the_ main steam line high flow bistable set point being set to trip at 123% of rated steam flow, a value in excess of the 120% limit specified in the LCO.
The bistable functions to initiate a primary c u tainment isolation in the event of a design basis accident. The condition had existed since December 1976 when the then existing set point was recalculated after replacement of certain flow restrictors.
The recalculation was in error at the time because the wrong reactor pressure was utilized in the calculation.
In April 1987, a Unit I engineer calculated the setpoint partly in response to a GE Service Information Letter (SIL) issued in June 1986 which described an inconsistency at another operating plant between the actual switch setpoint and the technical specification requirement.
Based on his calculation, the engineer determined that the setpoint in use at Millstone 1 was too high and so advised plant management.
Further, he sent the calculation to one of the corporate engineering departments for verification of both the calculation as well as the validity of the assumptions utilized in the calculation.
However,
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OFFICIAL RECORD COPY CP PKG MILL - 0001.0.0 900720016s90ok1]
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i this issue was not given a high priority by plant management or corporate engineering; no individual was assigned lead tesponsibility for resolution of this concern; and a final determination concerning the validity of the calculation and assumptions was not completed uitil February 1990. When plant management was apprised of that determinat'on in March 1990, action was then taken to initiate a shutdown of the reaccor.
The NRC recognizes that the safety significance of this condition was low in that the difference between the as found and required maximum setpoint
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was small and other instrumentation was available to initiate a primary containment isolation on a main steam line break.
Nonetheless, the NRC is concerned that although the engineer initially identified this condition in 1987 and the appropriate level of plant management was cognizant of the potential non-conservatism, adequate action was not taken to prioritize, track and resolve this condition in a timely manner.
In fact, final resolu-tion in March 1990 appears to have resulted primarily from the persistence of a Unit 1 Instrument & Control (I&C) engineer who routinely contacted corporate engineering concerning resolution of this issue.
The second condition adverse to quality involved the performance, since the 1970s, of the monthly technical specification surveillance test of the gas turbine generator at a load less than full load output, as required by the TS surveillance requirement. This condition had occurred because of an inconsistency betweer the technical specification surveillance requirements and the surveillance test procedure which had existed since the 1970s when certain procedures were consolidated.
These monthly tests were performed since that time at loads greater than 6 megawatts, as specified in the related surveillance procedure.
This is a concern with your current per-formance because neither the personnel who performed these monthly tests, nor the individuals who conducted biennial reviews of the tests for technical adequacy or periodic audits of the technical specifications to assure all specified requiremerits were being met, recognized that the technical specification required full load was described in the Final Safety Analysis Report at the time of identification as 9.876 megawatts. The NRC recognizes that the significance of this condition was also low since the gas turbine was tested to full load prior to the procedure consolidation,
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was maintained to a high degree of reliability and functioned properly when tested at the full load in March 1990.
These failures demonstrate weaknesses in your program for prompt identification and resolution of safety significant deficiencies.
To emphasize the importance of effective and long lasting corrective action to resolve this concern, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $25,000 for the violation set forth in the Notice. The violation has been classified at Severity Level III in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C, (1990) (Enforcement Policy).
The base civil penalty amount for a Severity Level III violation is S50,000.
The escalation and mitigation factors set forth in the Enforcement Policy 0FFICIAL RECORD COPY CP PKG MILL - 0002.0.0 07/11/90
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Northeast Nuclear Energy Company
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i were considered and, on balance, the base civil penalty has been mitigated by i
50%.
The bases for this decision are:
(1) although the conditions adverse to quality were identified by your staff, they reasonably should have been identi-fied and corrected sooner, and therefore, no adjustment of the base civil penalty on this factor is warranted; (2) your corrective actions subsequent to identification (which include correction of the specific setpoint and load test i
deficiencies), although acceptable, were not considered prompt and comprehensive in that the they did not adequately address improvements in your programs for assuring timely identification and resolution of potential safety concerns, and i
therefore, no adjustment of the base civil penalty on this factor is warranted;
(3) your past performance in operations, surveillance and engineering has been good, as evidenced by no related violations being identified in the past two years, and Category I ratings in the operation and surveillance areas during the last four SALP periods, and a Category 2 rating in engineering during the
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last SALP period, and therefore, 100% mitigation of the base civil penalty on i
this factor is warranted; and (4) you had prior notice of a potential problem regarding one of the two problems (namely, the nonconservative main steam line high flow set points) as described above, but did not prioritize nor monitor l
this issue to ensure resolution in a timely manner, and therefore, 50%
escalation on this factor is warranted.
The NRC also considered escalating
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the civil penalty amount because the violation involved two examples of not promptly resolving adverse condition; and because the conditions existed for an extended duration.
However, since these factors were considered in
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establishing the violation and cle,sifying it at Severity Level III, further escalation on these factors was considered inappropriate.
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You are required to respond to this letter and should follow the instructions
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specified in the enclosed Notice when preparing your response.
In your
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response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal hegulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject i
to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely, Orgncd% [ k R, SrncMt Thomas T. Martin Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty 0FFICIAL RECORD COPY CP PKG MILL - 0003.0.0 07/11/90
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Northeast Nuclear Energy Company
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ce v/ enc 1:
W. D. Romberg, Vice President, Nuclear Operations
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S. E. Scace, ',tation Superintendent D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing D. B. Mille., Station Superintendent, Haddam Neck Gerald Gar (ield, Esquire Public De,cument Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
. State of Connecticut _
0FFICIAL RECORD COPY CP PKG MILL - 0004.0.0 07/11/90
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i DISTRIBUTION:
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CA JTaylor, EDO HThompson, DEDS q
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TMartin, RI
JGoldberg, OGC THurley, NRR JPartlow, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV Resident Inspector FIngram, GOA/PA BHayes, 01
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EJordan, AEOD DWilliams, OIG WTroskoski, OE Day File EA File DCS
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