IR 05000423/1988003

Discusses Insp Rept 50-423/88-03 on 880119-29 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Event Demonstrates Need for Better Control of Configuration of Equipment

ML20151Q459
Person / Time
Site:	Millstone
Issue date:	04/12/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E NORTHEAST NUCLEAR ENERGY CO.
Shared Package
ML20151Q461	List: IR 05000423/1988003 ML20151Q475
References
EA-88-061, EA-88-61, NUDOCS 8804270039
Download: ML20151Q459 (4)

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April 12, 1988 Oocket No. 50-423 License No. NPF-49 EA-38-61 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:

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Subject: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC Inspection Report No. 50-423/88-03)

This refers to the special NRC inspection conducted on January 19-29, 1988 at Millstone, Unit 3 to review an event which occurred on January 19, 1988 involving an increase in reactor pressure while the reactor was in cold shutdown. This event was promptly reported to the NRC resident inspector by a member of your staff. The inspection report was sent to you on February 22, 1988. At the time of this pressure transient, and for approxi-mately three days prior to the date, none of the facility's three available overpressure protection systems were operable as required. Failure to have at least one system operable constitutes a violation of a technical specification limiting condition for operation. On March 8, 1988, an enforcement conference was conducted with Mr. W. Romberg and other members of your staff to discuss the violation, its causes, and your corrective actio The violation is descrited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty. The facility technical specifications require that one of the following overpressure protection systems be operable: (1) the two RHR suction relief valves with an appropriate lift setting; (2) the two power-operated relief valves (PORVs) with appropriate low pressure lif t settings, or (3) an appropriately sized RCS vent path with the RCS depressurized. Although your staff believed that the cold overpressure protection function of the PORVs was operable, this function was inoperable because certain Solid State Protection System (SSPS) output relays were not functional due to the SSPS being in the

"Test" mode. As a result, when one of the two RHR suction valves war. closed on January 16, it placed the facility in violation of a technical specificatio When the second RHR suction valve was isolated on January 19, due to a fuse pulling incident, the pressure transient resulte The NRC is concerned that this event demonstrated a number of deficiencies in control of operations at Millstone Unit 3. For example, the procedure for ensuring operability of the Cold Overpressure Protection System (COPS) did not adequately address the operability requirements of supporting equipmen Further, there was and still is no positive indication in the control room to show that the COPS is inoperable. In addition, Instrumentation arid Control (I&C) personnel who pulled the fuses that resulted in the second RHR valve OFFICIAL RECORD COPY CP PKG MILLSTONE /2 - 0001. l PDR ADOCK 05000423 i L Q DCD

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Northeast Nuclear Energy Company 2 becoming isolated were not adequately trained in the complex circuitry inter-relationships which were affected by fuse pulling, and the activity was performed without a procedure and without an adequate and formal revie This event demonstrates the need for (I) better control of the configuration of equipment at the facility, (2) better planning of activities that ;ould affect that control, (3) improved procedures for performing those act vities, and (4) improved training of personnel perforcing those activities. To emphasize these needs, I have been authorized, after consultation with the Diree or, Office of Enforcement, and the Deputy Executive Director for Regional

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Operations, to issue the enclosed Netice of Violation and Proposed Imposition of Civil Penalty in the amount of Fif ty Thousand Dollars (550,000) for the violation described in the enclosed Notice. In accordance with the "General Statement of Policy and Procedure for NRC Enforcemant Actions," 10 CFR Part 2, Appendix C (1987)) (Enforcement Policy), the violation described in the r:nclosed Notice has been categorized at a Severity Level III. The base value of a civ" penalty for a Severity Level III violation is $50,000. In considering the escalation and mitigation facters of the Enforcement Policy the NRC recognized your prompt and extensive corrective actions. However, no adjustment of the civii penalty was deemed appropriate because of the duracion and significance of the violatio You are required to respond to this letter and should fellow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. A#ter reviewing you response to this Motice, including your proposed corrective actions end the results of future inspections, the NRC will determine whether further NRC anforcement action is necessary to ensure compliance with NRC regelatory requiiement In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NP.C Public Document hoo The responses directed by this latter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51

Sincerely, Oriainal si;ned By CILLIA. T. 1,sc3_LL William T. Russell

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Northeast Nuclear Energy Company 3 cc w/ encl:

W. D. Romberg, Vice President, Nuclear Operations D. O. Nordquist, Manager of Quality Assurance R. M. Kacich, Manager, Generation Facilities Licensing S. E. Scace, Station Superintendent Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector State of Connecticut 0FFICIAL RECORD COPY CP PKG MILLSTONE /2 - 0006. /08/88

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