ML17054C083
| ML17054C083 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/29/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17054C082 | List: |
| References | |
| EA-87-045, EA-87-45, NUDOCS 8705080293 | |
| Download: ML17054C083 (12) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Niagara Mohawk Power Corporation Nine Mile Point, Unit 1 Docket No.
50-220 License No.
DPR-63 EA 87-45 During three NRC inspections conducted between August 4 and September 19, 1986, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.CD
- 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
A.
Technical Specification 6.8. 1 requires that written procedures and administrative policies be established, implemented and maintained that cover the activities recommended in Sections
- 5. 1 and 5.3 of ANSI Standard N18.7-1972.
Section 5.1 of ANSI N18.7-1972 specifies that a
maintenance program be developed to maintain safety-related equipment which includes the following:
(1) proper preplanning and performance of maintenance in accordance with written instructions or procedures that incorporate appropriate vendor manual information, (2) documented permission by responsible operating personnel to release equipment for work, and (3) post-maintenance review, testing and return to service to verify functional acceptability.
Contrary to the above, written procedures and administrative policies were not either established; implemented, or maintained covering the following maintenance activities, as evidenced by the following examples:
l.
On August 21,
- 1986, maintenance was performed on the Control Rod Drive (CRD) hydraulic control unit scram inlet and outlet valves, safety-related equipment, without establishment and implementa-tion of appropriate written procedures for conducting this main-tenance.
Specifically, the packing for the valves was tightened without proper approval of shift supervision, without proper pre-planning and written instructions, and without any post-maintenance testings 2.
In April 1986, a local leak rate test of the Feedwater Isolation Check Valve was not conducted in accordance with the approved Nine Mile Nuclear Station Procedure Nl-ISP-25.7.
Specifically, the cavity between the inboard isolation valve and outboard check valve was initially pressurized to 100 psig rather than 35.5 psig as stated in the procedure, and this change was not evaluated for its effect on the validity of the test.
t~~<>>0802%3 Sy<>ypiy~
PDR ADOCK 05000220 9FFICIAL RECORD COPY PDR CP PKG NINE MILE R'2 0004.0.0 04/28/87
. sE
Notice of Vio 1 ati on 3.
In July 1986, two Local Power Range Monitor (LPRM) cable connectors were replaced with a model connector that was not in accordance with NMNS Procedure N1-IMP-LPRM-1.
Specifically, Amphenol Type BNC connectors were used instead of the required Amphenol Type SMA connectors.
4.
On September 15,
- 1986, the restoration of safety-related equipment to an operable status 'after the maintenance activities was not performed in accordance with Administrative Procedure 5.0, "Procedure for Repair," in that physical separation of electrical equipment was not maintained.
Specifically, three steel panel isolation barriers which separate safety-related from non-safety-related equipment were not reinstalled within Remote Shutdown Panel No.
11.
Additionally, switch and relay covers and a spare instrument were not reinstalled.
5.
NMNS Procedure Nl-ST-g3 and Nl-ST-1CS used for the performance of surveillance testing of the High Pressure Coolant Injection (HPCI) pumps were not revised to incorporate new HPCI flow acceptance criteria.
- Further, on July 14, 1986 these procedures were not used during the surveillance testing of the HPCI pumps.
6.
The control and use of metering and test equipment (MME) was not conducted in accordance with Administrative Procedure AP-8.4, "Procedure for Control and Calibration of Equipment Used in Tests and Inspections",
as evidenced by the following examples:
On April 16, 1985, Transition Minitemp Calibrator (Serial No.
18947) was calibrated off-site and, as of September 18,
- 1986, a current calibration report was not, maintained with the responsible supervisor, as required.
b.
On November 4,
- 1985, a Gould recorder (Serial No.
1155) was used on at least thirteen instances during the performance of timing tests on scram valves without the required recording of its use on a protected log sheet.
C.
As of September 18, 1986, recorder channel
- modules, which were individually calibrated, were interchanged between several Gould recorder units without recording this fact on a protected log sheet, as required.
7.
On June 18,
- 1986, NMNS Procedure Nl-ST-C3, "Automatic Startup of HPCI System,"
was not properly followed in that the procedure was signed-off as complete without documenting the completion of the Feedwater (HPCI) System and Condensate System "return to service" alignments on the procedure Data Sheet.
OFFICIAL RECORD COPY CP PKG NINE MILE R 2 0004.1.0 04/28/87
I
As of September 18,
- 1986, housekeeping and cleanliness was not performed in accordance with Administrative Procedure 8.5 in that loose nuts, bolts, relay and switch covers, and other loose hard-ware and trash were present in the Recirculation Pump Motor Generation Field Breaker Cubicles and Remote Shutdown Panels.
9.
Design drawings that reflect plant modifications were not prepared and delivered to the Station Superintendent in a timely manner as required by Administrative Procedure APN-9, "Procedure for Station Permanent and Temporary Modifications and Replacement,"
as evidenced by the following examples:
a.
In 1984, a Plant Modification (No. 84-36) was made to the wiring for Anticipated Transient Without Scram (ATWS) Panel No.
- 1S48, and as of September 12,
- 1986, the associated wiring diagram (No.C-34122-C/1) at the facility was not prepared to accurately reflect the Modification.
~
On September 17, 1986, the latest available wiring diagram (No. C-3481C, Sheet 5, Revision 0, and Sheet 6, Revision 1) at the facility for the, Remote Shutdown Panels was not prepared to reflect the as-installed wiring configuration in that ten wiring configurations were different than indicated on the diagram.
10 CFR Part 50, Appendix B, Criterion XI, requires, in part, that test results be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above, on August 14, 1986, test results were not evaluated to assure that test requirements had been satisfied.
Specifically, although Raw Water Pump No.
121 motor current was observed as outside the acceptable
- range, an evaluation of the data was not completed and NMNS Procedure Nl-ST-Q6, "Containment Spray and Raw Water Pumps Operability Test,"
was completed as satisfactory.
C.
10 CFR 20.201(b) requires, in part, that each licensee make or cause to be made such surveys as may be necessary to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201(a) defines a survey, in part, as an evaluation of the radiation hazards incident to the presence of sources of radiation.
Contrary to the above, l.
although an Instrument and Control (IKC) technician's pocket dosimeter went off-scale while performing maintenance on local power range monitors under the reactor vessel on April 28,
- 1986, the individual reentered the area and performed additional work OFFICIAL RECORD COPY CP PKG NINE MILE R 2 0004.2.0 04/28/87
t.
~
~
~
Notice of Violation under the vessel, without an evaluation being performed to determine the extent of the radiation hazards that may have been present and without ensuring that the limits set forth in 10 CFR 20. 101 were not exceeded.
2.
on April 29,
- 1986, an adequate survey was not performed of an area under the reactor vessel area where maintenance on local power range monitors was to be performed in that the radiation levels from the control rod drive (CRD) flanges were not determined.
An individual performing the maintenance could come in contact with the CRD flanges which had a contact radiation level of approximately 1200 millirem per hour.
A technician was not instructed to avoid the area of these
- flanges, and this resulted in the technician working with his head resting against a flange without knowing that the flange had a contact radiation level of approximately 1200 millirem per hour.
D.
Technical Specification
- 6. 11 requires, in part, that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20, and be adhered to for all operations involving personnel radiation exposure.
Contrary to the above, in several instances, procedures for personnel radiation protection were not adhered to for operations involving personnel radiation exposure, as evidenced by the following examples:
1.
On April 28 and 29,
- 1986, an I&C Technician working under the reactor vessel received an uncontrolled radiation exposure as evidenced by off scale dosimetry readings, and Radiological Occurrence Reports were not issued in accordance with NMNS Procedure S-RP-5, "Radiation and Radioactive Contamination Control," Revision 4 ~
2.
On April 28,
- 1986, an I&C Technician, whose dosimeter indicated an accumulated dose of 300 mi llirem, did not rezero his dosimeter, as required by NMNS Procedure S-RP-1, "Access and Radiological Control,"
Revision 5, prior to entering an area under the reactor vessel where the radiation field could result in an off-scale reading.
3.
On April 29,
- 1986, an I&C Technician, designated as the Leadman for work performed under the reactor vessel, did not ensure, as required by NMNS Procedure S-RP-2, "Radiation cwork Permit Procedure,"
Revision 4, that the instructions of a Radiation Mork Permit (RWP) were strictly followed.
Specifically, the Leadman entered the area without the extremity dosimeter required by RMP No. 2043.
0 4.
On April 28,
- 1986, an I&C Technician returned his extremity dosimeter to dosimetry personnel, but did not return his whole body film badge at the same time, as required by NMNS Procedure S-RTP-7, "Issuing and Collecting Dosimetry Devices,"
Revision 6.
OFFICIAL RECORD COPY CP PKG NINE MILE R 2 - 0004.2.1 04/28/87
v.
4 1
lg
On April 28,
- 1986, an I&C Technician's pocket dosimeter went off-scale indicating a potential high exposure, but the film badge was not submitted to the vendor for processing as required by NMNS Procedure S-RRI-12, "Sending Special Records to Landauer,"
Revision 0.
E.
Technical Specification
- 6. 12. 1 requires, in part, that each individual or group of individuals permitted to enter areas with radiation levels greater than 100 mrem/hour be provided with or accompanied by one or more of the following:
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-grated dose is received.
Entry into such areas with this monitoring device may be made after the dose rates in the area have been established and personnel have been made knowledgeable of them.
C.
An individual qualified in radiation protection, with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area, shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Supervisor or designated in the Radiation Work Permit.
Contrary to the above, on April 29,
- 1986, an IKC technician entered an area under the reactor vessel and performed work on the Local Power Range Monitors (LPRMs) where the upper part of his body could come in contact with the Control Rod Drive (CRD) flanges where the radiation levels were as high as 1200 mrem/hr on contact.
The technician was not provided with a continuously indicating or continuously integrating
- device, nor was he accompanied by an individual qualified in radiation protection to perform periodic surveillance at the frequency specified on the RWP.
Collectively, the violations have been categorized in the aggregate as a
Severity Level III problem (Supplement I and IV).
Cumulative Civil Penalty
$50,000 (assessed equally among the violations).
-e Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation, is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, USNRC Region I, and a copy to the NRC Resident Inspector, Nine Mile Point, Nuclear Station, Unit 1, within 30 days of the date of this Notice.
This reply should be clearly marked as a
"Reply to the Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further OFFICIAL RECORD COPY CP PKG NINE MILE R 2 - 0004.3.0 04/28/87
E I
J IP I
0 Notice of Violation violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good
,cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
- 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Niagara Mohawk Power Corporation may pay the civil penalty by letter addressed to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of Fifty Thousand Dollars ($50,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555.
Should Niagara Mohawk Power Corporation fail to answer within the time specified, an order will be issued imposing the civil penalty in the amount proposed above.
Should Niagara Mohawk Power Corporation elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in
- part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed
- penalty, the five factors contained in Section V.B of 10 CFR Part 2, Appendix C (1987),
should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of Niagara Mohawk Power Corporation is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due, which has been subsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282.
FOR THE NUCLEAR REGULATORY COMMISSION Origina1'igned, BF MZLLIAH T.. RUSSELL William T. Russell Regional Administrator Dated at King of Prussia, Pennsylvania thi s~y < day of April 1987 OFFICIAL RECORD COPY CP PKG NINE MILE R 2 - 0005.0.0 04/28/87
4
~ I