ML17055E680

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Notice of Violation from Insp on 890218-0403.Violation Noted:Written Procedures Were Not Properly Implemented for Certain safety-related Activities as Outlined in Listed Three Examples
ML17055E680
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 04/25/1989
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17055E679 List:
References
50-220-89-04, 50-220-89-4, 50-410-89-04, 50-410-89-4, NUDOCS 8905030526
Download: ML17055E680 (4)


Text

APPENDIX A NOTICE OF VIOLATION Niagara Mohawk Power Corporation Nine Mile Point Units 1 and 2

Docket Nos.

50-220/50-410 License Nos.

DRP-63/NPF-69 As a result of the inspection conducted on February 18, 1989 through April 3,

1989, and in accordance with NRC Enforcement Policy ( 10 CFR Part 2, Appendix C) the following violations were identified:

A.

Nine Mile Point Unit 1 Technical Specification (TS) 6.8. 1 and ANSI N18.7-1972 require that written procedures shall be implemented for maintenance and testing activities.

Instrument'ation and Controls Department Procedure, N1-IP-1. 14, Steam Line Plug Pressure Panel Installations, Rev.

1, TCN-1, required that daily monitoring and recording of the as-found and as-left pressures to the seal assemblies of the installed main steam line plugs be performed on a daily basis.

Further, Nine Mile Point Unit 1 Technical Specification 6.8..3 and Site Administrative Procedure, AP-2 state in part that temporary changes to procedures subject to TS 6.8. 1 may be made provided the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's license on the unit affected.

1.

Contrary to the above, daily monitoring and recording of seal assembly pressures was not performed as required for various-dates and time periods (up to one week) from June 1988 until March 1989, when the procedure was eventually revised to authorize weekly checks.

2.

Contrary to the above, a procedure change which lowered the pressure to the seal assembly of the East main steam line plug from 80 +

5 psig to 35 psig on February 26, 1988 was not formally reviewed and approved until the issuance of a One-Time-Only procedure change on February 29, 1989.

These two examples comprise a Severity Level IV Violation (Supplement I).

B.

Nine Mile Point Unit 2, Technical Specification 6.8. 1 and Appendix A of Regulatory Guide 1.33 requi re that written procedures shall be established, implemented and maintained for maintenance and testing procedures.

Contrary to the above, written procedures were not properly implemented for certain safety-related activities as outlined in the following three examples:

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PDC

On February 19, 1989,an Instrumentation and Control technician performed a backfill of a reactor water level detector without using the correct procedure N2-IMP-GEN-'020, Reactor Instrument Fill and Vent resulting in an inadvertent High Pressure Core Spray System initiation.

On February 21,

1989, an operator identified a deficiency in Procedure N2-OP-52 (Standby Gas Treatment Operability Test) during its performance and proceeded on without obtaining a change to the procedure for clarification.

Consequently, by not correcting the procedural deficiency as required, the operator made an incorrect assumption which resulted in the inadvertent initiation of several Engineered Safety Features.

During the performance of an Electrical Department surveillance test (N2-ESP-ENS-M731) conducted on February 28,

1989, a reactor operator and another individual responsible for independently verifying his actions failed to follow the procedure and perform an electrical switch line-up, resulting in an inadvertent Low Pressure Core Injection System initiation.

This is a severity level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending this response time.