ML20046B017

Notice of Violation from Insp on 930519-0629.Violation Noted:During Performance of Procedure SP-2404AW Sample Canister Isolation Valves on Monitor RM-6038 Were Closed by Instrumentation & Controls Personnel

ML20046B017
Person / Time
Site:	Millstone
Issue date:	07/22/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20046B014	List: IR 05000245/1993016 ML20046B017
References
50-336-93-11, NUDOCS 9308030010
Download: ML20046B017 (3)

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l NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket No. 50-336 Millstone Nuclear Power Station, Unit 2 License No. DRP-65 During an NRC inspection conducted on May 19,1993 through June 29,1993, three 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, the 7

violations are listed below-l A.

Millstone Unit 2 Technical Specification 6.8.1 requires that procedures covering station activities shall be established and implemented. Station Administrative Control procedure (ACP) ACP-QA-3.02E, " Procedure Compliance," and Surveillance l

Procedure SP-2404AW, "RBCCW Liquid Radiation Monitor (RM 6038) Calibration,"

were established pursuant to the above.

2 Procedure ACP-QA-3.02E requires, in part, that the intent and direction of procedures shall be followed, and that deviatior. from procedures is not permitted.

Surveillance Procedure SP-2404AW, "RBCCW Liquid Radiation Monitor (RM 6038)

Calibration," Steps 4.7 and 6.8.8, require that operations personnel open and shut, I

respectively, the isolation valves to the sample canister on monitor RM-6038.

Technical Specification 3.3.3.9, " Radioactive Liquid Effluent Monitoring Instrumentation," Table 3.3-12, Action -. applicable to reactor building closed cooling water system radiation monitor RM-6038, requires, in part, that with monitor RM-6038 inoperable greater than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples of service water system effluent shall be collected and analyzed for gross radioactivity once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above; i

1.

During performance of Procedure SP-2404AW on May 3,1993, the sample canister isolation valves on monitor RM-6038 were closed by instrumentation and controls personnel vice operations personnel; and, at the completion of the calibration, the sample canister isolation valves were not reopened, rendering monitor RM-6038 inoperable.

2.

From 7:57 p.m., on May 3,1993, to 1:00 a.m., on May 6,1993, monitor RM-6038 was inoperable, during which time grab samples of service water system effluent were not collected and analyzed for gross radioactivity.

This is a Severity level IV Violation (Supplement I) 9309030010 930722 "

PDR ADDCK 05000245 O

PDR

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Notice of Violation 2

B.

Millstone Unit 2 Technical Specification 4.0.5.a requires, in part, that inservice testing of valves shall be performed in accordance with Section XI of the ASME Boiler and i

Pressure Vessel Code as required by 10 CFR 50, Section 50.55a(g).

Surveillance Procedure SP-21131, " Chemical and Volume Control System Operational Readiness Test," implements the requirements of the above for valves 2-CH-510 and 2-CH-511. Procedure SP-21131, Step 7.5.4, requires, in part, that if either valve does not meet the acceptance criterion specined by the procedure, the valves shall be immediately declared inoperable; a plant incident report shall be submitted; and the inservice test coordinator or the engineering department inservice inspection supervisor shall be notined as soon as possible.

l Contrary to the above, on May 25,1993, valves 2-CH-510 and 2-CH-511 failed to l

meet the failure mode test acceptance criterion of Procedure SP-21131, and were not declared incperable; a plant incident report was not submitted until June 3,1993; and j

neither the inservice test coordinator nor the engineering department inservice i

inspection supervisor were notined until June 3,1993.

This is a Severity Level IV Violation (Supplement I)

C.

Millstone Unit 2 Technical Specification 6.8.1 requires that procedures covering station activities be established and implemented. Station Administrative Control Procedures (ACP) ACP-QA-3.02E, " Procedure Compliance," and ACP-QA-2.06A, " Station Tagging," Chemistry Procedure CP-2806X, " Containment Purge," and Operations Procedure OP-2383A, " Process Radiation Monitors Operation," were established pursuant to the above.

1 Procedure ACP-QA-3.02E, Step 6.2, requires, in pan, that the intent and ' direction of procedures shall be followed, and that deviation from procedures is not permitted, j

i Procedure ACP-QA-2.06A, Step 6.1.2.1, requires, in part, that the position of valves be veriDed to be in the proper position when placing tags.

Chemistry Procedure CP-2806X, " Containment Purge," Step 5.2.10, and Operations Procedure OP-2383A, " Process Radiation Monitors Operation," Step 5.10, require that operations personnel disconnect the temporary sample rig from connections downstream of radiation monitor RM-8123 and restore normal valve positions following collection of containment atmosphere samples.

l Contrary to the above; 1.

On March 28,1993, valves 2-AC-122 and 2-AC-124 were not verified to be in the proper shut position when tags were placed on the valves. The valves were actually open.

Notice of Violation 3

2.

On several occasions prior to March 28,1993, following sampling of the contaMment atmosphere, chemistry personnel conducted activities required to be performed by operations, i.e., disconnecting the sample rig and repositioning valves.

This is a Severity Level IV Violation (Supplement I)

Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company 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, Region I, a copy to the NRC Resident inspector within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

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Dated at King of Prussia, PA this 22 day of July,1993 4

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