ML20058C900
| ML20058C900 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/01/1993 |
| From: | Romberg W NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20058C893 | List: |
| References | |
| NUDOCS 9312020616 | |
| Download: ML20058C900 (5) | |
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$$(CCdCd (203) 665-5000 October 1, 1993 Docket No. 50-245 B14628 Re:
Inspection Report No. 50-245/93-20 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No.1 Reply to a Notice of Violation Inspection Report No. 50-245/93-20 In a letter dated September 1,1993,"' the NRC Staff transmitted to Northeast Nuclear Energy Company (NNECO) a Notice of Violation (NOV) relating to Inspection Report No. 50-245/93-20.
The report discussed the results of an inspection to review resolution' and corrective actions taken for open items identified previously in the Electrical Distribution System Functional 2
Inspection (EDSFI) (Inspection Report No. 50-245/91-81).
Based on the results of the Staff's inspection, one apparent violation of NRC requirements was identified.
Attachment I to this letter provides NNEC0's reply to the violation on behalf of Millstone Unit No. 1, in accordance with the requirements of 10CFR2.201 and the instructions contained within the report.
We trust that you will find this information satisfactory, and we remain available to answer any questions you may have.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: J. F. Opeka Executive Vice President BY:
W. D. Romberg p Vice President cc:
T. T. Martin, Region I Administrator J. W. Andersen, NRC Acting Project Manager, Millstone Unit No. 1 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 (1)
M. W. Hodges letter to J. F. Opeka, " Notice of Violation, NRC Inspection Report No. 50-245/93-20," dated September 1, 1993.
(2)
M.
W.
Hodges letter to J.
F. Opeka, " Electrical Distribution System Functional Inspection (EDSFI) of Millstone Unit 1 Inspection Report No. 50-245/91-81," dated December 30, 1991.
Os341/ MV Lan 9312O20616 931109 PDR ADOCK 05000245 G
1 Docket No. 50-245 B14628 l
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Attachment I Millstone Nuclear Power Station, Unit No.1 Reply to Notice of Violation Inspection Report 50-245/93-20 i
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October 1993 P
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U.S. Nuclear Regulatory Commission B14628/ Attachment 1/Page 1 October 1, 1993 i
Restatement of Violation During an NRC inspection conducted on July 19-23, 1993, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, as of July 23, 1993, measures to assure conditions adverse to quality were not taken to promptly correct the deficiency of failure to follow procedures as evidenced by the following:
- 1) a Notice of Violation was issued to the licensee on December 30, 1991, for failure to provide biennial reviews of station procedures as required by administrative procedure ACP-QA-3.02D; and 2) on July 23, 1993, it was found that the corrective actions for the above violation were inadequate because more than 200 station procedures still did not receive the required biennial review.
The number of unreviewed procedures actually increased during the past 19 months.
This is a Severity Level IV violation (Supplement 1).
Reason for Violation The most significant contributing cause to the procedural non-compliance which caused this violation is that the requirement to perform biennial reviews was not fully understood by all appropriate station personnel.
There is a significant effort underway at Millstone Station to improve procedures.
Some plant management and personnel were under the impression that the requirement to perform biennial reviews was waived during this procedure upgrade effort.
Although reports are generated to plant management which identify overdue biennial reviews, it was not recognized as noncompliance with ACP-QA-3.02D,
" Biennial Review of Station Procedures."
Although ACP-QA-3.02D has no provision for waiving or delaying biennial reviews, there was a perception by some plant management and personnel that this provision did exist and was in force.
Contributing to this confusion is the provision for identifying a procedure as "D0 NOT USE" (i.e., inactive) within ACP-QA-3.020.
This provision is invoked i f, as the result of a biennial review, the procedure requires revision, and it is not desirable to implement the revision (emphasis added). Then, the mechanism for inactivating
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U.S. Nuclear Regulatory Comission B14628/ Attachment 1/Page 2 October 1, 1993 the procedure is provided. Some plant management and personnel were under the impression that the overdue procedures were inactive as allowed by ACP-QA-3.02D.
This is a different root cause than that of the similar violation issued December 30, 1991 "' for past due biennial reviews.
By letter dated February 10, 1992,12 NNEC0 provided a response to that Notice of Violation.
The cause was identified as follows:
"This violation occurred due to lack of adequate tracking of this activity."
The overdue biennial reviews, indicated in the September 1,1993 letter, were adequately tracked and timely reports were provided to responsible managers.
Even though these reports indicated past due biennial reviews, these reports were interpreted as acceptable by some plant management in light of the perception of waived reviews due to inactive procedures as described above.
Corrective Actions Taken and Results Achieved All procedures at Millstone Station which have not received a biennial review within the past two years have been identified. The Vice President-Millstone Station has provided interim instructions to all department managers at Millstone Station regarding the use of procedures which are past their due dates for biennial review.
With the excepticn of Administrative Control Procedures, each controlled copy of these procedures will be stamped "D0 NOT USE."
As circumstances arise which may require use of one of these procedures, the Plant Operations Review Comittee (PORC) or Site Operations Review Comittee (SORC), as applicable, must review and approve the use of an inactive procedure.
This approval must be obtained prior to use of these procedures.
Administrative Control Procedures will be reviewed on an expedited schedule to be completed by December 15, 1993.
In the interim, use of the ACPs is approved.
Corrective Steps to Avoid Further Violations Senior station management is taking aggressive action to ensure that those persons involved recognize their responsibility to follow procedures and are being held accountable.
ACP-QA-3.02D has been revised to ensure that any procedure that has not received a biennial review within two years will be made inactive.
This j
(1)
M.
W.
Hodges letter to J.
F. Opeka, " Electrical Distribution System Functional Inspection (EDSFI) of Millstone Unit 1 Inspection Report No. 50-245/91-81," dated December 30, 1991.
(2)
J.
F. Opeka letter to U.S.
Nuclear Regulatory Comission, " Millstone
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Nuclear Power Station, Unit No.1 Reply to Notice of Violation Inspection Report No. 50-245/91-81," dated February 10, 1992.
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U.S. Nuclear Regulatory Commission B14628/ Attachment 1/Page 3 October 1, 1993 revision to ACP-QA-3.02D also proceduralizes the requirement for PORC/SORC approval, as applicable, of such procedures prior to subsequent use.
Although the primary purpose of ACP-QA-3.02D is to provide the administrative requirements to periodically review procedures for technical and administrative adequacy, NNEC0 recognizes that it may be necessary or desirable to extend this period for some procedures.
ACP-QA-3.02D will be routed by document acknowledgment sheet to all department managers to reinforce the requirements for biennial reviews and to communicate the revised requirements.
Full compliance with ACP-QA-3.02D will be achieved by December 15, 1993. This will entail the following:
1.
All ACPs will have received biennial reviews.
2.
All other procedures will either have:
a) received biennial reviews, or b) been inactivated in accordance with ACP-QA-3.02D (as changed).
Generic Imolications The root cause of this violation also applies to other departments at Hillstone Station.
The corrective actions described above apply to all departments at Millstone Station. The corrective actions, as described above, will be reviewed for applicability to the Haddam Neck Plant and appropriate actions taken, if required.