ML20141F818
| ML20141F818 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/08/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20141F808 | List: |
| References | |
| 50-213-97-01, 50-213-97-1, NUDOCS 9705220060 | |
| Download: ML20141F818 (3) | |
Text
_
ENCLOSURE 1 NOTICE OF VIOLATION Connecticut Yankee Atomic Power Company Docket No. 50-213 Haddam Neck Plant License No. DPF 61 During NRC inspections conducted on January 6 - April 7,1997, certain violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30,1995) the violations are listed below.
1.
Technical Specification 6.8.1 requires that written procedures and/or administrative policies be estab.bhed, implemented and maintained covering the activities as recommended in Appendix A of Regulatory Guide 1.33. Regulatory Guide 1.33 requires that procedures be established governing plant operations and administration, work controls and security.
I Work Control Manual WCM 2.4-1, Equipment Tagging, Revision 7, was a.
written pursuant to the above and states in Step 1.2.2 that any equipment tagged with a red tag shall not be operated by anyone. Contrary to the above, on February 19,1997, a contractor health physics technician opened the red tagged prefilter access door for auxiliary building filter F-70-1 A.
b.
Procedure NOP 2.19-8A, Auxiliary Boiler Operation, Revision 2 dated 1/30/97 requires in Step 6.1.12a that the operator maintain the condensate receiver tank one-half to two-thirds full when operating the condensate makeup pump manually. Contrary to the above, on January 5 and 11,1997, an operator began a manual fill of the auxiliary boiler condensate receiver tank, and then left the area. The condensate receiver tank overflowed on both occasions, resulting in an unplanned discharge to the environment.
c.
Technical Specification 6.2.2.f requires that administrative procedures be developed and implemented to limit working hours of facility staff.
Procedure NGP 1.09 was developed pursuani to the above, and requires in Step 4.6 that workers have no less that 8 continuous hours off between scheduled work periods and that workers do not work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period. Contrary to the above, on February 5-6,1997, an operatoi worked two shifts without 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off between scheduled work periods. In addition, the results of a licensee audit submitted to the NRC on January 17,1997 identified 6 instances over a four week period in July and August 1994 in which work hours for plant staff exceeded the overtime lirnits, d.
Work Control Manual WCM 2.1-2, Trouble Reporting / Job Scoping, Revision 3, was written pursuant to the above and requires in Steps 1.2.3 and 1.3.3 that trouble report tags be removed and closed upon development of work packages, or for work that will be completed under blanket authorized work 9705220060 970508 PDR ADOCK 05000213 G
O 2
that trouble report tags be removed and closed upon development of work packages, or for work that will be completed under blanket authorized work 4
orders. Contrary to the above, on February 18,1997 as documented in
~
adverse condition report ACR 97 90, a review of trouble reports by plant operators identified that of 275 trouble reports hanging on plant equipment, 113 were associated with trouble reports or AWOs that had been either deleted, completed or canceled.
e e.
Work Control Manual WCM 3.31, Technical Specification Surveillance Tracking, Revision 2, requires in Steps 1.4.2 and 1.4.3 that the station procedures be audited annually (initiated in January) to assure the technical specification requirements are met. Procedure ACP 1,2-6.5A, Station Procedures, Revision 0, requires that technical specification surveillances be conducted by procedures in the Surveillance Procedure category. Contrary to WCM 3.31, as of April 4,1997, the licensee had not completed the annual audit of procedures per WCM 3.3-1. Contrary to ACP 1.2-6.5A, on March 12,1997, the licensee identified that technical specification surveillances were completed by preventive maintenance (PMP 9.1-31) and environmental services (ESP 14.1-4) procedures.
f.
Security procedure 1.3-8, Package and Material control, Revision 26, requires in Step 6.2.1.b that all packages that all packages be searched prior to entry into the protected area. Contrary to the above, on March 13,1997, six boxes were brought into the protected area without receiving the required security searches.
This is a Severity Level IV violation (Supplement 1).
2.
Technical Specification (TS) 4.4.7 requires that reactor coolant system chemistry be sampled every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to awe that chloride and fluoride concentrations remain below the limits specified in TS 3.4.7. The mode of applicability for the i
specification 3.7.7. is "at all times."
Contrary to the above, no RCS chemistry samples were taken from November 15, 1996 through February 6,1997.
1 This is a Severity Level IV violation (Supplement 1).
3.
10 CFR 50 Appendix B, Criterion XVI, " Corrective Actions," requires that measures be established to assure that conditions adverse to quality 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, the licensee did not correct the recurrence of significant conditions adverse to quality, in that there have been multiple examples of a failure to adequately implement the technical specification (TS) operational surveillance program. Past deficiencies related to missed or late TS surveillances were the
i 3
)
subject of inspection item URI 94-27-01, and licensee event reports 9b-12,96-04, 96-17 and 96-22. The licensee identified the following failures to complete technical specification surveillances in a timely manner: on February 6,1997, the l
J failure to test reactor coolant system chemistry per TS 4.4.7; on February 11, the failure to test the main station battery per TS 4.8.2.2. and 4.8.2.1.c; on February 12, the failure to test the service water pumps per TS 4.7.3.b.2; and, on March 21, the f ailure to verify the position of safety related valves per TS 4.5.2.c.
This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Connecticut Yankee Atomic Power 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, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date cf 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. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information 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. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it I
necessary to include such information, you should clearly indicate the specific information l
that you desire not to be placed in the PDR, and provide the legal basis to support your l
request for withholding the information from the public, Dated at King of Prussia, Pennsylvania l
this 8th day of May,1997.
l
-