ML20155B152

Notice of Violation from Insp on 980810-0903.Violation Noted:Design Basis,As Described in FSAR Chapter 14,Accident Analyses Had Not Been Correctly Translated Into Plant Procedures & Acceptance Criteria

ML20155B152
Person / Time
Site:	Millstone
Issue date:	10/23/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20155B115	List: IR 05000336/1998213 ML20155B111 ML20155B152
References
50-336-98-213, NUDOCS 9810300073
Download: ML20155B152 (2)

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O NOTICE OF VIOLATION i

Northeast Nuclear Energy Company Docket No. 50-336 Millstone Nuclear Power Station, Unit 2 License No. DPR-65 During an NRC inspection conducted from August 10,1998, through September 3,1998, violations of NRC requirements were identified. In accordance with NUREG-1600," General Statements of Policy and Procedure for NRC Enforcement Actions," the violations are listed below.

A.

10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," states, in part, that

" measures shall be established to assure that the app,Sabe regulatory requirements and the design basis...are correctly translated into specificatient., drawings, procedures, and instructions."

Contrar/ to the above, in the following examples, the dasign basis, as described in the Final Safety Analysis Report (FSAR) Chapter 14, Accident Analyses, had not been correctly translated into plant procedures and acceptance criteria. The critical design characteristics (CDCs) used in the revised main steam line break (MSLB) analyses for the containment and the reactor coolant system (RCS) and the small-break loss of coolant accident (SBLOCA) analysis are considered design basis charactoristics. The team's review of the validity of these accident analyses CDCs determined that 'here was a failure to translate them into plant procedures.

1.

The MSLB containment accident analysis CDC for containment free net volume assumed 1,899,000 cubic feet. However, Engineering Procedure EN 21065, Rev. 3

" Containment Mass Tracking," dated April 3,1998, does not include an acceptance limit to assure that this CDC continues to be valid.

2.

The CDCs for the MSLB containment and RCS accident analyses and the SBLOCA accident analysis assume that all control element assembly (CEA) holding coils release the control rods within 0.5 seconds and control rods insert 90 percent within 2.75 seconds. Station Procedure (SP) 21010, Rev. 5, "C'!A Drop Times (IPTE)," step 4.4.5.1, ensures the 90-percent inserthn within 2.75 seconds, but does not verify that the rods are released within 0.5 seconds.

3.

The MSLB containment accident analys's CDC assJmed that at power levels greater than 25 percent, the feedwater regulating bypass valves would be closed (if they were open in manual, additional feedwater would be provided to the faulted steam generator before they were closed, with a reaultant increase in peak containment pressure).

Operating Procedure (OP) 2203, Rev.13. " Plant Startup," does not include a prohibition for using the bypass valve above 25-perceni power, nor did the team identify any other applicable procedure with such a prohibition.

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4.

The MSLB containment accident analysis CDC assumes the maximum auxiliary feedwater (AFW) enthalpy is based on 100 degrees Fahrenheit. However, according to OP 23198, Rev.13, " Condensate Storage and Surge System," and OPS Form 2669A-l 1, " Unit 2 Turbine Buirding Rounds, Outside Areas," the maximum allowable condensate l

storage tank (CST) temperature is 120 degrees Fahrenheit. The AFW supply is the l

CST and, therefore, the CDC maximum temperature may be exceeded.

This is a Severity Level IV Violation (Supplement I).

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Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby required to submit a written statement or explanation within 30 days of receipt of the letter l

transmitting this Notice of Violation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555, with a copy to the Region i Regional Administrator; a copy to the Director, Millstone Independent Corrective Action Verification Program inspections, Associate Director for Technical Review, Office of Nuclear Reactor Regulation; and a copy to the NRC Resident inspector at the Millstone Nuclear Power Station Unit 2. This reply should be clearly marked as a " Reply to a Notice of Violation," and should include the following information for each vicbtion: (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 fur;her 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 required time specified in this Notice of Violation, an Order or a Demand for Information may be issued as to 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.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 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 POR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a roc;uest for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response please provide the level of protection described in 10 CFR 73.21.

Dated at Rockville, Maryland this/fda'y ofdoh1998 l

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