ML20195H690

Notice of Violation from Insp on 980818-1005.Violation Noted:Engineering Evaluations Not Performed When RCS Heatup Rate Limit Exceeded on 951217 & When RCS Cooldown Rate Limit Exceeded on Three occasions,940424,0728 & 951215

ML20195H690
Person / Time
Site:	Millstone
Issue date:	11/18/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20195H672	List: IR 05000245/1998216 ML20195H666 ML20195H690
References
50-336-98-216, NUDOCS 9811240075
Download: ML20195H690 (3)

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ENCLOSURE 1 l

NOTICE OF VIOLATION l

I Northeast Nuclear Energy Ccmpany Docket No.: 50-336 Millstons Nuclear Power Station License No.: DPR-65 Unit 2 During an NRC inspection conducted on August 18,1998 through October 5~ 1999,

-violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 4 600, the violations are listed below:

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' Technical Specification (TS) 3.4.9.1 action requirements states, in part, that when the maximum heatup and cooldown limits specified in TS 3.4.9.1.a & b are exceeded, an engineering evaluation must be performed to determine the effects of l

the out-of-limit condition on the structural integrity of the Reactor Coolant System l.

(RCS), and to determine that the RCS remains acceotable for continued operations.

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Technical Specification 3.0.4 requires, in part, that entry into an operational mode shall not be made when the conditions for the Limiting Condition for Operation are l

not met and the associated action requires a shutdown if they are not met within a -

l specified time interval.

l Contrary to the above, engineering evaluations were not performed when the RCS heatup rate limit was exceeded on December 17,1995, and when the RCS cooldown rate limit was exceeded on three occasions (April 24,1994, July 28, 1994, and December 15,1995.)- Consequently, because the licensee had not recognized that the heatup limit had been exceeded on December 17,1995, they continued to change modes to full power operation while not having met the actions j

of Limiting Condition for Operation 3.4.9.1.a.

This is a Severity Level IV violation (Supplement l} for Docket No. 50-336.

The NRC has concl* ded that information regarding the reascn for the violation, the l

corrective actions taken and planned to correct the violation'and prevent recurrence is L

already adequately addressed on the docket in Licensee Event Reports 50-336/96-001 and j

96-007, dated January 30,1996, and March 22,1996, respectively. Therefore, you are j

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not required to respond to this specific violation unless the description therein does not l

accurately reflect your corrective actions or your position, in that case, or if you choose to provide additional info mation, you should follow the intructions specified in the enclosed Notice.

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s-9911240075 981118 PDR ADOCA 05000245 G

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l Mr. M. L. Bowling 2

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Unit 2 Technical Specification 6.8.1.c requires that written procedures be i

established, implemented, and maintained for surveillance activities of safety related 1

equipment.

Contrary to the above, Revision 23 to Form 2611C-2,"RBCCW System Alignment Checks, Facility 1," which was issued July 2,1998, and the associated procedure, procedure SP2611C,"RBCCW System Alignment and Valve Tests, Facility 1 &

Cross Ties," were not adequately established in that the instructions provided in Note 9 in Form 2611C of this the valve lineup did not verify that valve 2-RB-68.1 A, (the reactor building closed cooling water system throttle valve to the "A" engineered safeguards room cooler) was in its required throttled position. As a result, the valve lineup was performed on July 14,1998, and July 20,1998, without identifying that the valve 2-RB-68.1 A was fully open rather than the required throttled position of four and one-quarter turns open.

This is a Severity Level IV violation (Supplement 1) for Docket No. 50-336.

Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby i

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 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 or severity level, (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 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.

i If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United Ststes Nuclear Regulatory Commission, Washington, DC 20555-0001.

Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

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. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide l

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

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Mr. M. L. Bowling 3

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 request 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.

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l Dat.sd at King of Prussia, PA l

' this 18th day of November,1998 L

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