ML20202J789
| ML20202J789 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/05/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202J759 | List: |
| References | |
| 50-423-97-206, NUDOCS 9712110241 | |
| Download: ML20202J789 (5) | |
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NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket No. 50423 Millstone Nuclear Power Station License No. NFP-49 Unit 3 During an NRC inspection conducted August 18-29 and September 8-19,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Technical Specification (TS) 6.8.1.s requires, in part, that written procedures be established and maintained in accordance with the applicable portions of Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. The applicable portions of Appendix A of Regulatory Guide 1.33, Revision 2 include procedures for equipment surveillance and annunciator response.
Contraiy to the above, during an NRC inspection that ended Sep* ember 19,1997, the following instances were identifed where the requirements of TS 6.8.1a were not met:
1.
SP 3608.4, the procedure specified to verify that each charging injection flow path valve 1
not locked or otherwise secured was in its correct position every 31 days as required by TS 4.5.2 b.2 was inadequate. Specifically, the procedure failed to require the verification of the position of 13 unlocked / unsecured charging injection flow path valves (including 3CHS*V706, 3CHS*V44 and CHS*V707).
2.
Procedure SO 3604 A.5, Rev.10, which specifies the testing required of sitemate charging path valves CHS*V190 A and B was inadequate. Specifically, the procedure failed to l
include a prerequisite that the valves, which are only used during special circumstances such as foi, lowing a fire, on!y be tested during cold shutdown when normal charging is isolated.
3.
Procedure SP 3604C.1 which is the procedure that demonstrates that refueling water storage tank (RWST)levelis compliance with TS 3.5.4a was inadequate. Specifically, the procedure as written relies only on wide-range RWST level to verify compliance with the TS but given the inadequate accuracy of the wide-range RWST level, the annunciators actuated by the narrow range level are also necessary and are used by the operators used to demonstrate compliance with the TS.
4.
OP 3353.MB1C, " Main Board 1C Annunciator Response," Rev.1, Change 5,1-1B "CTMT Recire CLR SW FLOW Hl/LO"is inadequate. Specifically, atep 6.2.2 incorrectly required the safety injection pump be stopped for a service water (SW) rupture even with the safety iajection actuated.
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OP 3353.MB1C," Main Board 1C Annunciator Response," Rev.1, Change 5,1-1A "RPCCW HX SW Flow Hi\\LO" is inadequate. Specifically, the procedure failed to require that after an alarm at 6200 gpm is received that a verification of adequate SW flow (7125 gpm) to the heat exchanger for achieving safety grade cold shutdown is performed.
This is a Severity Level IV violation (Supplement 1).
B.
TS 4.5.2.b.1 requires that in Modes 14, ECCS piping, with the exception of the RSS i
pump, heat exchanger and associated piping be verified to be full of water by venting the ECCS pump casing and accessible discharge high points.
Contrary to the above, accessible ECCS vent valve 3SIL*V992 was not vented every 31 days in t
Modes 1-4 to verify the associated piping was full of water, l
This is a Severity Level IV violation (Supplement 1).
C.
10 CFR 50.71 (e) requires, in part, that the licensee update the final safety analysis report (FSAR) to assure that the FSAR contains the latest information developed at an interval not to exceed 24 months.
Contrary to the above, during an NRC inspection ending September 19,1997, the following instances were identified that the information contained in the FSAR had not been updated within the past 24 months:
1.-
FSAR Section 6.3.3.2 states, 'A makeup flow rate from one charging pump is adequate to sustain pressuriza pressure at 2250 psig [2,235 psia) for a break through a.375-inch diameter hole." However, no testing has been done to confirm that the statement and actual-test data indicates that the charging pumps can not perform as described in the FSAR statement.
2.
FSAR Section 9.4.3.1, item 12, states that air flow in the auxiliary building shall be maintained from least contaminated to more contaminated spaces. However, in the winter alignment, air is recirculated from the potentially more contaminated charging pump rooms back to the less contaminated areas of the auxiliary building.
This is a Severity Level IV violation (Supplement I).
D.
10 CFR Part 50, Appendix B, Criterion XVI, requires that conditions adverse to qualiiy be identified and promptly corrected.
Contrary to the above:
1.
The licensee's corrective actions for restricting the use of Teflon tape on components that may be exposed to high radiation doses was inadequate. Specifically, in CR M3-96-0067 the licensee identified and prohibited the use of Teflon tape on components in containment as a condition adverse to quality because of the potential for high radiation doses but failed to
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j similarly restrict the use of such tape in areas outside the containment that could be subject to high radiation levels, i
2.
FSAR Table 6.3.3, *MOV in the ECCS,* which was previously identified by the licensee j
as requiring updating (FSARCR 97-MP3 323), was found to require further updating as the j
information on the interlocks associated with valve 3 CHS*8840 B was stillincorrect.
3.
FSAR Section 7.3.1.1.5 descriptions of the bypassed and inoperable status indication equipment, which was previously identified by the licensee as requiring updating (FS ARCR 97-MP3-101), was found to require further updating as the information failed to reflect that an inoperable safety injection cooling pump would cause the safety injection pump to be inoperable.
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This is a Severity Level IV violation (Supplement 1).
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E.
10 CFR 50.55a requires, in pa t that plant systems be constructed and modified in
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accordance with the applicable ASMc Code. The applicable version of the ASME Code,1971 through the Summer 1973, addenda requires, in part, that the stress indices of NB-3600 be used for Class 1 piping, and the requirements of NC-7512 for pressure drop considerations and those of NC-3677 for sizing of discharge piping t;n followed when designing system relief valves.
i Contrary to the above, when installing orifices 3SlH*R038,039, and 041 in the charging system, the calculation supporting the modification failed to consider the proper stress indices for the installation of the offices. When designing charging system relief valves pressure drop l
considerations for 3CHS*RV8119 and 3CHS*RV8123 failed to consider possible volume control i
tank back pressure and the area of the common discharge line for 3CHS*RV8119 and 8123 i
was considerably smaller than the required combined area of all lines discharging to it.
This is a Severity Level IV violation (Supplement 1).
j F.
10 CFR Part 50, Appendix B, Criterion ill, requires, in part, that design control measures l
be provided for verifying or checking the adequacy of design.
Contrary to the above, measures for verifying the adequacy of the design of the annulus pipe rack structure were inadequate. Specifically, design verification measures failed to identify that i
_ the 1996 calculations performed to demonstrate the annulus rack was within the design stress i
and load limits failed to consider the masses of the supported piping in analyzing the performance of the structure, 4
f This is a Severity Level IV violation (Supplement 1).
G.
TS 6.8.1a requires, in part, that written procedures be established and implemented in accordance with the applicable portions of Appendix A of Regulatory Guide (RG) 1.33, Rev. 2, February 1978. The applicable portions of RG 1.33, Rev. 2, Appendix A, include procedures for j
maintenance and replacement of equipment.
l Contrary to the above, during an NRC inspection that ended September 19,1997, it was j
identified that certain required procedures were not properly implemented. Specifically:
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Nuclear Group Procedure (NGP) 6.12, Rev.1, " Evaluation of Replacement items,"
j requires that Replacement item Evaluations (RIE) include preventative maintenance management system (PMMS) and bill of materials (BOM) updates. However, RIE No. PSE-i MP3E-94101, which evaluated the replacement of relief valve 3CHS*RV8119, did not include PMMS and BOM updates to reflect a change of valve sealing gasket material from asbestos j
(40-year life) or Buna-N (13-year life).
j 2.
Specification SP-ME-570, Rev. 3, " Field Fabrication and Erection of Piping and Supports requires, in part, that all bolted or stud connections have full thread engagement with the nuts.
Further, Common Maintenance procedure, C-MP-715A, Rev. O, requires, in part, that it be verified that nuts have full engageme1 on studs or bolts. However, it was identified that the j
Reactor Coolant Pump A and D seal water injection line pump connections flanges, last made i
up in 1993, each had nuts that were not fully engaged to their respective studs, 3.
Procedure CC1, Rev. 2, " Control of Chemical Consumable Products" requires, in part, that chemical consumable products, including tape, used on primary or secondary systems are either labeled "A" for chemical product use category or are controlled by instructions in the i
automated work order. However, during a walkdown of the seal water injection piping, yellow plastic high pressure tape, not controlled as required above, was found attached to the piping.
This is a Severity Level IV violation (Supplement 1).
j H.
10 CFR 50.49 requires, in part, that safety and nonsafety-related equipment whose j
failure under postulated environmental conditions could prevent the reactor from being shut down and maintained in a safe shutdown condition shall be included in the licensee's environmental qualification program and appropriate environmentally qualified.
Contrary to the above, during an NRC inspection that ended September 1,1997, it was identified that motor operators for valves 3MM*-MOV-18A-D, equipment whose failure under postulated environmental conditions could prevent the reactor from being shut down and i
maintained in a safe shutdown condition, were not in the licensee's environmental qualification program or appropriately environmentally qualified.
i This is a Severity Level IV violation (Supplement 1).
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Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby L
required to submit a written statement or explanation within 30 days of receipt of the letter j
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 Director, Special Projects Office, Office of Nuclear Reactor Regulation, and a copy to the NRC Resident inspector at the Millstone Nuclear Power Station, Unit 3. This reply should be clearly marked as a " Reply to a l
Notice of Violation," sad 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, i
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 j
required response. If an adequate reply is not received within the required time specified in this f
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Notice of Violation, an order or a Demand for Information may be issued as to why the license 4
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 3
response time.
Dated at Rockville, Maryland this 5th day of December,1997 2
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