ML20210S870

Notice of Violation from Insp on 970520-0721.Violations Noted:Overcoat Window Was Exceeded by 45 Minutes to 2 H & 45 Minutes

ML20210S870
Person / Time
Site:	Millstone
Issue date:	08/29/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20210S864	List: ML20210S860 ML20210S870 ML20210S886
References
50-423-97-202, NUDOCS 9709120171
Download: ML20210S870 (2)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION '

Northeast Nuclear Energy Company Docket No.: 50 423 Millstone Nuclear Power Station License No.: NFP-49 Unit 3 During an NRC inspection conducted on May 29,1997 through July 21,1997, violations of NRC requirements were identified. In accord 6nce with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. Unit 3 Technical Specification 6,8.1 requires that written procedures shall be established, implemented, and maintained for activities referenced in Appendix A of Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements (Operation)." Item 9, " Procedures for Performing Maintenance," of Appendix A to RG 1.33 requires, in part, that maintenance that can affect the performance of safety related equipment should be properly performed in accordance with written procedures.

Procedure MP 3710C, " Application of Linings to Plant Systems Subject to Salt Water immersion," step 4.5.2.c. states, " Refer to applicable product specific technique sheet (PSTS) for the coat to be applied and using surf ace temperature, OBTAIN minimum and maximum times to recoat and RECORD on Maint. Form 3710C 3."

Maintenance Form 3710C-A S30Pr, PSTS for Arcor Polmeric S30 Prime, states that the acceptable maximum overcoat condition is "7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> @72'F or Thumb Nail Test with no indentation, whichever is less."

Contrary to the above, on several occasions in May and June 1997, the overcoat window was exceeded by 45 minutes to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 41 minutes.

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

B. Paragraph (a) of 10 CFR 50.9 " Completeness and accuracy of information,"

requires that "Information provided to the Commission by an applicant for a license or by a licensee or information required by a statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects."

Contrary to the above, in letters to the NRC dated May 29,1997 and July 14, the licensee provided, in part, "...significant items needed to be accomplished prior to restart" and " items to be deferred until after restart." This information was inaccurate or incomplete in that: 1) Open item Reports (OIRs) were not included in the May 29,1997 submittal; 2) control room deficiencies and bypass jumpers were 9709120171 970829 t PDR ADOCK 05000245 G PM

.i not reviewed for inclusion in the May 29,1997 submittal; 3) all existing items were not included in the submittals; and,4) a number of items that the licensee did not intend to defer were improperly included in the list of items to be def erred until af ter j restart. A complete and accurate submittalis important to permit the NRC to assess the potential safety significance of allitems that will not be completed prior to startup.

l This is a Severity 1.evel IV violation (riupplement il for Docket No. 50 423.

l Pursuant to the provisions of 10 CFR 2.P.01, furtheast Nuclear Energy Company is hereby required to submit a written statement or explanation within 30 days of receipt of the letter  ;

transmitting this Notice of Violation (Notice) to the U.S. Nuclear Regulatory Commission, l ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Director, Special Projects Office, and a copy to the NRC Resident inspector at the f acility that is the  !

subject of this Notice. This reply should be clearly marked as a

• Reply to a Notice of Violation" and should include for each violation: (1) the reason f or 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 violat!ons, and (4) the date when full com.pliance 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, 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.

Dated at King of Prussia, Pennsylvania this 29th day of August,1997 s