ML20247D856
| ML20247D856 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247D844 | List: |
| References | |
| 50-423-98-01, 50-423-98-1, EA-98-179, NUDOCS 9805180125 | |
| Download: ML20247D856 (3) | |
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- Northeast Nuclear Energy Company Docket No. 50-423 l
Millstone Unit 3 License No. NPF-49 EA No.98-179 During an NRC inspection conducted from February 23 - 26,1998, for which an exit meeting was conducted on February 26,1998, a violation of NRC requirements was identified..in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Millstone Unit 3 Technical Specification 6.4.8.d, " Administrative Procedures and Programs," " Post Accident Sampling System (PASS)," requires that there be a program in place to ensure the capability to obtain and analyze reactor coolant, radioactive iodine and particulate in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shallinclude:
training, procedures for sampling and analysis, and provisions for maintenance of sampling and analysis equipment.
Contrary to the above, between 1988 and February 26,1998, the licensee failed to maintain an adequate PASS program that ensured the capability to obtain and analyze samples under post accident conditions. Specifically:
From 1988 to 1995, maintenance was ineffective in that continual system pmblems were found during semi-annual surveillance tests, such as instrument tubing and fitting leaks, valve position indication failures, and solenoid valve failures. Further, although a dedicated system engineer was assigned in 1995 to maintain the system, problems continued to occur as evidenced by the fact that 31 condition reports were generated between 1995 and January,1998.
As of February 26,1998, valves at the sample panel were improperly marked and system identification tags could not be distinguished from some of the valve identification tags.
As of February 26,1998, PASS procedures and maintenance were inadequate in that the containment sump portion of the reactor coolant liquid sample module was not operationally tested at least semi-annually to ensure system availability, as described in section 9.3.2.6.4 of the Updated Final Safety Analysis Report (UFSAR).
1 As of February 26,1998, PASS procedures were inadequate in that surveillance procedures lacked sufficient detail to provide the technicians with the information needed to successfully acquire 'a sample and the prerequisite steps in that procedure omitted the type of sample containers needed.
Training of technicians expected to obtain the samples under post accident conditions was inadequate in that the technicians performing the surveillance 9905100125 990506 PDR ADOCK 05000423 G
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2 on February 26,1998, were not familiar with the procedure and needed guidance from chemistry personnel.
Training was inadequate in that PASS drills, that are to be conducted annually per the licensee's Emergency Plan, did not ensure the capability to obtain and analyze samples under post accident conditions because routine surveillance procedures were used to obtain samples during the drills rather than the emergency PASS procedure. The PASS procedure specifies requirements for sample acquisition, radiological protection, analyses and timeliness under emergency conditions. During emergency exercises, post accident sampling was only simulated. Without use of the emergency procedure during PASS drills or during emergency exercises, there was no assurance that a sample could be obtained and analyzed under accident conditions within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> as described in section 9.3.6.2 of the UFSAR.
(01013)
This is a Severity Level lli Violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company (Licensee) 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 1, 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 l
achieved. Your response may reference or include previous docketed correspondence, if I
the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an orde 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, United States 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.
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3 Because your response will be placed in the NRC Public Document Room (PDR), to the j
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
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a bracketed copy of your response that identifies the information that should be protected 3
and a redacted copy of your response that deletes such information. If you request i
withholding of such material, you mM11 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (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.
i Dated at King of Prussia, Pennsylvania this 6th day of May,1998 l
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