ML20247Q545
| ML20247Q545 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/18/1989 |
| From: | Mroczka E, Romberg W NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8909290015 | |
| Download: ML20247Q545 (3) | |
Text
- .,.
NORTHEAST UTILITIES con <,i Omc,. soie.n si, i. B.,iin, conn ciico,
[
l wmv., v -ns uc=c c "'E P.O. BOX 270
[ww.c uc,7(($.,,,
,72^1" e-w HARTFORD. CONNECTICUT 06141-0270 k
k J
(203) 665-5000 a
September 18, 1989 Docket No. 50-336 A08248 Ret 10 CFR 2.201 i
Mr. V. T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission, Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 1
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Response to Notice of Violation; Inspection 50-336/89-16 In a letter dated August 21, 1989,'*' the NRC Staff issued a Notice of Violetion to the Northeast Nuclear Energy Company (NNECO) for Millstone Unit No. 2.
This action was the result of a routine inspection conducted June 16-July 26, 1989.
Pursuant to the provisions of 10 CFR 2.201, NNECO hereby provides tne following response to the Notice of Violation (Severity Level IV).
Requirement Plant Surveillance Technical Specification 4.3.2.1.1, Amendment 53, dated April 9, 1981, requires implementation of a channel functional test for each engineered safety features actuation system instrument per Table 4.3-2.
Table 4.3-2, item 2e requires a monthly channel functional test of the automatic actuation logic, including the automatic test feature, which is to be verified operable every 31 days.
j (1)
E. Ci Venzinger letter to E. J. Mroczka, dated August 21, 1939, Millstone 2 Routine Inspection 50-336/89-16 (6/16/89 - 7/26/89).
i 8909290015 890918 PDR ADDCK 05000336 G
PNV
\\
OS3422 REV. 4-88
p.,...
4-i L.
NORTHEAST UTILITIES c,,ner,i Omc... seioon si,,,,, e.,,in, conn,ctico, 1*4 C4M*1f CfrCUT 196.W.fmtD Cfp.edy 2C 7.C '[M.7 '""
P.O. BOX 270 HARTFORD, CONNECTICUT 06141-0270 w-,
.uun uma cc -
g J
.(203) 665-5000 e
.rf w.a.a ww u--
September 18, 1989 Docket No. 50-336 A08248 Re:
10 CFR 2.201 Mr. V. T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission, Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Response to Notice of Violation; Inspection 50-336/89-16 In a letter dated August 21, 1989,'*' the NRC Staff issued a Notice of Violation to the Northeast Nuclear Energy Company (NNECO) for Millstone Unit No. 2.
This action was the result of a routine inspection conducted June 16-July 26, 1989. Pursuant to the provisions of 10 CFR 2.201, NNECO hereby provides the following response to the Notice of Violation (Severity Level IV).
Requirement Plant Surveillance Technical Specification 4.3.2.1.1, Amendment 53, dated April 9, 1981, requires implementation of a channel functional test for each engineered safety features actuation system instrument per Table 4.3-2.
Table 4.3-2, item 2e requires a monthly channel functional test of the automatic actuation logic, including the automatic test feature, which is to be verified operable every 31 days.
(1)
E. C. Venzinger letter to E. J. Mroczka, dated August 21, 1989, Millstone 2 Routine Inspection 50-336/89-16 (6/16/89 - 7/26/89).
($N 8909290015 890918 PDR ADOCK 05000336 G
PNU
\\
OS3422 REV. 4-88
o.'
o Mr. V. T. Russell A08248/Pcga 2-September 18, 1989 Finding i
contrary to-the above, the automatic test function of the engineered
-safety features automatic actuation logic was not verified operable pursuant to Technical Specification 4.3.2.1.1 between April 9, 1981-l and July 26, 1989.
Root Cause The root cause is personnel oversight.that occurred in not properly incorporating Technical Specification 4.3.2.1.1 (Amendment 53) into l
Millstone Unit No. 2 surveillance procedures.
I Resolution / Corrective Action Plant in-service testing was performed on July 26, 1989 that demonstrated that the automatic test feature was operable and was accurately testing the portion of the engineered safety features i
actuation system in question. This testing also pointed out the deficiency in the existing plant surveillance procedure SP2403A, that j
had allowed the portion of the automatic test feature to go unchecked.
The surveillance procedure performs a monthly check to verify that the automatic test feature is operable and is automatically testing each of the various actuation lofc pathways. The procedure failed to i
check the testing of the actuation pathway for the Containment Spray Actuation Signal (CSAS).
j l
The in-service testing demonstrated that the automatic test feature also simulates the required Safety Injection Actuation Signal (SIAS) input to allow the testing of the CSAS actuation pathway.
Surveillance. procedure SP2403A has been corrected to include such testing by a revision approved on August 9, 1989, at PORC meeting number 2-89-136.
These actions brought Millstone Unit No. 2 into full compliance with the Technical Specification requirements stated abovec Action to Prevent Recurrence A Technical Specification requirement was not being met due to an omission in a procedure. To ensure no similar conditions exist, a cross check will be made of the surveillance required by Technical Specification section 3/4.3, Instrumentation, against those plant surveillance procedures that are required to implement that section's requirements. This vill be completed by Deceinber 31, 1989.
In addition, NNECO implemented /CP 3.29, " Incorporation of License Amendments" on May 25, 1989. This procedure establishes a method of timely incorporation of license amendments and related requirements into the appropriate NNECO procedures.
.Mr. V. T. Russell A08248/P:gs 3 September 18, 1989 Additional Information In the August 21, 1989 letter, the NRC Staff requested that we pay particular attention to the " prolonged failure to detect this technical spec!fication noncompliance." NNECO acknowledges and shares the NRC's concern and therefore is evaluating further actions (beyond corrective actions described above) te ensure timely detection of noncompliance with technical specifications. We vill, of course, discuss the result of these evaluations with the NRC resident inspector.
We trust the above information satisfactorily responds to your concerns.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Wf% c a to E. J. Mroczka Senior Vice President N0 By:
W. D. Rom W g Vice President STATE OF CONNECTICUT )) ss. Berlin COUNTY OF HARTFORD
)
Then personally appeared before me, W.
D.
Romberg, who being duly sworn, did state that he is Vice President of Northeast Nuclear Energy Company, Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.
}Mbut tary Pub 1[ MyCommissionExpiresMarch31,1993 cc:
G. S. Vissing, NRC Project Manager, Millstone Unit 2 V. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3 E. C. Venzinger, Region I U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D.C.
20555 l
_______________a