ML20249B042

Notice of Violations from Insp on 980413-24.Violations Noted:Only 1 RCS Loop Operable W/Plant in Mode 4 on 980407

ML20249B042
Person / Time
Site:	Millstone
Issue date:	06/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20249B041	List: IR 05000423/1997083 ML20249B040 ML20249B042
References
50-423-97-83, NUDOCS 9806220006
Download: ML20249B042 (4)

Text

.- _ ._ _ __- _ - _ _ _ _ _ _ - - _ _ _ _ _ - _ - -

' ENCLOSURE 1-

- NOTICE OF VIOLATION

^

Northeast Nuclear Energy Company Docket No. 423 Millstone Nuclear Power Station Unit 3 License No. NPF-49 During'an NRC inspection conducted on April 13-24, 1998, several violations of NRC requirements were identified. In accordance with NUREG-1800, " General Statement of Policy and Procedure for NRC Enforcement Actions," these violations are listed below:

A. . . Technical Specification (TS) 6.8.3 requires, in part, that temporary changes to procedures of Specification 6.8.1 (including Appendix A of Regulatory Guide 1.33) may be made provided (a) the intent of the original procedure is not altered; (b) the change is approved by two members of plant management staff, at least one of

. whom holds a Senior Operator license on the unit affected; and (c) the change is -

documented and reviewed by the Plant Operations Review Committee (PORC) or Site Operations Review Committee (SORC) or Station Qualified Reviewer, ... within 14 days of implementation.

Contrary to the above, as of February 20,1998, administrative procedure Document Control (DC) 4, " Procedural Compliance," allowed operators to make non-intent changes to procedures without being approved by two members of plant management staff or reviewed by the PORC or SORC or Station Qualified Reviewer,

... within 14 days of implementation. Examples of procedure.non-intent changes where required reviews were not completed included not isolating a residual heat removal (RHR) loop from the reactor coolant system as required when aligning the RHR loop fcr safety injection (OP 3310A, Residual Heat Removal System);

exceeding the guidance of a procedural caution statement (SP 3606.4, Containment Recirculation Pump 3RSS*P1D Operational Readiness Test); and performing procedure steps out of order and not removing vent rigs (OP 3301D, Reactor Coolant Pump Operation).

This is a Severity Level IV violation (Supplement l}

B. TS 3.4.1.3 requires, in part, that at least two of the reactor coolant system loops (from among 4-reactor coolant system loops and/or 2-residual heat removal loops)

. shall be operable in Mode 4.

Contrary to the above, on April 7,1998, at 22:54 hours, only 1 reactor coolant system (RCS) loop was operable with the plant in Mode 4. This violation continued until April 8,1998, at 18:10 hours, when a second RCS loop was made operable.

t

-.This is 'a Severity Level IV violation (Supplement l}

C.- TS 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of

' Regulatory Guide 1.33,' Revision 2, February 1978.

_' - f n .

(

1 2

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, item 2a requires general operating procedures for cold shutdown to hot standby, item 3j requires procedures for startup, operation and shutdown of safety-related pressurized water reactor (PWR) systems for pressurizer pressure and spray control systems, and item 1d requires that administrative procedures covering procedure adherence and temporary change methoo be developed. l Contrary to the above, written procedures were not implemented as evidenced by the following examples: l

1. Operating Procedure OP-3301G, step 4.1.6, requires the operators to place the pressurizer master pressure controller in automatic. l On April 12,1998, operators deviated from the operating procedure and did not place the master pressure controller in automatic in accordance with step 4.1.6. Instead they manually lowered the master pressure controller in an attempt to match the automatic and manual signals. This failure to follow the procedure resulted in two inadvertent openings of the pressurizer power operated relief valve.

2. Operating Procedure (OP) 3201, " Plant Heatup," step 4.4.9, requires that steam generator level be maintained between 45-55%.

On April 11,1998, operators failed to maintain the level in the "C" steam generator between 45-55% during a plant heatup. The level in the "C" steam generator dropped to the low-low level setpoint (18%) before level was automatically restored by the motor-driven auxiliary feedwater ptmps.

3. Condition Based Maintenance Procedure CBM 105, "PM Program Changs and Deferrals for U3," states that, " deferral requests are required if a PM , .

cannot be performed within its grace period.

On April 13,1998, a preventive maintenance task (automated work orde' 96-12561) for the turbine auxiliary feedwater pump governor had not been deferred or performed within its grace period.

This is a Severity Level IV violation (Supplement l}

D. Technical Specification (TS) 3.4.9.2 requires, in part, that pressurizer temperature shall be determined to be within the limits at least once per 30 minutes during l system heatup or cooldown.

1 Contrary to the above, on April 1,1998, pressurizer temperature was not determined to be within the lirnits at least once per 30 minutes during a plant heatup. The pressurizer heatup rate was not compared to Technical Specification limits between 04:00 hours and 04:45 hours as required.

3 This is a Severity Level IV violation (Supplement 1)

E. Criterion XVI of 10 CFR 50, Appendix B, requires, in part, that measures must be established to assure that conditions adverse to quality, such as failures, malfunction, deficiencies, deviations, defective material and equipment, and nonconformances are promntly identified and corrected. For significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

1) Contrary to the above, as of April 13,1998, appropriate corrective actions were not taken to prevent recurring system alignment deficiencies that were identified in an investigation report , " Configuration Control of Valves Switches / Breakers, CR-M3-97-0485." These deficiencies included valves not properly aligned, inadequacies in the implementation of the valve and breaker alignment process, and deficiencies in the implementation of the locked valve procedures.

This is a Severity Level IV Violation (Supplement 1). i l

F. TS Table 3.3-1, Functional Unit 21, Action 5(a), requires, in part, that with a Shutdown Margin Monitoring channel inoperable, restore the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or verify valves as per Specification 4.1.1.2.2 l (potential dilution paths), are closed and secured in position within the next four i l

hours.

Contrary to the above, on April 8,1998, at 21:15 hours,52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> after declaring a Shutdown Margin Monitoring channelinoperable, the valves identified in Specification 4.1.1.2.2 had not been verified to be closed and secured in position.

On April 9,1998, upon discovery of this deficiency by the licensee, the valves were i verified closed and secured in position.

This is a Severity Level IV violation (Supplement 1)

Pursuant to the provisions of Title 10 of the Code of FederalRegulations (10 CFR), Section 2.201, Northeast Nuclear Energy Company (NNECO) 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 Director, Special Projects Office, and a copy to the NRC Resider.t inspector at Millstone within 30 days of the receipt L date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly I 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 l

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 l

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 l

4 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, U.S. 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, proprietar

• 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

- 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 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.

Dated at King.of Prussia, Pa this 12th day of June,1998 s .. t L

l m

i

- _= = - -