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| | NOTICE OF VIOLATION c |
| | North Atlantic Energy Service Corporatior Dockot No. 50-443 Seabrook Station, Unit 1 License No. NPF-86 l EA No. 98-097 During an NRC inspection conducted during the period December 15 through December 18,1397, and January 70 through January 21,1998, 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: |
| | l A. 10 CFR 50.59, " Changes, tests and experiments," in part, permits the licensee to 4 make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report |
| | ! without prior Commission approval, provided the change does not involve a change ; |
| | in the technical specifications or an Unreviewed Safety Question (USO). The |
| | ~ |
| | l licensee shall maintain records of changes in the facility and these records must i include a written safety evaluation which provides the bases for the determination j that the change does not involve a USO. |
| | t. |
| | l- UFSAR, section 17.2.12.3, Calibration, states, in part, that primary standards have |
| | ! an accuracy of at least four times the required accuracy of the end use equipment |
| | ; being calibrated. |
| | i 2 |
| | -Contrary to the above, on March 13,1997, the licensee changed procedures as - |
| | i described in the UFSAR and failed to perform a written safety evaluation to |
| | ;- determine that the change did not involve an unreviewed safety question (USO). |
| | Specifically, the licensee changed procedure MA 2.3, " Control and Calibration of - |
| | Measuring and Test Equipment," Section 4.1.8, which implements UFSAR, Section 17.2.12.3,to modify the requirement for accuracy of the primary standards auch s that the procedure no longer required that the primary standard have an accuracy of 1- at least four times the required accuracy of the end use equipment being calibrated. |
| | d No safety evaluation was performed to determine that the deletion of the requirement to compare the accuracy of the primary standard with the end use 4 |
| | equipment did not involve a USQ. |
| | This is a Severity Level IV Violation (Supplement 1). |
| | i B. 10_CFR 50, Appendix B, Criterion XII, " Control of Measuring and Test Equipment," |
| | requires measures to be established to assure that tools, gages, instruments, and i other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. |
| | UFSAR, Section 17.2.12.3, Calibration, states, in part, that primary standards have l an accuracy of at least four times the required accuracy of the end use equipment i' being calibrated. Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and documented. |
| | j 9802270042 980220 ADOCK 05000443 PDR 3 |
| | . - - . , , . - , , , . - , en . - . . . ,,n ,,.~..n- , ...,..,n ,, , --. |
| | |
| | O Notice of Violation 2 Contrary to the above, prior to January 21,1998, measuring and testing devices were not properly controlled to maintain accuracy within necessary limits. |
| | Procedure MA 2.3, section 4.4.2, which implements UFSAR, section 17.2.12.3, did not require authorization and documentation for standards less accurate than 4:1. |
| | This is a Severity Level IV Violation (Supplement 1). |
| | Pursuant to the provisions of 10 CFR 2.201, North Atlantic Energy Service Corporation 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 reeson 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 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 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 Nuciaar Regulatory Commission, Washington, DC 20555-0001. |
| | Because your response will be placed in the NRC Public Document Room (PDR), to the 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 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 mWi.t 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, Pennsylvania this RQth day of February,1998. |
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Category:NOTICE OF VIOLATION OF A REGULATION
MONTHYEARML20210P3431999-08-0303 August 1999 Notice of Violation from Insp on 990129-0527.Violation Noted:On 980116,G Pageau Engaged in Deliberate Misconduct That Caused Naesco to Be in Violation of 10CFR50.7 ML20210P3251999-08-0303 August 1999 Notice of Violation from Insp on 980129-0527.Violation Noted:On 990116,Willimas Power Corp (Wpc),Contractor for Naesco,Discriminated Against Wpc Electrician Due to Employee Involvement in Protected Activity ML20210N5781999-08-0303 August 1999 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:On 980116,licensee Contractor Discriminated Against Contractor Electrician Due to Employee Involvement in Protected Activity ML20198C1441998-12-11011 December 1998 Notice of Violation from Insp on 981004-1114.Violation Noted:On 981113, a Service Water & a Cooling Tower SWS Removed from Service to Conduct Planned Maint on SWS Valve & Applicable TS Action Statement Not Identified & Tracked ML20236W2411998-07-30030 July 1998 Notice of Violation from Insp on 980517-0704.Violation Noted:On 980504,licensee Did Not Take Action to Promptly Identify Whether Steam Pressure Protection Channels for a & D Steam Generators Operable,After Three Found Inoperable ML20217L8231998-04-27027 April 1998 Notice of Violation from Insp on 980201-0328.Violation Noted:On 980313,inspector Identified That Four Individuals Performing Work Inside Posted Contaminated Area Failed to Comply W/Radiation Work Permits & Posted Instructions ML20217L0631998-04-0101 April 1998 Notice of Violation from Insp on 971207-980131.Violation Noted:Measures Not Established to Assure That Significant Conditions Adverse to Quality Promptly Identified & Corrected ML20203E4091998-02-20020 February 1998 Notice of Violation from Insp on 971215-18 & 980120-21. Violations Noted:On 970313,licensee Changed Procedures as Described in UFSAR & Failed to Perform Written SE to Determine That Change Did Not Involve USQ ML20199L3191997-11-20020 November 1997 Notice of Violation from Insp on 970816-1004.Violation Noted:Mfp Reassembled & Tested W/O Terminating Lead (D4) Defeating Electrical Trip Capability of MFP ML20211G0061997-09-23023 September 1997 NOV from Insp on 970616-0815.Violation Noted:Staff Changed Lineup of Safety Injection Sys Test Header from Primary Drain Tank to Refueling Water Storage Tank W/O Properly Changing Procedure Os 1005.05,Safety Injection Operation ML20210N5811997-08-13013 August 1997 Corrected NOV Consisting of Revised Pages ML20196J6501997-07-30030 July 1997 Notice of Violation from Insp on 970522.Violation Noted: Vehicle Number Ldv 16-02 Found Unattended W/Keys in Ignition & Running & Not in Control of Authorized Person ML20140D1241997-05-30030 May 1997 Notice of Violation from Insp on 970304-0414.Violation Noted:On 950305,35 Licensee Designated Vehicles in Use Outside Protected Area for Purposes Other than Servicing, Repairs,Emergencies or Moving Supplies from Warehouse ML20133A5351996-12-24024 December 1996 Notice of Violation from Insp on 961001-1129.Violation Noted:On 940127,licensee Implemented Change 1 to Rev 7 to Station Procedure, Startup Feed Pump Operation, That Authorized Sys Configuration During Normal Plant Operation ML20135A1381996-11-22022 November 1996 Notice of Violation from Insp on 960813-0930.Violation Noted:On 960821,inspector Identified Three 4 Inch Floor Drains in EFW Pump House Covered with Tape During Painting Activities,Which Constituted Change to Facility ML20058P9531993-10-15015 October 1993 Notice of Violation from Insp on 920310-13.Violation Noted: Licensee Determined That Records Required to Be Maintained by Commission Regulations or License Conditions Not Complete & Accurate in All Matls Respects ML20056H2261993-08-31031 August 1993 Notice of Violation from Insp on 930615-0726.Violation Noted:Maint Workers Identified Need for & Installed Electrical Jumper W/O Performing Work Request Scope Change ML20128E2941992-12-0101 December 1992 Notice of Violation from Insp on 921013-1116.Violation Noted:On 921110,containment Air Lock Seal Leakage Had Not Been Verified for Over 72 H After Plant Had Entered Mode 4 & Air Lock Had Been Used for Multiple Entries ML20058P7901990-08-16016 August 1990 Notice of Violation from Insp on 900625-0729.Violation Noted:Circuit Breakers Feeding Power Distribution Panels Found to Have Been in Shut Position for 78 H During Mode 1 Operation ML20247R5851989-05-25025 May 1989 Notice of Violation from Insp on 890228-0424.Violation Noted:Valves CS-V625 & CS-V176 Found Mispositioned & Measures Established to Implement Procedure to Verify Closed,Locked & Chained Position of Valves Found Inadequate ML20206F8741988-11-0909 November 1988 Partially Withheld Notice of Violation from Insp on 880926-29 (Ref 10CFR73.21) ML20155E6141988-10-0606 October 1988 Notice of Violation from Insp on 880706-0906.Violation Noted:On 880224,start Failure Occurred on Train B Emergency Diesel Generator Which Was Not Reported to NRC Until 880722 ML20236B9921987-10-21021 October 1987 Notice of Violation from Insp on 870707-0908.Violation Noted:One Train of Control Room Air Intake Radiation Instrumentation Incapable of Isolating Control Room.Licensee Corrective Actions Did Not Preclude Repetitive Failing ML20237H8411987-08-19019 August 1987 Notice of Violation from Insp on 870720-24.Violation Noted: Safety Tagging Operations Improperly Controlled.Svc Hearing List Encl ML20236E6551987-07-28028 July 1987 Notice of Violation from Insp on 870505-0706.Violation Noted:Safety Evaluation Not Performed to Ensure Mod Did Not Involve Unreviewed Safety Question & Responsible Station Staff Members Unaware of Mod Initiated by Operation Dept ML20206L6291987-04-10010 April 1987 Notice of Violation from Insp on 870103-0309.Hearing Svc List Encl ML20205G3951987-03-23023 March 1987 Notice of Violation from Insp on 870219-20 ML20211P9761986-12-12012 December 1986 Notice of Violation from Insp on 860916-1110 ML20211F7591986-10-22022 October 1986 Notice of Violation from Insp on 860708-0915 ML20198J4161986-05-28028 May 1986 Notice of Violation from Insp on 860310-21 ML20204A0241986-04-29029 April 1986 Notice of Violation from Insp on 860203-0331 ML20137Z8721985-10-0303 October 1985 Notice of Violation from Insp on 850603-14 IR 05000708/20080271985-09-18018 September 1985 Notice of Violation from Insp on 850708-0827 ML20055B6081982-07-0808 July 1982 Notice of Violation from Insp on 820601-18 ML20054F7921982-05-26026 May 1982 Notice of Violation from Insp on 820323-0503 1999-08-03
[Table view] Category:TEXT-INSPECTION & AUDIT & I&E CIRCULARS
MONTHYEARIR 05000443/19990101999-09-24024 September 1999 Insp Rept 50-443/99-10 on 990726-30 & 0809-13.No Violations Noted.Major Areas Inspected:Corrective Action Program IR 05000443/19990051999-08-25025 August 1999 Insp Rept 50-443/99-05 on 990621-0801.No Violations Noted. Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maint & Plant Support ML20210P3251999-08-0303 August 1999 Notice of Violation from Insp on 980129-0527.Violation Noted:On 990116,Willimas Power Corp (Wpc),Contractor for Naesco,Discriminated Against Wpc Electrician Due to Employee Involvement in Protected Activity ML20210N5781999-08-0303 August 1999 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:On 980116,licensee Contractor Discriminated Against Contractor Electrician Due to Employee Involvement in Protected Activity ML20210P3431999-08-0303 August 1999 Notice of Violation from Insp on 990129-0527.Violation Noted:On 980116,G Pageau Engaged in Deliberate Misconduct That Caused Naesco to Be in Violation of 10CFR50.7 ML20211A7351999-07-29029 July 1999 EN-99-029:on 990803,notice of Proposed Imposition of Civil Penalty in Amount of $55,000 Issued to Licensee.Based on Severity Level III Violation Involving Licensee Contractor That Discriminated Against Contractor Electrician IR 05000443/19990061999-07-26026 July 1999 Insp Rept 50-443/99-06 on 990510-0620.No Violations Noted. Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maint & Plant Support,Including Security Controls ML20196E0261999-06-21021 June 1999 Insp Rept 50-443/99-01 on 990321-0509.Violations Noted. Major Areas Inspected:Aspects of Licensee Operations,Maint, Engineering & Plant Support IR 05000443/19990031999-05-20020 May 1999 Insp Rept 50-443/99-03 on 990308-0408.Non-cited Violations Noted.Major Areas Inspected:Licensee Engineering Activities Which Included in-depth Review of PCCW Sys IR 05000443/19990011999-04-20020 April 1999 Insp Rept 50-443/99-01 on 990207-0321.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support IR 05000443/19980111999-02-26026 February 1999 Insp Rept 50-443/98-11 on 981228-990207.No Violations Noted.Major Areas Inspected:Licensee Operations,Engineering, Maint & Plant Support IR 05000443/19980101999-01-28028 January 1999 Insp Rept 50-443/98-10 on 981115-1227.No Violations Noted. Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maint & Plant Support IR 05000443/19980091998-12-11011 December 1998 Insp Rept 50-443/98-09 on 981004-1114.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support ML20198C1441998-12-11011 December 1998 Notice of Violation from Insp on 981004-1114.Violation Noted:On 981113, a Service Water & a Cooling Tower SWS Removed from Service to Conduct Planned Maint on SWS Valve & Applicable TS Action Statement Not Identified & Tracked IR 05000443/19983011998-11-25025 November 1998 NRC Operator Licensing Exam Rept 50-443/98-301 (Including Completed & Graded Tests) for Tests Administered on 981016- 981016-23.All Five SRO & All Four RO Applicants Passed All Portions of Exam PNO-I-98-051, on 981112,licensee Shutdown Seabrook Station, After Visual Insp Indicated Damage to Main Generator a Phase Output bus.One-week Outage Planned to Troubleshoot & Repair Bus Ductwork.Licensee Did Not Issue Press Release1998-11-13013 November 1998 PNO-I-98-051:on 981112,licensee Shutdown Seabrook Station, After Visual Insp Indicated Damage to Main Generator a Phase Output bus.One-week Outage Planned to Troubleshoot & Repair Bus Ductwork.Licensee Did Not Issue Press Release IR 05000443/19980061998-11-0606 November 1998 Insp Rept 50-443/98-06 on 980823-1003.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support IR 05000443/19980081998-10-16016 October 1998 Insp Rept 50-443/98-08 on 980921-25.No Violations Noted. Major Areas Inspected:Long Term MOV Program Under GL 89-10 Program at Seabrook Station & Will Review long-term MOV Program Under GL 96-05 IR 05000443/19980071998-10-0202 October 1998 Errata to Insp Rept 50-443/98-07 on 980803-07,including Coversheet & Executive Summary Pages ML20154B1681998-09-28028 September 1998 Insp Rept 50-443/98-09 on 980803-07.Violations Noted.Major Areas inspected:medium-voltage & low-voltage Power Circuit Breakers IR 05000443/19980051998-09-25025 September 1998 Insp Rept 50-443/98-05 on 980705-0822.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support Re Licensee Security Facilities & Equipment in Areas of Protective Area Assessment Aids IR 05000443/19980041998-07-30030 July 1998 Insp Rept 50-443/98-04 on 980517-0704.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support ML20236W2411998-07-30030 July 1998 Notice of Violation from Insp on 980517-0704.Violation Noted:On 980504,licensee Did Not Take Action to Promptly Identify Whether Steam Pressure Protection Channels for a & D Steam Generators Operable,After Three Found Inoperable IR 05000443/19980031998-07-0909 July 1998 Insp Rept 50-443/98-03 on 980602-04.No Violations Noted. Major Areas Inspected:Insp Observed & Evaluated Licensee Biennial full-participation Exercise in Simulator Control Room,Technical Support Ctr & Operations Support Ctr PNO-I-98-022, on 980611,Seabrook Station Commenced Plant Shutdown After Declaring Control Bldg Air Conditioning Sys Inoperable.Licensee Evaluating Problems Associated W/Air Conditioning Sys.State of Nh Has Been Notified1998-06-12012 June 1998 PNO-I-98-022:on 980611,Seabrook Station Commenced Plant Shutdown After Declaring Control Bldg Air Conditioning Sys Inoperable.Licensee Evaluating Problems Associated W/Air Conditioning Sys.State of Nh Has Been Notified IR 05000443/19980021998-06-12012 June 1998 Insp Rept 50-443/98-02 on 980329-0516.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support ML20217L8231998-04-27027 April 1998 Notice of Violation from Insp on 980201-0328.Violation Noted:On 980313,inspector Identified That Four Individuals Performing Work Inside Posted Contaminated Area Failed to Comply W/Radiation Work Permits & Posted Instructions ML20217L8311998-04-27027 April 1998 Insp Rept 50-443/98-01 on 980201-0328.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support ML20217L0631998-04-0101 April 1998 Notice of Violation from Insp on 971207-980131.Violation Noted:Measures Not Established to Assure That Significant Conditions Adverse to Quality Promptly Identified & Corrected ML20216B1271998-02-27027 February 1998 Insp Rept 50-443/97-08 on 971212-980131.No Violations Noted. Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maint & Plant Support IR 05000443/19970091998-02-20020 February 1998 Insp Rept 50-443/97-09 on 971215-18 & 980120-21.Violations Noted.Major Areas Inspected:Maint ML20203E4091998-02-20020 February 1998 Notice of Violation from Insp on 971215-18 & 980120-21. Violations Noted:On 970313,licensee Changed Procedures as Described in UFSAR & Failed to Perform Written SE to Determine That Change Did Not Involve USQ IR 05000443/19970991998-01-23023 January 1998 SALP Rept 50-443/97-99 for 960505-971206 IR 05000443/19970071998-01-0707 January 1998 Insp Rept 50-443/97-07 on 971005-1206.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support Re Implementation of Security Program ML20199L3191997-11-20020 November 1997 Notice of Violation from Insp on 970816-1004.Violation Noted:Mfp Reassembled & Tested W/O Terminating Lead (D4) Defeating Electrical Trip Capability of MFP IR 05000443/19970061997-11-20020 November 1997 Insp Rept 50-443/97-06 on 970816-1004.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering, Maint & Plant Support IR 05000443/19970051997-10-27027 October 1997 Insp Rept 50-443/97-05 on 970825-0910.No Violations Noted. Major Areas Inspected:Process of Operating Experience, Trending,Tagging & self-assesment ML20211G0121997-09-23023 September 1997 Insp Rept 50-443 on 970616-0815.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support & Emergency Preparedness Program ML20211G0061997-09-23023 September 1997 NOV from Insp on 970616-0815.Violation Noted:Staff Changed Lineup of Safety Injection Sys Test Header from Primary Drain Tank to Refueling Water Storage Tank W/O Properly Changing Procedure Os 1005.05,Safety Injection Operation ML20210N5811997-08-13013 August 1997 Corrected NOV Consisting of Revised Pages IR 05000443/19970031997-08-13013 August 1997 Corrected Insp Rept 50-443/97-03 Consisting of Changes to Section S1.2.c ML20196J6501997-07-30030 July 1997 Notice of Violation from Insp on 970522.Violation Noted: Vehicle Number Ldv 16-02 Found Unattended W/Keys in Ignition & Running & Not in Control of Authorized Person ML20196J6691997-07-30030 July 1997 Insp Rept 50-443/97-03 on 970415-0615.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support ML20140D1281997-05-30030 May 1997 Insp Rept 50-443/97-02 on 970304-0414.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support ML20140D1241997-05-30030 May 1997 Notice of Violation from Insp on 970304-0414.Violation Noted:On 950305,35 Licensee Designated Vehicles in Use Outside Protected Area for Purposes Other than Servicing, Repairs,Emergencies or Moving Supplies from Warehouse PNO-I-97-025A, on 970426,protest Related to Twentieth Anniversary of Mass Arrest at Seabrook in 1997 Update Made. Forty Protestors Arrested for Trespassing After Climbing owner-controlled Fence1997-04-28028 April 1997 PNO-I-97-025A:on 970426,protest Related to Twentieth Anniversary of Mass Arrest at Seabrook in 1997 Update Made. Forty Protestors Arrested for Trespassing After Climbing owner-controlled Fence PNO-I-97-025, on 970426,Clamshell Alliance Planning Twentieth Anniversary civil-disobedience Rally at Seabrook Site. Licensee Made Special Arrangements to Escort Reporters to Cover Demonstration from Inside Site Boundary Fence1997-04-25025 April 1997 PNO-I-97-025:on 970426,Clamshell Alliance Planning Twentieth Anniversary civil-disobedience Rally at Seabrook Site. Licensee Made Special Arrangements to Escort Reporters to Cover Demonstration from Inside Site Boundary Fence IR 05000443/19970011997-04-0808 April 1997 Insp Rept 50-443/97-01 on 970114-0303.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support IR 05000443/19960111997-03-0707 March 1997 Insp Rept 50-443/96-11 on 961130-970113.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support ML20133A5351996-12-24024 December 1996 Notice of Violation from Insp on 961001-1129.Violation Noted:On 940127,licensee Implemented Change 1 to Rev 7 to Station Procedure, Startup Feed Pump Operation, That Authorized Sys Configuration During Normal Plant Operation 1999-09-24
[Table view] |
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NOTICE OF VIOLATION c
North Atlantic Energy Service Corporatior Dockot No. 50-443 Seabrook Station, Unit 1 License No. NPF-86 l EA No.98-097 During an NRC inspection conducted during the period December 15 through December 18,1397, and January 70 through January 21,1998, 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:
l A. 10 CFR 50.59, " Changes, tests and experiments," in part, permits the licensee to 4 make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report
! without prior Commission approval, provided the change does not involve a change ;
in the technical specifications or an Unreviewed Safety Question (USO). The
~
l licensee shall maintain records of changes in the facility and these records must i include a written safety evaluation which provides the bases for the determination j that the change does not involve a USO.
t.
l- UFSAR, section 17.2.12.3, Calibration, states, in part, that primary standards have
! an accuracy of at least four times the required accuracy of the end use equipment
- being calibrated.
i 2
-Contrary to the above, on March 13,1997, the licensee changed procedures as -
i described in the UFSAR and failed to perform a written safety evaluation to
- - determine that the change did not involve an unreviewed safety question (USO).
Specifically, the licensee changed procedure MA 2.3, " Control and Calibration of -
Measuring and Test Equipment," Section 4.1.8, which implements UFSAR, Section 17.2.12.3,to modify the requirement for accuracy of the primary standards auch s that the procedure no longer required that the primary standard have an accuracy of 1- at least four times the required accuracy of the end use equipment being calibrated.
d No safety evaluation was performed to determine that the deletion of the requirement to compare the accuracy of the primary standard with the end use 4
equipment did not involve a USQ.
This is a Severity Level IV Violation (Supplement 1).
i B. 10_CFR 50, Appendix B, Criterion XII, " Control of Measuring and Test Equipment,"
requires measures to be established to assure that tools, gages, instruments, and i other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
UFSAR, Section 17.2.12.3, Calibration, states, in part, that primary standards have l an accuracy of at least four times the required accuracy of the end use equipment i' being calibrated. Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and documented.
j 9802270042 980220 ADOCK 05000443 PDR 3
. - - . , , . - , , , . - , en . - . . . ,,n ,,.~..n- , ...,..,n ,, , --.
O Notice of Violation 2 Contrary to the above, prior to January 21,1998, measuring and testing devices were not properly controlled to maintain accuracy within necessary limits.
Procedure MA 2.3, section 4.4.2, which implements UFSAR, section 17.2.12.3, did not require authorization and documentation for standards less accurate than 4:1.
This is a Severity Level IV Violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, North Atlantic Energy Service Corporation 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 reeson 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 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 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 Nuciaar Regulatory Commission, Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), to the 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 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 mWi.t 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, Pennsylvania this RQth day of February,1998.
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