ML20202A749

Notice of Violation Form Insp on 970722-1001.Violation Noted:On 971215 Activities Affecting Quality Were Not Prescribed by Documented Instructions,Procedures or Drawings

ML20202A749
Person / Time
Site:	Millstone
Issue date:	11/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202A741	List: IR 05000245/1997203 ML20202A737 ML20202A749
References
50-245-97-203, 50-336-97-203, 50-423-97-203, NUDOCS 9712020209
Download: ML20202A749 (4)

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ENCLOSURE 1.

- NOTICE OF VIOLATION -

4 Northeast Nuclear Energy Company Docket Nos.: 50-245: 50-336:50-423 Millstone Nuclear Power Station License Nos.: DPR-21: DPR 65; NFP-49 Units 1, 2, and 3 During an NRC inspection conducted on July 22,1997, through October 1,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the viol 9tions are listed below:

A. Technical Specification 6.8.1, requires that written procedures be established, implemented, and maintained for activities referenced in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2, February 1978. Item 9.a., " Procedures for Performing Maintenance," recommends that maintenance that can affect the performance of safety related equipment should be properly preplanned and performed in accordance with written procedures.

WP 8003, " Unit 1 Work Package Planning," step 1.17.15, requires that IE work has a Quality indicator of "Y" or "U" QB involves non-QA code welding, INDICATE "QC required," "Yes," except for the following activities:

• Motor: Replace air filters, screens, and cover fasteners, er e Tests and calibration (non-EEO): Any test or calibration that do (sic) not disassemble systems beyond designed access covers.

Contrary to the above, on August 25, and August 29,1997, work with a quality i indicator of "Y," indicated "QC required," "No" and did not meet the exceptions stated in step 1.17.15 of WC 8003. The work involved: 1) AWO M197 0956, Gas Turbine Hydraulic Pump Motor Replacement; and 2) AWO M197-05332, Unit 1 CO, Fire System Surveillance Testing, which required disassembl; of the components in the system.

This is a Severity Level IV Violation (Supplement 1) for Docket No, 50-245.

B. _10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Contrary to the above, at Unit 2, on December 15,1997, activities affecting quality were not prescribed by documented instructions, procedures, or drawings, of a type 1

9712020209 971121 PDR ADOCK 05000245 G PDR

appropriate to the circumstances in that Section 5.25 cf Operating Procedure 2322,

'" Auxiliary Feedwater System," was deleted, removing a requirement that had been _'

added to Procedure OP 2322 by Change 8 of revision 22, dated July 3,1995, to cycle periodically turbine-driven auxiliary feedwater pump steam admission valves 2-MS 201 and 2 MS 202. Deletion of the_ requirement from the procedure rendered

. the valves susceptible to thermal binding.

4 This is a Severity Level IV violation (Supplement l} for Docket No. 50-336.

C. 10 CFR 71,5(a) requires that a licensee who transports licensed material outside of

- the confines of its plant or other place of use, or who delivers licensed material to a -

carrier for transport, comply with the applictble requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189. 49 CFR 173.421 requires that radioactive materials shipped as a limited quantity have radiation levels at any point on the external surface of the package not exceeding 0.005 milliSieverts per hour (0.5 millirem /hr).

Contrary to the above, on July 25,1997, a shipment of limited quantity radioactive 1 material was made from Millstone Station, with radiation levels ore the external surface of the package, as high as 0.01 milliSieverts per hour (1.0 millirem /hr).

This is a Severity Level IV violation (Supplement V) for Docket Nos 50-f 245/336/423.

D. Plant technical specification 6.8 requires that the licensee develop, maintain and implement written procedures for areas listed in Appendix A of Regulatory Guide 1,33 (February 1978). Item 7.e (1) of Appendix A lists, " Access control to radiation areas including radiation work permit system," as one of the required i written procedures. Licensee procedure 5.2.2, " Basic Radiation Worker Responsibilities," implements this requirement and requires, in part, that personnel are required to comply with written instructions provided by health physics.

Contrary to the above, on September 8, September 12, and September 13,1997, individuals entered the radiologically controlled areas (RCAs) at Units 1,2 and 3 respectively without wearing electronic dosimetry as required by the radiation work 4

permit, a written health physics instruction. On September 16,1997, an individual exited the RCA at Unit 2 through a door specifically posted as an emergency exit only, and thereby circumvented the normal controls for exiting the RCA.

This is a Severity Level IV violation (Supplement IV) for Docket Nos 50-245/336/423.

Pursuant to the provisions of 10 CFR 2.201, Northeast 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, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Director, Special Projects Office, Nuclear Reactor Regulation , and a copy to the NRC Resident 2

a

- Inspector at the Millstona Station. This reply should be clearly marked as a " Reply to a

' Notice of Violation" and should include for ea'ch violation: (1) the reason for the violation,

or, if contestad, 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 i'

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-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.

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3 i Dated at King of Prussia, Pennsylvania this 21st day of November,1997 1

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