ML20128D607

Notice of Violation from Insp on 921028-1222.Violation Noted:Bypass Jumpers Not Initiated for Scaffolding Installed for Greater than 90 Days as Required by Procedure ACP 2.19

ML20128D607
Person / Time
Site:	Millstone
Issue date:	02/01/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128D540	List: IR 05000245/1992029 ML20128D535 ML20128D607
References
50-245-92-29, 50-336-92-31, 50-423-92-28, NUDOCS 9302100187
Download: ML20128D607 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION 1

Northeast Nuclear Energy Company Docket Nos.: 50-245; 50-i 336; 50-423 1 Millstone Nuclear Power Station License Nos.: DPR-21; DPR-i 65; NPF-49 j During an NRC inspection conducted on October 28, 1992, through December 22, 1992, j violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC- Enforcement Actions," 10 CFR Part 2, Appendix C, the 2

violations are listed below:

^

A. Millstone Unit 3 Technical Specification 6.8.1 requires that procedures covering station i activities be established and implemented. Station administrative control procedure (ACP) 2.19, " Scaffolding Program," and procedure ACP-QA-2.06B, " Jumper, Lifted l Lead, and Bypass Control," were written punuant to the above.

l Procedure ACP 2.19, step 6.2.1, requires in part, that the installation duration of

! scaffolding should be evaluated and, if required for greater than ninety days, a bypass -

jumper shall be initiated.

Procedure ACP-QA-2.MB, step 6.10 4, requires in part, that the plant operations review

committee review jumper devices that are installed longer than three month _s and provide

[ written determinations stating whether the jumper devices are still needed. Step 6.10.5

requires that for jumper devices installed longer than six months, the Unit Director will inform the Executive Vice President - Nuclear 'on a quarterly basis by summary

memorandum.

Contrary to the above, as of December 22,1992;

1. Bypassjumpers were not initiated for scaffolding installed for greater than ninety

. days as required by procedure ACP 2.19,

2. Plant operations review committee review of bypassjumpers installed over three months or whose expected removal date was exceeded was not being performed as required by procedure ACP-QA-2.%B.

3. The quarterly summary memorandum for bypass jumpers installed over six months was not being submitted to the Executive Vice President as required by

, procedure ACP-QA-2.06B.

1 This is a Severity Level IV Vio!ation (Supplement 1).

9302100187 930201 PDR ADOCK 05000245 O PDR

f 9 B. 10 CFR 50 Appeniix B, Criterion XVI (Corrective Action) requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. These measures shall assure that the causes of significant conditions adverse to quality are identified and corrective actions are taken to preclude repetition.

Northeast Utilities Quality Assurance Program-Topical Report, Revision 15, dated June 15,1992, incorporates the requirements of 10 CFR 50 Appendix B, Criterion XVI.

The licensee's corrective actions to preclude repetition of a mispositioned valve documented in Unit 2 licensee event report (LER) 50-336/90-22 and NRC Inspection Report 50-336DI-02 included a commitment to identify other valves with similar control logic and revise procedures to include information and cautions emphasizing the design features of the suspect valves.

The "A" train suction header isolation valve to the "A" Reactor Building Closed Cooling Water (RBCCW) pump 2-RB-21lE, has a similar control logic to the LER subject valve such that the valve may reposition to an undesired state upon restoration of control air pressure to the valve operator.

Contrary to the above, as of December 4,1992, the licensee had not identified Unit 2 valve 2-RB-21lE as having similar control logic to the previously mispositioned valve, and procedures were not revised to includ: information and cautions to prevent the repetition of the previous event. As a result, valve 2-RB-211E was inadvertently mispositioned during system restoration on December 4,1992, causing a loss of heat sink to shutdown cooling and spent fuel pool cooling for approximately 10 minutes.

This is a Severity Level IV Violation (Supplement I).

C. 10 CFR 50.71(e) requires, in part, that licensees revise the Final Safety Analysis Report (FSAR) annually or 6 months after each refueling outage provided the interval between successive updates to the FSAR does not exceed 24 months. The revisions must reflect all changes up to a maximum of six months prior to the date of filing. The revisions shall include the effects of all changes made in the facility as described in the FSAR.

Contrary to the above:

1. - When on April 13,1989, the licensee completed increasing the Unit I spent fuel pool capacity, the effects of this change were not reflected in an FSAR update submittal dated November 3,1989 or subsequent submittals; and,

1 1 9 Notice of Violation

7.  : When on April 11,1991,' the licensee completed installing new springs in two Unit 3 safety injection ~(SI) system relief valves and raising the SI system design pressure, these changes were not reflected in an FSAR update submittal dated -

February 25,1992.

This is a Severity Level IV. Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby required to submit a written statement o_r explanation to the U.S. Nuclear Regulatory Commission, ATrN: Document Control Desk, Washington, D.C. 20555 with a copy _to the Regional Administrator, Region I, and if applicable, a copy to the NRC Resident Inspector 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 reann for the violation, or, if contested,= the basis for disputing the violation, i (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.

Where good cause is shown, consideration will be given to extending the response time.

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