ML20249C693

Notice of Violations from Combined Insp on 980301-0427. Violations Noted:Prior to 980424,instrument Min Accuracy of Wind Speed Channels Were Not Measured as Required by Table 3.3-8 of Unit 2 TS 3/4.3.3.4

ML20249C693
Person / Time
Site:	Millstone
Issue date:	06/19/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20249C689	List: ML20249C688 ML20249C693
References
50-245-98-207, 50-336-98-207, 50-423-98-207, NUDOCS 9807010049
Download: ML20249C693 (5)

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ENCLOSURE 1 NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket Nos.: 50-245;50-336 50-423 Millstone Nuclear Power Station License Nos.: DPR-21; DPR-65; NFP-49 l

Units 1,2, and 3 During an NRC inspection conducted on March 1,1998, through April 27,1998, 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:

A.

Criterion Vil of 10 CFR 50, Appendix B, " Control Of Purchased Material, Equipment, And Services," states in part, that measures shall be established to assure that purchased material conforms to the procure' ment documents, and documentary evidence that material conforms to the procurement requirements shall be available prior to use of such material.

Contrary to the above, the licensee failed to ensure that measures were established to assure that purchased material conformed to the procurement documents, and l

documentary evidence that material conformed to the procurement requirements l

were not available prior to use of such material as evidenced by the following I

examples:

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As early as May of 1992, the licensee failed to identify that kerosene was delivered and used in the emergency gas turbine generator instead of Jet A-1 fuel as required by applicable procurement documents.

2.

Between 1995, until a gas turbine generator fuel oil delivery on May 13, 1998, the licensee failed to document in maintenance receipt inspection reports that the fuel oil conformed to the procurement documents prior to its use in the emergency gas turbine generator.

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

B.

Paragraph (a) of 10 CFR 50.9, " Completeness and accuracy of information,"

l requires that "Information provided to the Commission by an applicant for a license l

or by a licensee or information required by a statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects."

1 Contrary to the above, the licensee's submittal to the NRC dated September 3, 1997, which involved a proposed revision to the final safety analysis report to address the fact that the emergency diesel generators (EDG) fuel oil supply tanks l

l did not have the required 7-day capacity, provided information that was not i

complete with respect to the following statement: "However, replenishment of fuel l

oil could be accomplished via an offsite source." This statement was incomplete in that the methods to directly replenish the fuel oil via an offsite source had not been determined and that the licensee planned to utilize the site emergency response organization to determine how to refill the fuel oil storage tanks following an event.

i 9807010049 980619 PDR ADOCK 05000245 O

PDR L

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2 The September 3,1997, submittal did not describe the fact that the fill connection to the fuel oil storage tanks had not been formally established, necessary pumps and hoses had not been staged, and procedures and training had not been provicad to replenish the supply tanks from a fuel oil delivery truck.

This is a Severity Level IV violation (Supplement 1) for Docket No. 50-336.

C.

Unit 2 Technical Specification 6.8.1.a requires that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix "A" of Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements (Operation)." RG 1.33, Appendix "A", Paragraph 3, recommends procedures for draining various safety-related systems. An example would be the Emergency Core Cooling Systems.

Contrary to the above, as of March 13,1998, with the exception of the Reactor Coolant System, procedures had not been established for draining various safety-related systems listed in RG 1.33, Appendix "A", Paragraph 3. One example was the Low Pressure Safety injection System.

This is a Severity Level IV Violation (Supplement 1) for Docket No. 50-336.

D.

Table 3.3-8 of Unit 2 Technical Specification 3/4.3.3.4 requires that the instrument minimum accuracies of the meteorological monitoring instrumentation channels (wind speed, wind direction, and delta temperature) be measured semiannually.

Contrary to the above, prior to April 24,1998, the instrument minimum accuracy of the wind speed channels were not measured as required by Table 3.3-8 of the Unit 2 TS 3/4.3.3.4.

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

E.

Unit 2 Technical Specification 3.3.3.9 states that the radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with applicable alarm / trip setpoints set to ensure the limits of Specification 3.11.1.1 are not exceeded. The setpoints shall be determined in accordance with methods and parameters as described in the Offsite Dose Calculation Manual (OCDM). Unit 2 Technical Specification 4.3.3.9 states that each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated operable by performance of a channel functional test at the frequency specified in Table 4.3-12. Unit 2 Technical Specification Table 4.3-12(1) requires a quarterly channel functional test of the gross radioactivity monitors for the Clean Liquid Radwaste Effluent Line, the Aerated Liquid Radwaste Effluent Line, and the Condensate Polishing Facility Waste Neutralizing Sump.

Unit 2 Technical Specification 3.3.3.10 states that the radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with applicable alarm / trip setpoints set to ensure the limits of Specification 3.11.2.1

.are not exceeded. Unit 2 Technical Specification 4.3.3.10 requires that each l

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3 radioactive gaseous effluent monitoring instrumentation channel shall be i-demonstrated operable by performance of a channel functional test at the frequency specified in Table 4.3-13. Unit 2 Technical Specification Table 4.3-13(2) requires a j

quarterly channel functional test of the Millstone 1 Main Stack Noble Gas Activity i

Monitor.

l Technical Specification 1.11, states that "A channel functional test shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify operability including alarm and/or trip functions."

Contrary to the above since 1996, each liquid and gaseous effluent monitoring instrumentation channel was not demonstrated operable by performance of e I

channel functional test in that: (1) for the gross radioactivity monitors for the Clean Liquid Radwaste Effluent Line, the Aerated Liquid Radwaste Effluent Line, and the Condensate Polishing Facility Waste Neutralizing Sump, the monitors'setpoints

. were lowered below background radiation levels rather than raising a simulated signal to the monitors'setpoint values that were determined in accordance with methods and parameters established in accordance with the ODCM; and (2) for the l

Millstone 1 Main Stack Noble Gas Activity Monitor, a simulated signal, which l

consists of changing the Rad Conversion Factor to increase the count rate signal above the established setpoint, is inserted into the digital portion of the circuit rather than "as close to the primary sensor as practicable." As a result, the operability of the liquid and gaseous digital radiation monitors was not fully tested because the ability of the amplifiers and/or analog-to-digital conversion circuitry to L

process the count rate signal at the higher pulse frequency was not verified.

. This is a Severity Level IV Violation (Supplement 1) for Docket No. 50-336.

F.

Unit 2 Technical Specification 6.8.1.a requires that written procedures be L

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 3.e., " Procedures for Startup, Operation, and E

Shutdown of Safety-Related PWR Systems," recommends that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of l

l operation should be prepared, as appropriate, for the component cooling water

. system.

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' Procedure OP2330A, "RBCCW System," Rev.17, step 5.14.2 required a review of l.:

automated work orders (AWOs) on the global clearance for draining the Facility 1 RBCCW header. Procedure OP2330A, step 5.14.3 required the development of necessary individual clearances for AWOs prior to filling and venting the Facility 1 RBCCW header.

1 Contrary to the above, procedure OP2330A, step 5.14.3 was not adequately implemented in that, during filling and venting of the Facility 1 RBCCW header on September 2,1997, a necessary individual clearance was not developed for an open AWO (M2-97-0207)that governed replacement of the solenoid controlled

- actuator for valve 2-RB-4.1 E, which was originally assigned to the global clearance l'

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for draining the Facility 1 RBCCW header. An individual clearance was necessary because the retest for AWO M2-97-0207 had not been performed to establish operability of the actuator for valve 2-RB-4.1E, and this valve was performing the safety function of separating the operating Facility 2 RBCCW header from the non-operational Facility 1 RBCCW header.

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

G.

10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," requires in part, that measures be established to assure that conditions adverse to quality, such as defective material and equipment, and nonconformances, are promptly identified I

and corrected.

'10 CFR 50 Appendix B, Criterion Vil, " Control of Purchased Material, Equipment, and Services," requires in part, documentary evidence that shows purchased material or equipment met specific requirements, such as codes, standards or specifications.

Licensee Specification SP-ST-ME-944," Standard Specification; Material, Equipment, and Parts Lists for in-Service Nuclear Generation Facilities (MEPL Program),"

Revision 4, dated May 21,1997, states, in part, that a nonconformance report I

(NCR) is required for certain MEPL classification upgrades and that the past maintenance work history and purchase history are to be evaluated by the NCR.

NRC Information Notice 88-95, " inadequate Procurement Requirements imposed by Licensees on Vendors," dated December 8,1988, discusses the handling of functionally important parts in ASME Code components as safety related; and indicates that compliance with the ASME Code is not always sufficient to ensure compliance with 10 CFR 50, Appendix B.

Contrary to the above, as of February 9,1998, NCR 397-010 had been approved for the MEPL upgrade of parts in 2431 safety-related components, without the performance of specific part or component maintenance work history and purchase history reviews and evaluation. Furthermore, this NCR did not adequately consider the functionalimportance of certain parts installed in ASME Code components and thus failed to identify that nonsafety-related parts had been procured and installed in 29 of these ASME components.

This is a Severity Level IV violation (Supplement 1) for Docket No. 50-423.

Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company 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 j

Director, Special Projects, Nuclear Reactor Regulation, 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 reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the

5 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 docket 6d 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 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, 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 must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withho! ding (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 safegisards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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l Dated'at King of Prussia, PA

this 19th day of June,1998 e__---_:-_--_.