IR 05000029/1988025

Discusses Safety Insp Rept 50-029/88-25 on 881227-30 & Forwards Notice of Violation.Expresses Concern That Adjustments to safety-related Instrumentation Were Made Even Though Procedures Lacked Guidance Re Gain Adjustments

ML20235J153
Person / Time
Site:	Yankee Rowe
Issue date:	02/15/1989
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kadak A YANKEE ATOMIC ELECTRIC CO.
Shared Package
ML20235J155	List: IR 05000029/1988025 ML20235J159
References
EA-89-011, EA-89-11, NUDOCS 8902240191
Download: ML20235J153 (4)

Text

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a- Docket N l ^ License No. DPR-3 L' EA 89-11 4 Yankee Atomic Electric Company-ATTH: Dr. Andrew C.:Kadek, President-and Chief-Operating Officer

 . 580 Main' Street-

Bolton,. Massachusetts ,01740-1398 _ j 3entlemen: , a NOTICE.0F VIOLATION

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 . SUBJECT:
  (NRC Inspection Report No.- 50-29/88-25)
 .This refers to:the'special-NRC safety inspection conducted on December 27-30c 1988, at the Yankee Nuclear Power Station, Rowe, Massachusetts to review the circumstances-associated with a violation of a technical specification: limiting; condition for operation (LCO) which was identified as a result 'of your operating
 - and. engineering Lstaff's review of a planned modification at the. facility. The-violation was promptly reported to the NRC. The report of the inspection was sent to you on January 19, 1989. On January 27, 1989,'an enforcement. conference
 "was conducted with you and members of your staff to discuss the violation, its causes, and your corrective actio .The violation, which is described in the enclosed Notice of Violation, involved operation of the reactor at low power for indeterminate periods of (time prior to November 1988 with certain reactor protective system power range
 - and. intermediate power range neutron flux trip values less conservative than the limiting safety system settings required by the technical specification The violation' existed during certain startups and shutdowns of the' reactor, and resulted from improper adjustments by a reactor operator to the fine gains on these' power range and intermediate power range neutron flux instrument . These adjustments were.made so as to avoid an unnecessary reactor' trip; however, the adjustments were made without recognizing that they resulted in certain. trip values being less conservative than the settings described in the technical specification The safety significance of this violation was minimized by the fact that other instruments provided backup trips which would have shutdown the reactor prior Lo'any of the required. safety settings being exceeded, although not all of
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those trips are credited in the safety analysis. Nonetheless, the NRC is concerned that these adjustments to safety related instrumentation were made even though procedures lacked guidance concerning gain adjustments during plant startup and shutdown evolutions, and these adjustments had not been covered in training programs. Furthermore, although there was no caution in the appropri-ate procedure, the operator (s) who made these adjustments did not exhibit a suf ficiently inquisitive attitude toward the making of equipment adjustments without appropriate procedural controls and in this case without adequate OFFICIAL RECORD COPY CP PKG YANKEE R0WE - 0001. , s 02/14/39 i 8902240191 890215 PDR O ADOCK 05000029 U

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! Yankee Atonic Electric Company 2 knowledge of the full effects of the adjustments. In addition, the oversight provided by shift supervision and shift technical advisors during the startup and shutdorn evolutions was not sufficient to identify these deficiencie The NRC recognizes that this violation appears tt constitute an isolated departure from an otherwise conservative ope"ating philosophy at this facility, as evidenced by Category 1 ratings in the operations area during the six prior SALP assessment period Nonetheless, these adjustments to nuclear instrumentation without appropriate procedural controls represents a signifi-cant regulatory concera, and therefere, is classified at 3everity Level III in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Apoendix C (1988) (Enforcement Policy).

Although a civil pent.lty is considered for a Severity Level III violation, I have been authorized, after consultation with the Director, Office of ( Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support, not to issue a civil penalty in this case because (1) the violation was identified by your staff' and promptly reported to the NRC; (2) your corrective actions upon identification were prompt and extensive; and (3) your prior enforcement history has been good, as evidenced by the prior Category I SALP ratings in the operations are You are required to respond to this letter and the enclosed Notice and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-511.

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Sincerely, l l l Or4" 3 Si nnd 7 By

   - - . . JSLLL William T. Russell Regional Administrator Enclosure: Notice of Violation

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    ' G. Papanic, Jr., Senior Project Engineer - 1.icensing
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    . P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts'
    . Sterzinger, Commissioner, Vermant Departmen; of Public Service Fucient Safety Information Cente:r (NSIC)

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NRC Resident Inspector t L Comm'anwealth of Massachusetts (2) State of Vermont

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