IR 05000220/1987021
| ML17055D689 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/14/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mangan C NIAGARA MOHAWK POWER CORP. |
| Shared Package | |
| ML17055D690 | List: |
| References | |
| EA-87-224, NUDOCS 8803220152 | |
| Download: ML17055D689 (12) | |
Text
gc Cg~gATED DISHDBUTlON DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
CCESSION NBR:8803220152 DOC-DATE: 88/03/14 NOTARIZED:
NO FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe AUTH.NAME AUTHOR AFFILIATION RUSSELL,W.T.
Region 1, Ofc of the Director RECIP.NAME RECXPIENT AFFILIATION MANGAN,C.V.
Niagara Mohawk Power Corp.
DOCKET 05000220 SUBJECT:
Discusses notice of DISTRIBUTION CODE:
TITLE: Enforcement NOTES:
Insp Rept 50-220/87-21 on 871005-30
& forwards violation
& proposed imposition of civil penalty.
IE14D COPIES RECEIVED: LTR
~
ENCL
~
SIZE:
Action Non-2.790-Licensee Response RECXPIENT ID CODE/NAME PD1-1 LA BENEDICT,R INTERNAL: AEOD/DOA DEDRO NRR/DREP/EPB10D OF~ZZ
REG
GN2/DRSS/EPRPB TERNAL: LPDR NSIC COPIES LTTR-ENCL
1
1
1
1
1
1
1
1
1
1 RECIPIENT ID CODE/NAME PD1-1 PD HAUGHEY,M AEOD/DSP/TPAB NRR/DOEA/EAB11E NRR/PMAS/ILRB12 OE LIEBERMAN,J RGN1 FILE
NRC PDR COPIES LTTR ENCL
1
1
1
1
1
1
1
1 D
S TOTAL NUMBER OF COPIES REQUIRED:
LTTR
ENCL
m S,
March 14, 1988 Oocket No. 50-220 License No.
OPR-63 EA 87-224 Niagara Mohawk Power Corporation ATTN:
Mr.
C.
V. Mangan Senior Vice President 301 Plainfield Road Syracuse, New York 13212 Gentlemen:
Subject:
NOTICE OF VIOLATION ANO PROPOSED IMPOSITION OF CIVIL PENALTY (NRC Inspection Report Nos.
50-220/87-21 and 50-410/87-39)
This refers to the NRC inspection conducted between October 5-30, 1987, at Nine Mile Point, Unit 1, Scriba, New York Which included a review of the inservice inspection program of Unit 1.
Ouring the inspection, violations of NRC requirements were identified.
The inspection report was sent to you on November 10, 1987.
On January 7,
1988, an enforcement conference was conducted with you and members of your staff to discuss the violations, their causes and your corrective actions.
The violations, which are described in the enclosed'Notice of Violation and Proposed Imposition of Civil penalty (Notice), involve (1) operation of the Unit 1 reactor between June 1986 and September 1987 without dispositioning certain weld flaw indications identified during the ten year Inservice Inspection (ISI) examinations conducted during the 1986 refueling outage which ended in June 1986, (2) failure to take appropriate corrective actions when subsequent opportunities existed during that time to identify and correct the ISI deficiency, and (3) failure. by'the corporate engineering and corporate licensing staff to immediately notify appropriate operations department supervision and pursue resolution when these nonconformances were identified in August and September of 1987.
The NRC recognizes that your review of these deficiencies in September 1987 indicated that these flaws would not have affected the ability of these systems to perform their intended safety function,
. Nonetheless, the NRC is concerned that (1) your administrative system was not adequate to ensure that the proper personnel were notified of the ISI deficiencies and to ensure that the defic-iencies were properly dispositioned prior to startup in June 1986, and (2)
multiple opportunities existed between June 1986 and September 1987 to identify and correct these deficiencies, yet the deficiencies went uncorrected.
For example,
'during discussions in November 1986 between NRC personnel and the Unit 1 Superintendent concerning the improper dispositioning of an ISI deficiency involving certain heat exchangers, the NRC raised questions as to whether similar problems existed elsewher Further, during the exit meeting by your guality Assurance Oepartment in July 1987 and in occurrence reports 8803220152 880314 PDR ADOCK 05000220
DCD OFFIC:AL RECORO COPY C
P G
niir aiyaig g>ti g inr ii~
nnni
~ r P
I 4Q I ~illl>Illus g Aa II vvv
~
03/11/88
'li
Niagara Mohawk Power Corporation issued by that department in September 1987, these issues were identified to plant management personnel.
However, effective action was not promptly taken to have these underlying problems corrected.
Further, on January 15, 1988, a member of your staff informed the NRC that other ISI deficiencies were identified on January 9,
1988, in that several ten-year ISI inspections, which had been scheduled to be performed during the 1986 refueling outage, were either missed or inappropriately deferred.
Although these recent findings are not described in the enclosed Notice, they represent another example of a lack of adequate management attention to, and control of, the ISI program.
This may be subject to further correspondence.
Collectively, the ISI deficiencies are an additional symptom of problems expressed by Region I in the SALP Report issued on July 27, 1987 and in a
letter, dated April 29, 1987, transmitting a Notice of Violation and a
$ 50,000 civil penalty for violations of maintenance, testing, and radiation protection program requirements at Unit 1.
In the April 29 letter, the NRC expressed concern regarding the effectiveness at the facility in ensuring that identified problems are brought to management for resolution, adequately analyzed for cause, and appropriately corrected.
Furthermore, in the July SALP, in the areas of "Assur'ance of guality" and "Maintenance",
both of which were rated as Category 3, the NRC also indicated that (1) plant management did not seek out problems from first line supervision and this'attitude did not foster identification of problems or elevation of problems to the level appropriate for corrective action; and (2) there was a lack of interdepart-mental coordination which could affect safety.
Although the NRC recognizes that corrective actions had been developed and are in the process of being implemented in response to those underlying concerns, these violations, as well as the recept ISI findings identified in January 1988, demonstrate the need for expediting completion of these improvements and monitoring their effectiveness.
Improvements needed include:
( 1) better administrative systems for ensuring that all deficiencies that could affect the operability of safety systems are appropriately resolved; (2) improved coordination and communication between various departments, and improved conduct of the Site Operations Review Committee (SORC) meetings, to 'assure adequate assessment and appropriate resolution of identified deficiencies; and (3) more aggressive actions by all personnel in your organization in identifying, assessing and correcting problems.
These improvements are needed promptly not only to ensure that the ISI program is appropriately implemented, but also to ensure that the reactor is operated safely and in accordance with the facility technical specifications.
To emphasize the importance of ensuring that significant deficiencies are promptly and completely resolved, including deficiencies in the ISI program at Unit 1, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the'enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of One Hundred Thousand Dollars ($ 100,000) for the violations described in the enclosed Notice.
In accordance with the "General Statement of Policy and'rocedure for NRC Enforcement Actions,"
CFR Part 2, Appendix C
~'FFICIAL RECORD COPY CP PKG NINE MILE/REV2 - 0001.1.0 03/10/88
Niagara Mohawk Power Corporation (1987) (Enforcement Policy), the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III violation or problem is
$50,000.
The base civil penalty amount has been increased by 100'~ because of your prior poor performance in the area of concern as demonstrated by:
( 1) the similarity of these concerns to the concerns raised in both the letter trans-mitting a previous civil penalty on April 29, 1987 (Reference:
EA 87-45)
and in
.the July 27, 1987 SALP report, and (2) ineffective prior corrective actions.
You are required to respond to this letter 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 recur rence.
Further, you should describe in detail, as discussed at the enforcement conference, your plans for improving the pace of improvements in management controls regarding identifying and correcting deficiencies.
This is especially important in view of your prior enforcement history which, since 1980, includes six civil penalties and an order and which dictates the necessity for your current corrective actions to be prompt, effective, and lasting.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspection, the NRC will determine. whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
k 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 Room.
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.
Sincerely, Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty William T. Russell Regional Administrator OFFICIAL RECORD COPY CP PKG NINE MILE/REV2 " 0002.0.0 03/10/88
Niagara Mohawk Power Corporation cc w/encl:
T.
E.
Lempges, Vice President, Nuclear Generation J.
A. Perry, Vice President, Quality Assurance T. Perkins, General Superintendent, Nuclear Generation W. Hansen, Manager Corporate Quality Assurance T.
Roman, Unit I Station Superintendent J. Aldrich, Unit I Superintendent, Operations C.
Beckham, Manager Nuclear Quality Assurance Operations W. Drews, Technical Superintendent Troy B. Conner, Jr.
Esquire John W. Keib, Esquire Director, Power Division Director of Public Service, State of New York Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York A'. Pinter, NMPC Site Licensing R. Abbott, Station Superintendent, Unit 2 R. Smith, Unit 2 Superintendent of Operations'FFICIAL RECORD COPY CP PKG NINE MILE/REV2 - 0004.0.0 03/10/88
Niagara Mohawk Power Corporation bcc w/encl:
Region I Oocket Room (with concurrences)
Management Assistant, ORMA (w/o encl)
ORP Section Chief Robert J.
Bores, ORSS SECY J. Taylor, OEORO J.
Li'eberman, OE J. Allan, RI D. Holody, RI J. Goldberg, OGC Enforcement Oirectors, RII-III Enforcement Officers, RIV-V T. Murley, NRR F. Ingram, PA J. Bradburne, CA E. Jordan, AEOO B. Hayes, OI S. Connelly, OIA P.
Robinson, OE R. Cunningham, NMSS O. Nussbaumer, OGP/SP OE File (3,copies
+ ltrhd)
EDO Rdg Fi l e apr'a, NRR RE Benedict, NRR B. Clayton, EDO RI: EO Holody RPDDP Johnson er RI: ORP Johnston ti rez 1/Zg/88
/88 EDRO Taylor I
/88 1/Pg'88 1/gb/88 s
Miraglia J/g/88 +
I/
/88
~(ill<'handler OE
, Lieberman 1/
/88 1/
/88
/88'FFICIAL RECORO COPY CP PKG NINE MILE/REV2 - 0005.0.0 03/10/88