IR 05000306/1996009
| ML20154H586 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island, Maine Yankee |
| Issue date: | 10/08/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Meisner M Maine Yankee |
| Shared Package | |
| ML20154H589 | List: |
| References | |
| 50-309-96-09, 50-309-96-10, 50-309-96-11, 50-309-96-16, 50-309-96-9, 50-309-97-01, 50-309-97-1, EA-96-299, EA-96-320, EA-96-397, EA-97-034, EA-97-147, EA-97-34, EA-97-375, EA-97-559, NUDOCS 9810140261 | |
| Download: ML20154H586 (11) | |
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@ Ctioq kg UNITED STATES NUCLEAR REGULATORY COMMISSION
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5 j REGloN I QL 475 ALLENDALE ROAD 4 KING oF PRUsslA, PENNSYLVANIA 194%1415 g * * * * * [g October 8, 1998 EA Nos.96-299; 96-320;96-397; 97-034;97-147 (ISA)
EA Nos.96-397; 97-375;97-559 (Investigations)
Mr. Michael J. Meisner, President Maine Yankee Atomic Power Company 329 Bath Road Brunswick, Maine 04011 SUBJECT: NOTICE OF VIOI.ATION (NRC Inspection Report Nos. 50-309/96-09;96-10;96-11;96-16;97-01) i l
NOTICE OF VIOLATION '
(NRC Office of Investigations Report Nos. 1-95-050,1-96-025 & 1-96-043) l Dear Mr. Meisner l
This refers to the results of several NRC inspections conducted between July 15,1996, and March 15,1997, and three investigations of Maine Yankee Atomic Power Company l (Maine Yankee) conducted by the NRC's Office of Investigations (01) between December I
1995 and October 1997. The inspections included an Independent Safety Assessment (ISA), as well as several inspections conducted by resident and Region I based inspectors
- to follow-up on the ISA findings. The purpose of the ISA was tn determine whether Maine Yankee was in conformity with its design .and licensing bases; to assess operational safety '
performance; and to evaluate Maine Yankee's self assessment and corrective action processes. All of the related inspection reports were sent to you previously. The ,
investigations concerned (1) the adequacy of Maine Yankee's small break loss-of-coolant l accident (SBLOCA) emergency core cooling system (ECCS) analyses, (2) the submittal to the NRC of inaccurate information pertaining to the capacity of the facility's atmospheric steam dump valve, and (3) the failure to perform station test procedures as required by facility technical specifications. The synopses of the referenced reports were previously
- sent to you.
With respect to the ISA and related inspections, the NRC has determined that numerous
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violations of NRC requirements occurred. The majority of the violations were discussed at a predecisional enforcement conference at the Maine Yankee media center in Wiscasset, Maine on March 11,1997. While the conference was held to discuss the violations, their
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causes and your corrective actions, the conference focused on the broader programmatic deficiencies underlying the violations and which contributed to the performance problems at Maine Yankee. The information you presented at the conference was considered in reaching our enforcement decision. Additional violations identified subsequent to the March 11,1997, conference (Reference: Inspection Report No. 97-01) are also included in this enforcement action, although they were not discussed during the conference.
Mr. G. Leitch, formerly of your staff, informed Mr. J. Yerokun of my staff on April 2, 1997, that Maine Yankee agreed that another enforcement conference was not needed to discuss these additional violations.
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With respect to the 01 investigations referenced above, the NRC transmitted to you on December 19,1997, a letter describing 13 apparent violations identified as a result of the ;
investigations, to which you responded in writing on April 6,1998. A closed, transcribed, i predecisional enforcement conference was held on April 23,1998, to discuss the issues
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associated with the NRC investigations. Based on the results of the investigations, the review of your April 6,1998, response, and the information you presented at the conference, the NRC has determined that additional violations of NRC requirements occurred.
ISA ISSUES The specific violations pertaining to the ISA follow-up inspections are described in a Notice i of Violation (Enclosure 1, hereinafter referred to as Notice 1). A number of the violations adversely impacted the operability of safety related equipment. These violations are generally related to four broad categories, namely, the failure to: (1) adequately test -
equipment; (2) environmentally qualify equipment; (3) perform adequate safety reviews; and (4) either identify deficiencies, or take appropriate corrective actions in a timely manner a address known deficiencies, including design related issues. Some of the violations !ed to safety equipment being inoperable or degraded for extended periods contrary w technical specifications. The Notice also contains several violations of lesser -
significaace which pertain to inadequate procedures or the failure to properly implement !
procedures.
The violations related to inadequate testing (Section I of Notice 1) involve failures to ,
adhere to Technical Specifications (TS), which were failures to assure that various safety related instrument channels, logic actuation circuits, and safety related pump discharge check valves functioned as required. For example, Mair o Yankee's testing process failed to detect a cut wire in the safety injection actuation circuit for a high pressure safety injection (HPSI) pump which would have prevented that pump from automatically starting, -
as required, during an accident. This condition had apparently existed since 1991, but was not detected until 1996 after prompting by the ISA. These violations are significant because testing requirements ensure the implementation of a " defense in depth" barrier for detecting inoperable safety related equipment and ensuring proper operation within i expected tolerances.
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The violations related to inadequate environmental qualificatbn (Section ll of Notice 1)
involve: (1) 30 instruments which were either not qualified or could not be qualified for L submergence during containment flooding following a loss of coolant accident (LOCA); and i (2) the component cooling water pumps which were not qualified for a harsh environment in the turbine building. The failure to environmentally qualify the instruments in containment had potentially significant safety consequences. Operators rely on these instruments to monitor safety parameters such as steam generator water level during post-accident conditions. Failure of the instruments could hamper operator actions to mitigate the accident. For example, all four narrow range channels and one wide range channel for
- levelindication for each of the three steam generators could have been unavailable due to
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submergence when the containment was flooded post-LOCA. These violations are also
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significant because the submergence issue was identified previously, yet was not effectively corrected. Seven components that wero below the submergence level in the j r
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M. Meisner 3 containment were identified in your Environmental Qualification (EQ) sut mittal dated October 31,1980, and the NRC safety evaluation report (SER) dated June 1,1981.
However, corrective actions were not taken for several of these components in that they were still below the submergence level in 1996 and not environmentally qualified for such submergence.
The violations in Section lli of Notice 1 pertain to your failure to perform ade uate design basis safety review activities. Specifically, you failed to determine that a change to emergency power supplies for safeguards equipment, which provided for cross connecting of redundant 125Vdc vital buses, constituted an unreviewed safety question and required Commission review and approval prior to implementation. Section 111 also contains multiple examples of changes to the facility as described in the FSAR without performing safety evaluations required by 10 CFR 50.59, as well as a violation of 10 CFR 50.71(e) for failure to update the facility FSAR to reflect 27 changes to the facility implemented between 1980 and 1996. These violations are significant because they are indicative of Maine '
Yankee's failure to maintain strict control of the design basis of the facility.
The violations in Section IV of Notice 1 involve conditions adverse to quality that were either not identified or for which corrective actions were not taken in a timely manner commensurate with the safety significance of the condition. Most notably, although testing identified that one train of control room ventilation could not maintain a positive pressure in the control room, the condition was not corrected due to inadequate evaluation of the test results. Also, even though a design deficiency that could have rendered the containment spray building ventilation system inoperable was identified in 1991, the degraded condition was allowed to exist for 5 years due to failure to recognize the significance of the deficiency and weaknesses in Maine Yankae's corrective action programs. These violations are significant both because of their programmatic nature and the fact that Maine Yankee's inaction resulted in safety-related equipment being degraded or inoperable for extended periods.
In your letter dated February 28,1997,in a response to NRC Inspection Report No.
50-309/96-16,and at the March 11,1997, predecisional enforcement conference, you admitted all the violations that were the subject of that conference.
Each Section, I through IV, of Notice 1 constitutes a separate Severity Level ill problem due to the saf ty significance and significant regulatory concern involved in each of the four broad categories of violations.Section V of the Notice includes multiple Severity Level IV violations pertaining to procedure or procedural implementation deficiencies.
ECCS ANALYSIS ISSUES Based on the information developed during the 01 investigations and provided in your written response and at the April 1998 conference,6 violations associated with your small
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M. Meisner 4 break-loss-of-coolant (SBLOCA) analyses (RELAP5YA)' are cited in Sections I and ll of the second Notice of Violation (Enclosure 2, hereinafter referred to as Notice 2).
The two most significant violations involve your use of unacceptable evaluation models (EM) to determine emergency core cooling system (ECCS) performance for Cycle 14 and
15 operations, contrary to 10 CFR 50.46(a). The NRC interprets 10 CFR 50.46(a)(1)(l) to i
require that in order to be acceptable, ems must be capable of analyzing the entire spectrum of break sizes that may result in a loss of coolant accident. Maine Yankee's ems for operating Cycles 14 and 15 were inadequate because the Large-Break Loss-of-Coolant Accident (LBLOCA) and Small-Break Loss-of-Coolant Accident (SBLOCA) ems were not, singly or combined, capable of analyzing or reliably analyzing the entire break spectrum, ,
specifically, the region between 0.35ft and at least 0.6ft2, j l
Maine Yankee relied on engineering judgement to conclude that the ECCS analyses had
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identified and bounded the most severe postulated loss-of-coolant accidents. This *
judgment was not well-founded. Maine Yankee's LBLOCA EM had been run down to 0 6 .
fta, only after Cycle 14 had ended and after issuance of the January 1996 Order,2 and was never demonstrated, by comparison te applicable experimental data, to reliably calculate ECCS performance in the small-break region, in addition, the technical report of Maine Yankae's contractor, acknowledges that, although the SBLOCA code, RELAP5YA,2 was authorized to analyze break sizes up to 0.7 ft 2, it could only run the RELAP5YA EM up to 0.35 ft .2 Nonetheless, Maine Yankee reasoned that despite termination of the RELAP5YA
- EM at 0.35 ft 2, the limiting small break had been identified at 0.15 ft . Maine Yankee l based this conclusion on a continual decrease in peak fuel cladding temperature after the
! O.15 ft 2break size, despite the fact that the previous SBLOCA EM, used for approximately l 20 years in licensing basis SBLOCA analyses, had calculated the limiting SBLOCA break size at about 0.5 ft 2. In addition, increasing instability and oscillations occurred in the RELAPSYA SBLOCA EM as it approached 0.35fta, where the model terminated following safety injection tank actuation. Therefore, it was unreasonable to assume that in analyzing the small-break spectrum up to only 0.35 ft ,a the most severe postulated SBLOCA, or limiting break, had been identified. Finally, Duke Engineering & Services (DE&S),' after reviewing development of the RELAP5YA SBLOCA EM by Yankee Atomic Electric Company (YAEC), acknowledged that it was unable to draw a definitive conclusion
'RELAP5YA was the NRC-approved code for performing SBLOCA analyses at Maine Yankee
On January 3,1996 the NRC issued a Confirmatory Order Suspending Authority for and Limiting Power Operation and Containment pressure (Effective immediately).
' RELAP5YA was the NRC-approved code for performing SBLOCA analyses at Maine Yankee --
l * DE&S purchased that portion of Yankee Atomic Electric Company (YAEC) that
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actually performed the SBLOCA analysis for Maine Yankee. DE&S and YAEC were served with a Demand for Information concurrent with the transmittal of the 01 investigation
- results to Maine Yankee on December 19,1997.
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! M. Meisner 5 regarding the RELAP5YA peak cladding temperatures (PCTs) for the unanalyzed portion of the Maine Yankee SBLOCA spectrum. DE&S also acknowledged at the predecisional enforcement conference, that during the initial application of a new ECCS code, it is standard practice to perform an initial run from the top to the bottom of the break spectrum at regular intervals, rather than to perform a truncated run as was done in this Case.
The NRC considers these violations, involving the failure to demonstrate by calculations using acceptable ems the cooling performance of ECCS over a full spectrum of postulated LOCA break sizes, to be very significant. In fact, when this issue was first identified, the NRC issued an Order on January 3,1996 modifying the facility operating license to derate the plant to the original licensed thermal power limit to regain the necessary assurance that ECCS performance was acceptable for continued operation. It was only after subsequent substantial additional review, that Maine Yankee demonstrated that there was no actual safety consequence of the failure to analyze the entire SBLOCA spectrum because the -
LBLOCA accident analyses contained the limiting condition, and therefore determined the facility operating limits.
The significance of these violations stems from the fact that for Cycle 14 operations, l Maine Yankee operated the facility without having demonstrated that its ECCS systems were capable of mitigating the most severe postulated loss-of-coolant accident. While evidence indicates that individuals at Maine Yankee and Yankee Atomic Electric Company (YAEC) believed in good faith that they had identified the most limiting break size in the small-break spectrum, it was inappropriate to rely on unfounded engineering judgement to reach this conclusion. This judgment was not sufficient to demonstrate compliance with the 50.46 requirement that the ECCS cooling performance must be demonstrated by calculations over the entire break spectrum using acceptable ems, especially when instabilities and oscillation of the peak cladding temperature and other parameters resulted in termination of the RELAPSYA SBLOCA computer run, and since the previous SBLOCA analyses of record identified the most limiting break in the region of the small-break spectrum that the new RELAP5YA SBLOCA EM could not calculate.
For these reasons, the two violations in Section I of Notice 2 have collectively been classified as a Severity Level 11 problem. Severity Level 11 violations or problems are defined in NUREG-1600," General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy) as being of very significant regulatory concern.
It should be noted that the issues which constituted the Severity Level 11 problem cited in Section I of Notice 2 were considered by the Office of Investigations (01) as willful acts on the part of Maine Yankee and YAEC. The staff, however, after thorough review of all the evidence concluded these violations were the result of poor judgment being exercised in both performing and reviewing analyses rather than on willful acts on the part of Maine Yankee personnel. As previously discussed, the RELAPSYA evaluation model was authorized to analyze break sizes from 0 to 0.7ft2, but the model was only able to calculate results up to 0.35ft which
YAEC and Maine Yankee concluded covered the most limiting break size. The licensee used engineering judgment without sufficient basis for concluding that the most limiting break size had been identified. While the licensee's judgment was l
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M. Meisner 6 seriously flawed, and its actions constituted violations of 10 CFR 50.46, the NRC accepts Maine Yankee's explanations that it believed in good faith that it had sufficient justification to conclude that the limiting break for the SBLOCA region had been properly identified. l Furthermore, it is clear from technical report, YAEC-1868, " Maine Yankee Small Break LOCA !
Analysis," which was incorporated by reference into the Core Performance Analysis Report, that ;
Maine Yankee did not try to conceal the fact that it was unable to analyze the entire small-break -
spectrum. For these reasons, the staff concludes that the violations were not the result of willfulness on the part of Maine Yankee. As to YAEC, a Demand for Information was issued on December 19,1997, requesting that YAEC and its successor, Duke Engineering &
Services (DE&S), address why its deficient actions associated with the SBLOCA analysis should not be considered the result of willfulness, either deliberateness or careless disregard. The NRC has reviewed the responses of YAEC, DE&S and several individuals and is addressing the results of that review in separate correspondence issued concurrently with this action.
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SANCTIONS l
The violations described in both of the enclosed Notices of Violation appear to relate to the I same fundamental underlying concerns with Maine Yankee's conduct of licensed activities.
Many of these violations and underlying causes were longstanding and appeared to be caused by ineffective engineering analyses, review and processes which led to inadequate design and configuration control; a corrective action program which was fragmented; a quality assurance function which was not effective at both an individual and organizational level; and ineffective oversight as well as inadequate knowledge of vendor activities. The NRC's assessments, along with your own assessment as described at the March 1997 conference, found that Maine Yankee was a facility in which pressure to be a low-cost performer led to practices which overrelied on judgment, discouraged problem reporting, and accepted low standards of performance, as well as informality rather tnan rigorous adherence to program and procedural requirements. Lastly, Maine Yankee had become insular, failing to keep up with industry practice and failing to communicate adequately with the NRC.
The Commission considered a substantial civil penalty for the broad programmatic deficiencies described herein, and because Maine Yankee is still performing regulated activities important to safety. However, a civil penalty is not being proposed given the specifics of this case. Among the issues considered were: (1) Maine Yankee essentially replaced the entire management infrastructure since the time these problems occurred, and the new management has been effective in safely managing shutdown and decommissioning operations; (2) the fact that the Maine Yankee facility has been shutdown since December 5,1996, was permanently retired on August 6,1997, and the violations at issue here are not reflective of Maine Yankee's post shutdown and decommissioning performance; and, (3) unlike Haddam Neck in which a substantial civil penalty was imposed after declaring permanent retirement of the facility, Maine Yankee is not in the business of operating other nuclear power facilities. Accordingly, the NRC considers that civil penalties are not necessary in this case to provide the emphasis for a high standard of compliance in the future.
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M. Meisner 7 DISPOSITION OF REMAINING ECCS ANALYSIS ISSUES Violation ll.A of Notice 2, involving the failure to use the SBLOCA code specified in technical specifications to determine core operating limits and the subsequent provision of inaccurate information to the NRC in the Core Operating Limits Report (COLR), was characterized as the result of apparent careless disregard in our letter of December 19, 1997. After extensive staff review of the evidence, your April 6,1998 response to our letter of December 19,1997, and your presentation at the predecisional enforcement conference on April 23,1998, the NRC has determined that the violation did not result from careless disregard. It is clear that Maine Yankee did not use the SBLOCA code specified by its Technical Specifications to determine Core Operating Limits (limits) for Cycle 13, and subsequently submitted inaccurate information to the NRC in its COLR that the limits had been develope ( Sy using the codes specified by the Technical Specifications.
The NRC, however, accepts Maine Yankee's explanation that it believed in good faith that the LBLOCA was the most limiting accident scenario and that it had used the LBLOCA '
analysis only to determine Core Operating Limits. Furthermore, it is clear that Maine Yankee did not try to conceal the fact that it had not used the SBLOCA code specified in the Technical Specifications because the Core Performance Analysis Report, which was submitted to the NRC, clearly revealed that Maine Yankee had used the CE SBLOCA5 code, rather than the RELAP5YA SBLOCA code that was specified in the Technical Specifications at the time. The NRC, therefore, does not conclude that there was willfulness, and absent willfulness, the NRC categorizes the Cycle 13 violation at Severity Level IV.
The NRC concludes that three additional violations associated with Maine Yankee's SBLOCA analyses occurred and have been classified at Severity LevelIV. These violations involve: (1) & (2) use of unjustified ECCS penetration factors and cross flow resistance factors in the SBLOCA EM for cycle 14 and 15 operations; and (3) the use of an unacceptable ECCS EM for the 1993 analysis of a decrease in steam generator pressure.
The unjustified ECCS penetration factors and cross flow resistance factors resulted from a calculational error in the application of the Alb-Chambre correlation. YAEC exercised unfounded judgment in selecting the penetration and resistance factors. Therefore, the resultant EM was unacceptable. The EM used to evaluate the effect of reduced steam generator pressure was a best estimate model, not an Appendix K model as approved by the staff. Furthermore, the methods used to determine fission product decay heat and two-phase discharge flow were different from those required by 10 CFR Part 50, Appendix K. For these reasons, the EM used for the reduced steam generator pressure analysis was unacceptable. These violations are cited in Sections ll.B -II.D of Notice 2.
The remaining three apparent violations associated with ECCS analyses, described in our December 19,1997, letter, will no'. ;e cited. The NRC concluded that the use of the CE SBLOCA code in determining core operating limits for Cycle 12 operations and the statement to the NRC in the Core Operating Limits Report that the analyses specified by the Technical Specifications were used, did not constitute a violation of NRC requirements
The CE SBLOCA code had been the approved method for demonstrating compliance with 10 CFR 50.46 at Maine Yankee prior to staff approval of the RELAP5YA code.
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M. Meisner 8 l because the Technical Specification amendment requiring the use of the RELAPSYA l SBLOCA code became effective beginning with Cycle 13 operations. The apparent j
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violations associated with the failure to develop and maintain a complete and uccurate 1 Core Performance Analysis Report (CPAR) for Cycles 14 and 15 were not sustained ;
because, upon further review, the NRC concluded that only an abstract of a document l referenced by the CPAH was misieading and the document, when read in its entirety, I l clearly demonstrates there was no intent to mislead. I ATMOSPHERIC STEAM DUMP VALy1 At the enforcement conference, Maine Yankee acknowledged it was responsible for the l acts of its employees. However, M Ma Yankee contended that the submission of known I inaccurate information by a working level employee did not constitute a willful violation on the part of Maine Yankee. Nonetheless, the NRC contends the 1986 submission of materially lnaccurate information relative to the capacity of the facility's atmospheric steam '
dump valve was willful. However, the NRC has decided, given the circumstances of this case, including the age of the violation, to exercise discretion pursuant to section Vll.B.6 of 1 the Enforcement Policy and not cite the violation described in our letter of December 19, i 1997. l l
SAFETY SYSTEM LOGIC TESTING Based on the findings of the Ol' investigation and the information provided in your response and at the April 1998 conference, one violation is being cited associated with safety I
system logic testing as set forth in Section lli of Notice 2. Two engineers violated station test procedures (a Technical Specification violation) and caused a violation of 10 CFR 50.9,
" Completeness and accuracy of information." Work orders specified that specific contacts be verified as open with a voit-ohm meter. The field engineers performing the tests, however, obtained a quantifiable electrical resistance value when they used the volt-ohm meter, indicating a problem. Because of a resistor in the circuit, it was not possible to verify an open contact with the volt-ohm meter. The engineers visually verified the open contacts without first stopping the test and following the process required by the Technical Specifications for implementing a minor technical change (MTC) to the procedure. The engineers then signed the work order as completed according to test procedures. 01 concluded that the violations were deliberate. The staff concludes, however, based on all the evidence, that the engineers believed in good faith that they were not required to implement a MTC. The engineers had executed several other MTCs as they encountered l
other difficulties with the same work order. Also, the two engineers had the authority to ,
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approve the MTCs themselves and the engineers did not believe that an MTC was required i in this particular instance. Thus,it does not appear that the engineers attempted to j circumvent the MTC process. Therefore, the staff concludes that it is not unreasonable for 4
! the engineers to have believed that they had the authority to document the execution of I the steps in the manner they did and consequently, the act was not a deliberate or willful !
violation of station procedures. Absent willfulness, this violation is categorized at Severity i Level IV.
You are required to respond to this letter and should follow the instructions prescribed in the enclosed Notices when preparing your response. The NRC will consider your response, l
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in part to determine whether further enforcement is necessary to ensure compliance with
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regulatory requirements.
In'accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room.
Sincerely, I
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Hubert J. Miller Regional Administrator Docket No. 50I309 '
License No. DPR-36 ;
Enclosures:
(1) Notice of Violation (Notice 1) (EA Nos.96-299,96-320,97-034,97-147)
(2) Notice of Violation (Notice 2)(EA 96-397,97-375,97-559)
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cc w/ encl:
R. Fraser, Director - Engineering i J. M. Block, Attorney at Law P. L.~ Anderson, Project Manager (Yankee Atomic Electric Company)
L. Diehl, Manager of Public and Governmental Affairs T. Dignan, Attorney (Ropes and Gray)
' G. Zinke,' Director, Regulatory Affairs W. Odell, Director, Operations j M. Ferri, Director, Decommissioning '
M. Lynch, Esquire, MYAPC P. Dostie, State Nuclear Safety inspector
! P. Brann, Assistant Attorney General U. Vanags, State Nuclear Safety Advisor C. Brinkman, Combustion Engineering, Inc.
W. D. Meinert, Nuclear Engineer First Selectmen of Wiscasset M. Kilkelly, State Senator, Chair - Community Advisory Panel
, -Maine State Planning Officer - Nuclear Safety Advisor State of Maine, SLO Designee State Planning Officer - Executive Department Friends of the Coast i
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DISTRIBUTION:
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AThadani, DEDO JLieberman, OE t HMiller, RI FDavis, OGC SCollins, NRR -
BBoger, NRR Enforcement Coordinators Rl, Ril, Rlll, RIV BBeecher, GPA/PA GCaputo, 01 ,
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DBangart, OSP HBell, OlG TMartin, AEOD OE:EA (2 copies) (Also by E-Mail)
NUDOCS DScrenci, PAO-RI NSheehan, PAO-RI Nuclear Safety Information Center (NSIC) 4 Resident inspector - Maine Yankee LTremper, OC DDorman, NRR MWebb, NRR .
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DOCUMENT NAME: G:\MYRELAP.NOV l l . To receive a copy nf this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy l l with attachment / enclosure "N" = No copy l
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! OFFICE RI j l D:OE l l l l NAME @illefr / JLieberman DATE W1/98 09/ /98
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DlBTRIBUTION:
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'SE CA LCa an, EDO ATh ani, DEDO JLie rman,OE HMill r, RI .
FDs , OGC SColli ,NRR BBogo NRR-
- Enfore ont Coordinators RI, Ril Rlli, RIV BBeech r,GPA/PA GCaputc', 01 DBangar OSP ,
HBell, 01 TMartin, EOD ' *
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OE:EA'(2 oples) (Also by E-Mail)
NUDOCS DScrenci, 0-Rl NSheehan, AO-Ri Nuclear Saf information Center (NSIC)
Resident in ctor - Maine Yankee LTremper, O DDorman, N MWebb, NRR .
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DOCUMENT NAME: G:WRELAP.NOV Ta rooolve a copy of this document, indicate in the box: "C" = copy without attachment / enclosure "E" = Copy 2 anachmenpenclosure "N" = Noody, OFFICE RI j l D:9lI \ l l l NAME M ; Ji ^.L .7,rien DATE Wi/98 g /95
\ lb1[ 5 i OFFICIAL RECORD COPY TOT A P.02 TOTA P.01