ML20024H564
| ML20024H564 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/30/1991 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kadak A YANKEE ATOMIC ELECTRIC CO. |
| Shared Package | |
| ML20024H565 | List: |
| References | |
| EA-91-042, EA-91-42, NUDOCS 9106050036 | |
| Download: ML20024H564 (5) | |
Text
..
e May 30, 1991 Docket No.
50-29 License No. DPR-3 EA 91-042 Yankee Atomic Electric Company ATTN: Mr. Andrew C. Kadak President and Chief Executive Officer SSO Main Street Bolton, Massachusetts 01740-1398 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - 550,000 (NRC INSPECTION REPORT NO. 50-29/91-03)
This letter refers to the NRC inspection conducted between february 20, 1991 and March 25, 1991 at the Yankee Nuclear Power Station, Rowe, Massachusetts.
The inspection report was sent to you on April 10, 1991.
The inspection was conducted to review the circumstances associated with an event involving a failure of one of the three Emergency Diesel Generators (EDGs) to start during a routine technical specification surveillance test in January 1991, as well as your follow-up review of the event and its root causes, which resulted in the identification of 92 nonconforming conditions involving improper electrical cornectors associated with the EDGs, as well as additional noncnnforming conditions associated with other systems.
During this inspection, violations of NRC requirements were identified. On April 29, 1991, the NRC conducted an enforcement conference with Mr. J. Thayer and other members of your staff to discuss the violations, tiieir causes and your corrective actions.
The failure of EDG-1 to start in January 1991, was caused by a faulty electrical connection in the governor oil solenoid operated dump valve (50V) circuit.
The faulty connection, which was made by an electrical contractor when the three new EDGs were installed during the 1990 refueling outage, was attributed to the incorrect installation of electrical crimps.
The NRC is concerned that the contractor electricians performing the work on the EDGs were not adequately trained or qualified.
Such training and qualification were particularly important since the electrical contractor was not on your list of Approved /
Authorized Vendors and, as you stated during the enforcement conference, the electricians were supposed to be working under your Quality Assurance (QA)
Program.
The NRC is also concerned that appropriate Quality Control (QC) coverage of the contractor was not provided.
Since the vendor services for the EDG replacement I
and testing were procured as "Non Nuclear Safety" (NNS), the licensee was l
required to perform a quality assessment through source verification, special 0FFICIAL RECORD COPY EA 91-042 5/24 - 0001.0.0 05/24/91 9106050036 910530
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tests, inspection and verification of still and training of contract personnel, which it failed to do.
In addition, although the licensee inplemented avality I
control inspections during the replacerent of the ED3s, using a procedure which required mandatory QC inspections, the site quality organization misinterpreted the instruction to be applicable only to repairs performed on critical equipment and not to modification or replacement of critical components.
As a result, the replacement of the [D3s was only subject to random surveillance and not mandatory inspections.
Reviewers, especially the QA organization, should have recognized the insufficient scope and depth of the inspections of electrical Connections.
The violations associated with this cccurrence are described in the enclosed Notice and involved: (1) the f ailure to ensure adequate training of contractor craft nersonnel necessary to install quality electrical splice connections during the EDG replacement in the 1990 refueling outage; and (2) the failure to establish and implement an effective quality centrol inspection program necessary to ensure quality installation of the replacement EDGs.
The NRC considers these violations significant because the deficient electrical connections had the potential to be a common mode failure since the work was performed by the same contractor on each EDG.
The NRC recognizes that you subsequently performed visual inspections of all the splice / terminations installed by the electrical contractor, including splices in other systems (Nuclear Instrumentation (NI), the Safety Parameter Display (5PDS), and other instrumentation). Nonetheless, there was a significant lack of oversight of activities performed by the electrical contractor during the 1990 refueling outage that resulted in the use of a large number of nonconforming connectors that needed to be repaired or replaced and which affected the operability of a safety system.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C (1990), the violations are classified in the aggregate as a Severity Level 111 problem.
The NRC recognizes that subsequent to the event (1) actions were initiated to identify the root causes of the event, including expansion of the review after programmatic and potential generic concerns were identified; and (2) appropriate corrective actions were initiated.
The corrective actions, which were described at the enforcement conference, included development of training for plant and contractor personnel in the proper use of calibrated crimpers; revision of plant procedures to include specific instructions for making crimp connections; revision of the nonconformance process to provide more timely dissemination of information; and a review of work and QC oversight of the work performed by other contractor individuals operating under the Yankee Quality Assurance Program.
Notwithstanding those actions, to emphasize the importance of (1) proper control of contractor activities associated with safety related equipment, incluuing the training and qualifications of contractor personnel, and (2) proper implementation of a quality control inspection program that provides the OFFICIAL RECORD COPY EA 91-042 5/24 - 0002.0.0 05/24/91
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necessary oversight to ensure quality of materials and services, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level 111 problem set forth in the enclosed Notice.
The base civil penalty for a Severity Level !!! problem is $50,000.
The escalation and mitigation factors set forth in the enforcement policy were i
considered. The base civil penalty was neither escalated nor mitigated for the identification and reporting factor due to the self-disclosing nature of the j
event that led to the discovery of the nonconforming connections. Additionally, the issue of reportability was first raised by the NRC inspectors and an LER detailing the full scope of the problem wM not issued until March 28, 1991.
No mitigation is warranted for your corrective actions. Though the actions were ultimately good, you were slow in the development and implementation of the follow-up inspection program, and your subsequent review of other connections did not include power cable inspections until the NRC inspector raised the issue.
(Additional r.onconformances were revealed in this area.) _ Mitigation for your past performance is not warranted because (1) SALP ratings in the Operations, Maintenance / Surveillance, and Engineering and Technical Support areas have indicated a recent' decline, as evidenced by Category 2 ratings in these areas during the recent SALP assessments compared to prior SALP assessments of Category 1 in those areas; and (2) a Severity Level 111 violation with no civil penalty was issued on October 19,1990 (Reference EA 90-151) for inadequate testing of and quality in your EDGs. The potential civil penalty for EA 90-151 was mitigated, in part, based on the expectation that you were replacing the 3
EDGs with EDGs that would be of the necessary quality, including installation, i
No adjustment to the civil penalty based on the other escalation and mitigation factors is warranted.
You are required to respond to this letter and should follow the instructions i
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.
Your response should address what actions are being taken to address control of all contractors performing safety-related activities as well as action being taken to assure more timely and thorough evaluation and reporting. 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 requirements.
. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.
OFFICIAL RECORD COPY EA 91-042 5/24 - 0003.0.0 05/24/91 i
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The responses directed by this letter and the enclosure 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, Ori;;inal Cirn d By:
Thems T. Iliatin inomas 1. Martin Regional Administrator
Enclosure:
Notice of Violation and Proposed imposition of Civil Penalty cc:
J. Thayer, Vice President & Manager of Operations N. St. Laurent, Plant Supervisor G. Papanic, Jr., Senior Project Engineer - Licensing R. Hallisey, Dept. of Public Health, Commonwealth of Massachusetts Public Document Room (POR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector Commonwealth of Massachusetts State of Vermont, SLO Designee
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DISTRIBUTIO.N:
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