ML20058D281

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Discusses Violations Noted in Insp Rept 50-029/90-14 & Forwards Notice of Violation
ML20058D281
Person / Time
Site: Yankee Rowe
Issue date: 10/19/1990
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Kadak A
YANKEE ATOMIC ELECTRIC CO.
Shared Package
ML20058D283 List:
References
EA-90-151, NUDOCS 9011060038
Download: ML20058D281 (5)


See also: IR 05000029/1990014

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October 19, 1990

Docket No.

50-29

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License No. DPR-3

EA 90-151

-Yankee Atomic Electric Company

ATTN: Mr. Andrew C. Kadak

President and Chief Operating Officer

[

580 Main Street

Bolton, Massachusetts 01740-1398

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Gentlem r..

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Subject

NOTICE OF VIOLATION

(NRC Inspection Report No. 50-29/90-14)

This-letter refers to the NRC safety inspection conducted on August 2-27, 1990

at the Yankee Nuclear Power Station, Rowe, Massachusetts, The inspection report

war sent to you on September 10, 1990.

The NRC inspection included-a review of

conditions identified by your staf f and reported to the NRC concerning deficien-

cies i_n the testing of.your emergency diesels generators (EDGs) to assure that

they would operate in accordance with required specifications.

Based on the

inspection two apparent violations of NRC requirements were identified. On

~ September 21, 1990, an enforcement conference was held with you and members of

your staff to discuss the apparent violations, their causes, and your corrective

-actions.

_

The- enclosed Notice of Violat'.r 1 describes a failure to adequately test the: EOGs.

In July and August 1990, following a major overhaul _ of the EDGs, including

replacement of the. fuel injectors, drive shaft and pistons, as well as resleeving

.of the_-degraded cylinders, two of the EDGs. were only tested at half of their

-required capacity (200kW) prior to returning them to service.

These tests were

'not suf ficient to demonstrate that the EDGs would perform satisf actorily when-

required. As a result of this testing deficiency, two of the EDGs were returned.

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to' service without your staff assuring that the EDGs were capable of handling-

their intended load of 400kW.

_

1This violation demonstrates the importance NRC places on proper testing of

equipment.following maintenance and/or modifications,.to ensure that the equip-

r

ment operates-as intended. The violation is classified at: Severity Level III

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in accordance with the " General Statement of Policy and' Procedure for NRC

Enforcement Actions," 10 CFR Part 2, Appendix C, (1990) (Enforcement Policy).

-Although a civil penalty is normally issued for a Severity Level III violation,.

the escalation and mitigation factors set forth in the Enforcement Policy were

considered and, on balance, the base civil penalty of S50,000 has been mitigated

in:its' entirety because: (1) although you notified the NRC in August 1990 that

EDG-3 failed a surveillance test, no adjustment of the base civil penalty on the

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identification factor is warranted because you did not identify that the post-

maintenance tests on EDG-1 and EDG-2 were deficient until informed by the NRC;

(2) your corrective actions subsequent to identification, including replacement

of the EDGs, were considered prompt and comprehensive, and, therefore, 50%

mitigation of the base civil penalty on this factor is warranted; and (3) your

past performance in operations, surveillance / maintenance and engineering has

been good, as evidenced by Category 1 ratings in these areas during the last

Systematic Assessment of Licensee performance (SALP), and therefore,100% miti-

gation'of the base civil penalty on this factor is warranted.

Since this

violation did not involve multiple examples, prior Notice, extended duration

or a programmatic maintenance reiated cause, no adjustment of the base civil

penalty on the n factors is warranted.

Also during the enforcement conference, your discovery that the EDGs would not

provide the required power under all required conditions was discussed at

length. While you were testing EDGs in accordance with your surveillance

requirements, apparently you had not initially tested their capacity under the .

design ambient conditions. Your staff indicated that although she EDGs would

not operate at 400kW under certain conditions, your analysis indicates that the

EDGs would havo handled the octual load that would have existed during a design

basis event. .Nonetheless, your failure to have EDGs that would adequately

perform under all required operating and environmental conditions and the

failure-to discover that problem through adequate analysis and testing prior to

their. installation into the plant and subsequent operation is viewed by the NRC

staff as a significant concern. This is especially significant since you had

recognized that the design loading capacity with the EDGs was marginal. The

NRC recognizes that. Yankee Atomic Electric Company.took prompt and comprehensive

corrective actions, once the surveillance test failures were identified in' -

August, 1990. These actions included (1) a decision by the Board of the

Directors on. August 13, 1990 to replace all three EDGs with new 600kW capability

. units, each possessing a nuclear rating of 450kW, and (2) a commitment to test

'the:EDGs at 450kW during-quarterly surveillances.

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.

In' addition, you should

_

. describe (1) the specific corrective actions taken or planned to improve your

preventive maintenance program, in particular, post maintenance-testing of

equipment, and (2) whether increases in ambient temperature can adversely affect

the performance of any other safety-related equipment at your facility. 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 Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federa1' Regulations, a copy of this ietter and its enclosure

will be placed in the NRC Public Document Room.

0FFICIAL RECORD COPY

CP PKG YANKEE R0WE - 0004.0.0

10/18/90

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-Yankee Atomic Electric Company

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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,

I

(r; ' al Ci!rl0 ET.

Thunas T. liiatun

[

Thomas T. Martin

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Regional Administrator

Enclosure: Notice of Violation

cc w/ enc 1:

N. St. Laurent,. Plant Superintendent

G. Papanic, Jr. ,- Senior Project Engineer - Licensing

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- R.-Hallisey, Dept. of Public Health, Commonwealth of Massachusetts

Public Document-Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center.(NSIC)

NRC Senior Resident Inspector

Commonwealth of Massachusetts, SLO Designee

State of Vermont, SLO Designee

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