ML20134M499

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Forwards Insp Rept 50-309/96-16 on 961208-970128.No Violations Noted
ML20134M499
Person / Time
Site: Maine Yankee
Issue date: 02/11/1997
From: Cooper R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Frizzle C
Maine Yankee
Shared Package
ML20134M502 List:
References
EA-96-034, EA-96-299, EA-96-320, EA-96-34, NUDOCS 9702200271
Download: ML20134M499 (9)
v • d • e


See also: IR 05000309/1996016

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FEBRUARY 11, 1997 )

EA Nos: 96-299

96-320

97-034

Mr. Charles D. Frizzle

President

Maine Yankee Atomic Power Company

329 Bath Road

Brunswick, Maine 04011

SUBJECT: NRC INTEGRATED INSPECTION REPORT 50-309/96-16

Dear Mr. Frizzle:

This letter refers to the special inspection conducted from December 8,1996 through

January 28,1997, at the Maine Yankee facility. The purpose of this inspection was to

review the safety concerns raised by the NRC Independent Safety Assessment (ISA) team,

' to provide for the proper regulatory disposition of selected issues, and to review and verify

the actions taken by your staff in response to selected issues identified by the ISA. _ The .

team's issues were documented in their report which was transmitted to you on October 7,

1996. This inspection consisted of reviews of the ISA team's report, selected examinations

of design documentation, procedures and representative records, personnel interviews, and

review of the actions taken by your staff to address selected issues. The findings were

discussed with Messrs C. Frizzle and D. Whittier (via Telecon), and G. Leitch and others of

your staff at an exit meeting on January 28,1997.

This inspection and letter also brings into focus those issues and recent NRC inspection

activities, the majority of which are related to the ISA team review, that are appropriate at

this time to be considered for escalated enforcement. As such, based on the results of this

inspection (EA 97-034), and the inspections documented in NRC inspection reports

50-309/96-09 (considered part of EA 97-034), 50-309/96-10 (EA 96-299), and

50-309/96-11 (EA 96-320), sixteen (16) apparent violations were identified and are being

considered for escalated enforcement action in accordance with the " General Statement of l

' Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy) (60 FR 34381;

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' June 30,1995). The apparent violttions were grouped in the areas of: (1) safety related l

- equipment inoperability; (2) testing inadequacies; (3) safety review inadequacies;

(4) procedure inadequacies and non-adherences; and (5) corrective actions not identified,

untimely, and/or inadequate. The details pertaining to these apparent violations are

provided in the Executive Summary of the enclosed report. We note that the testing

inadequacies were particularly significant, in that, they contributed to the lack of timely

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9702200271 970211

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PDR ADOCK 05000309

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Mr. Charles D. Frizzle 2

identification of safety related equipment inoperabilities (i.e., the HPSI pump inoperability

due to a cut wire and the inability to maintain a positive pressure in the control room) that

resulted in apparent TS violations.

In addition, a number of items were identified as unresolved because further reviews are

needed by the NRC staff to determine their proper disposition. You should expect further

NRC review of these matters during future inspections.

Accordingly, no Notice of Violation is presently being issued for these inspection findings.

In addition, be advised that the number and the characterization of apparent violations

described in the enclosures to this latter may change as a result of further NRC review. A

predecisional enforcement conference to discuss the apparent violations is scheduled for

March 11,1997 at your media center. The conference will be open to the public.

The decision to hold a predecisional enforcement conference does not mean that the NRC

has determined that a violation has occurred or that enforcement action will be taken. The

conference is be held to obtain information to enable the NRC to make an enforcement

decision, such as, a common understanding of the facts, root causes, missed opportunities

to identify the apparent violations sooner, corrective actions, significance of the issues, and

the need for lasting and effective corrective action. Enclosure 1 to this letter is a proposed

outline for this conference that suggests a method for you to present the issues in a concise

manner and allow maximum discussion of your planned corrective actions. In particular, we

expect you to address those additional issues contained in first part of the meeting as

described in Enclosure 1.

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding these apparent violations is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and

its enclosure will be placed in the NRC Public Document Room.

Sincerely,

'A ,

Richard W. Cooper 11, irector

Division of Reactor Projects

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Mr. Charle.i D. Frizzle 3 l

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Docket No: 50-309

License No: DRP-36

Enclosure 1: Enforcement Conference Suggested Presentation

Enclosure 2: NRC Inspection Report No. 50-309/96-16

cc w/ encl:

G. Leitch, Vice President, Operations

J. M. Block, Attorney at Law

P. L. Anderson, Project Manager (Yankee Atomic Electric Company)

R. Blackmore, Plant Manager

L. Diehl, Manager of Public and Governmental Affairs

J. A. Ritsher, Attorney (Ropes and Gray)

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

Maine State Planning Officer - Nuclear Safety Advisor

State of Maine, SLO Designee

State Planning Officer - Executive Department

Friends of the Coast

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Mr. Charles D. Frizzle 4

Distribution w/ encl:

Region 1 Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC

NRC Resident inspector

D. Screnci, PAO

R. Conte, DRP

H. Eichenholz, DRP

D. Beard, DRP

J. Lieberman, OE

D. Holody, RI

Distribution w/ encl (VIA E-MAIL):

W. Dean, OEDO

S. Varga, Director,1/II, DRPE, NRR

D. Dorman, LPM, NRR l

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R. Frahm, Jr., NRR '

Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 5\MY9616.lNS

To receive a copy of this document, indicate in the bos: *C" = Copy without attachment / enclosure *E' = Copy with attachment enclosure

  • N' = No copy ,,, l

OFFICE Rl/DRS ,, Rl/DRS ,, Rl/DRP g, j Rl/DRP //ffj I

NAME HEichenholzg[ JYerokun 83.[jf'RCoptef/ W RCoop @

DATE 02&o/97 02//#/97 02//997 / O2////67

OFFICIAL RECORD COPY

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Enclosure 1 j

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ENFORCEMENT CONFERENCE SUGGESTED PRESENTATION I

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The first part of the presentation should be a brief introduction and review of each

apparent violation as identified in the individual inspection reports without going into i

detailed discussions about the multiple (if applicable), specific examples listed under each  !

apparent violation. This is the opportunity for Maine Yankee to point out any errors in

inspection reports, admit or deny the violations, state the root causes, missed opportunities

to identify the violations sooner, significance of the issues, and to provide any information

concerning your perspectives on: (1) the severity of the apparent violations, (2) the

application of the factors that the NRC considers when it determines the amount of a civil

penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy,

and (3) any other application of the Enforcement Policy to this case, including the exercise

of discretion in accordance with Section Vll. It will be particularly useful to the NRC for

you to provide your perspective on the relationship of your identified root causes for the

apparent violations to those ISA team developed root causes that were related to the  ;

team's identification of significant weaknesses and deficiencies. You may want to provide

the above information as a written handout or slides and then highlight only the significant

areas. The following order is preferred,

a. IR 50-309/96-10 (EA 96-299), Special Inspection of ISA Team's Concerns involving

Environmental Qualifications of Electrical Equipment important to Safety:

  • Apparent Violation 10 CFR 50.49, Section b.3 and Section e.6 (30 examples) I
  • Unresolved item 50-309/96-10-02, address the environmental qualification of

the primary component cooling water pump motors and the secondary ,

component cooling water pump motors

b. IR 50-309/96-11 (EA 96-320), Special Inspection of Logic Testing Deficiencies

identified Following ISA Team Concerns Regarding inadequate Safety System Logic

Testing and High Pressure Safety injection (HPSI) Pump inoperability:

  • Apparent Violation Technical Specification (TS) 3.9-2 No.1
  • Apparent Violation TS 4.1 (nine instances)
  • Apparent Violation TS 4.5 (three instances)
  • Address - the inoperability of the "A" HPSI pump over a number of years due

to inadequate surveillance testing; why the technical, quality, and safety

oversight review programs did not previously identify the inadequacies with

Maine Yankee's surveillance testing program, the adequacy of the program in

light of the number of surveillance tests not adequately covering TS

surveillance requirements, and any improvements taken or planned.

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c. IR 50-309/96-09 (EA 97-034), Integrated Resident inspection l

e- Apparent Violation 10 CFR 50, Appendix B, Criterion ill

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(two instances)

d. IR 50-309/96-16 (EA 97-034), Special Inspection for Followup of ISA Team Safety l'

Concerns-

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e Apparent Violation TS 3.25.B.2  !

e Apparent Violation TS 3.6

e Apparent Violation TS 3.12  ;

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e Apparent Violation 10 CFR 50, Appendix B, Criterion XI i

(four instances)

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e Apparent Violation TS 4.7/10 CFR 50.55a  ;

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e Apparent Violation 10 CFR 50.59(b)(1)

e Apparent Violation 10 CFR 50.71(e)(4)

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e Apparent Violation TS 5.8.2, Failure to establish procedures

(two instances) ,

e. Apparent Violation TS 5.8.2, Failure to implement procedures

(three instances) ,

o Apparent Violation 10 CFR 50, Appendix B, Criterion XVI .l

(seven instances) {

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e Address conformance with 10 CFR 50.59(b)(1) requirements as a result of ,

upgrade initiative of the UFSAR and the resolution of further deficiencies in ,

this area. l

The second part of the presentation should be an in depth discussion of the corrective

actions to address root causes as they apply to the broader implications of equipment

operability, testing, safety review activities, procedural adequacy and adherence, and

corrective actions. NRC staff expects Maine Yankee to focus the discussion on the

apparent violations and corrective actions on both the near-term and the long-term

- operations of Maine Yankee based upon your plans for resolving the concerns identified in ,

the ISA report. The NRC currently views the individual apparent violations grouped as  ;

follows; however, you may choose to place the individual violations into other groupings .

that have similar root causes or corrective actions.  !

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a. Safety-Related Equipment inoperability

  • 96-11, Section M4.1 - HPSI cut Wire
  • 96-16, Section E.3.2 - Control room ventilation and filter system
  • 96-10, Section E2.2 - EQ submergence
  • 96-09, Section E2.1 - CS building ventilation design deficiency

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  • 96-16, Section E2.1 - inadequate overpressure protection for PCC piping

affecting ECCS and EDGs

b. Testing Inadequacies -inadequacies in scope of testing, weaknesses in the rigor of

testing and evaluation of testing

  • 96-11, Section E3.2 -instrumentation and control circuits
  • 96-11, Section E3.2 - emergency power system periodic testing
  • 96-11, Section E3.2 - feedwater trip system periodic testing

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  • 96-09, Section M3.2 - EDG room fan thermostats
  • 96-09, Section M1.2 - PCC and SCC water system's flow control valves
  • 96-16, Section M1.2 - EDG load sequencers
  • 96-16, Section M1.2 - motor driven fire pump
  • 96-16, Section M1.2 - RAS permissive relays for the trip block timers

for LPSI

HP Si, LPSI, PCC, SCC, and SW pumps

c. Safety Review inadequacies - Operating differently than described in the FSAR

without having performed a written safoty evaluation, preparing an inadequate

written safety evaluation, or not providing periodic updates of the UFSAR

  • 96-16, Section E3.2 -inability to support plant operations up to the service

water temperature values stated in the UFSAR

  • 96-16, Section E3.2 -inadequate safety evaluation for operation of the

control room breathing air supply system with positive

pressure

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  • 96-16, Section E3.2 - failure to perform a written safety evaluation for the

procedure permitted the cross-connecting of DC buses

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  • 96-16, Section E3.2 - failure to provide periodic updates of the UFSAR

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d. Procedure inadequacies and Non-adherences - Failure to establish procedures as

required by TS and the failure to implement procedures as required by TS

  • 96-16, Section 04.1 -inadequate procedures to assure required shift staffing

and emergency preparedness response

  • 96-16, Section M1.1 - failure to establish procedures for the conduct

examination on a component of the "A" EFW pump

  • 96-16, Section M1.1 - failure to establish procedure to install and control j

fastener lockwire on safety related components

, * 96-16, Section 04.2 - failure to implement procedure to properly maintain

control room logs  ;

  • 96-16, Section 04.3 - failure to properly conduct an operability review

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  • 96-16, Section M1.1 - failure to implement procedure, resulting in improper j

removal of a seismic support on a SW pump i

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e. Corrective Actions Not identified, Untimely, and/or inadequate

  • 96-16, Section E8.1 - failure to identify problems that needed to be in the

corrective action system

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containtnent spray building ventilation design that relied on a non

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safety-related source of instrument air  ;

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the failure to identify components in containment that were below I

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submergence levelin the Environmental Qualification Program

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failure to recognize the lack of complete testing of the ECCS actuation

logic.

  • 96-16, Section E8.1 -Instances of untimely corrective action

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the design deficiency associated with the dampers for the containment

spray building ventilation system

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issue involving turbine hall flooding that puts the plant outside its

design basis

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e 96-16, Section E8.1 -ineffective corrective actions .

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auxiliary feedwater control system, a repetitive problem

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the manner in which the negative control room pressure 'Jectified J

during a surveillance tast was addressed.

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