ML20198K614
| ML20198K614 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/12/1998 |
| From: | Racquel Powell NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Christine K AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20198K617 | List: |
| References | |
| FOIA-97-401 NUDOCS 9801150056 | |
| Download: ML20198K614 (2) | |
Text
v...
.,, n -,, s v o.
.... ~ v..
.,o.. % vui,m m s, FOIA - MW/
/.a %g,
L t heoNtt tvet t
[
tc RESPONSE TO FREEDOM OF l'INat I W"^t 27 N-)q 0 '"' ""^ " ^ '*'""
"'8'
'h 2 m
"^"
/\\ Tup oon.1 ~o.a ms,,~,.
,u omo.% / G z
( A., 2: %
PART 1. AGENCY RECORDS RELL ASED OR NOT LOCATED (See chetArcttsones/
No agency records subject to the request have been located.
No additional agency accords subject to the request have been located.
RequMttJ records are available through another pubhc distribution program. See Comments section, Agency records subject to the reuucst that are 6dentihed in Append.a(es) are already available for pubhc inspection and copying at the NRC Public Document Room. 2120 L Street. N W, Washington. DC.
Agency records sut4ect to the ret ist that are 6dentified in Appendiales)
M are bemg made available for pubhc inspection and copying k
O the NRC Pubbe Document Rotr.1. 2120 L $treet, N W., Washington, DC, m a folder untier this F OI A number.
The nonpropnetary versiori of the proposalls) that you agreed to accept in a telephone conversabon with a member of my statf is now bemg made available for pubhc inspection and copy 6ng at the NRC Pubhc Ducument Room,2120 L Street, N.W., Washington, DC, in a folder under this FOI A number.
Atency records subject to the request that are identified in Appendt:(es) may be inspected and copied at the NRC Local Pubhc Document Room 6dentified in the Comments section.
L nclosed is mformation on how you may obtam access to and the charges for copying records located at the hf RC Public Document Hoom,2120 L btreet, N W, Washington, DC.
g Agency records subject to the request are enclosed.
Records subject to the request have been referred to any.her Freetal agency (ies) for review and direct tesponse to you, f oes You will be belled by the NRC for fees totahng $
You will receive a refund from the NRC in the amount of $
in view of NRC's response to this request, no further action is bems taken on appeal letter dated
, No
~
PART 41. A-INF ORMATiON WITHHELD FROM PUBLIC DISCLOSURE Corteln information in the requested records is being withheld f rom public disclosure pursuant to the enempdons described in anti for the reasons stated in Port it, B, C, and D. Any relened portions of the documents for which only part of the record is being withheld are being made available for public inspection end copying in the NRC Public Document Room,2120 L Street, N W., Washington, DC in a folder under this FOI A number, COMMI NTS h(( l y
7 7 p %
g,y y
, i
, e,l m u,. c l, j
.m c
/
l,AO%{U', DIM Ct. Vih 0N OF F ttDOA F FOHYAllON AND PUBLICAtlON5 5t RVICt5 A#
B: -
M
(
x m $ OUn' d y
i
+
A D.-
4 CHa!GT!97-401 PDR L
NRC FpRM M4 LPart H lt 99 r%D/ /J C C)Ms
l w
Re: FCIA 97-401 APPENDIX 5 i
RECORDS BEING RELEASED IN THElR ENTIRETY l
dQ, DATE DESCRIPTION /(PAGE COUNT) l 1.
12/05/94 Exhibit 11 to ROI 196-040, Letter to C. D. Frizzle from J. Linville,
Subject:
Inspection 50 309/9415 (6 pages) 2.
01/31/97 Exhibit 14 to ROI 196-040, Memorandum from J. Yerokun to B. Letts,
Subject:
Reviews regarding Potentially incompleti-and Inaccurate Information Deliberately Provided to the NRC regarding the Emergency Feedwater System Valves at Maine Yankee (196-040) (2 pages)
P 1
1 w
e
,... - ~...
.~
v.
-r-,
l R)lAA4 I4TXEST
,,,,"9 7-4 o lIf-jg[ g One No October 16,1997 0$ ovo:
Actbn 'Hf:
D*M.
r-
= c te.... e.,,,,.
his. Carol Ann Reed Nuclear Regulatory Commission Washington, DC RE: OFFICE OFINIliSTIGA T1053 REPORT #196-040 ONMAINE l'ANKEE A TOMIC Poll'ER STA TION
Dear his. Reed:
Pursuant to the l'reedom ofInfomiation Act, I am requesting copies of the Exhibits st3,1,6,7,8,10,11,14 and 16 in the Ollice ofInvestigations Report til 96 040 regarding the hiaine Yankee Atomic Power Station.
If there is a charge for photocopying these materials, please let rne know at the address below. I will mail you a signed, hard copy of this faxed request.
Thank you for your prompt attention to this request, I do appreciate it!
Lincerely, Kris L Christine
~ 774L'%MLf'
/f
4 g
m-41
'"'am s
,,___s..
W h
h 4
a h
C i
l i
EXHIBIT 11 d
EXHIBIT 11
y
' NUCLEAR RECULATORY. COMMl0SlON -
,' g, y,
m att70ALInoAo
[- [ \\ o.... M
- ma or enussiA. remsytymA mosam December 5, 1994 Mr. Charles D.-Trizzle-
- President Maine Yankee Atour c Power company
-329 Bath Road-
-Brunswick,-Maine C4011
$UBJECT:
IM5PECTION 50-309/94-15
.DeanLMr. Frizzla:
This refers to'your November 15, 1994 m resp wlence, in response to our ktober 20, 1994 letter..
Thank you for informing us of the corrective and preventive actions documented
-it your letter:regarding post-maintenance testing of emergency feedwater isolation valves.-- These actions will be examined during a future inspection -
'of-your-licensed program.
Your cooperations with us is appreciateo.
Sincerely,
,f pcY s C. Linville, C f
Projects Branch No.
Division of Reactor Projects Docket No. 50-309 cc:
-G. Leitch,.Vice President, Operations P. L. Anderson, Project Manager (Yankee Atomic Electric Company)
- R. W. Blackmore, Plant Manager L. Diehl, Manager of Public and Governmental Affairs cc w/cy.of Licensee's Response-Letter:
J.'A. Ritsher, Attorney-(Ropes and Gray)
P.'Dostie, State Nuclear. Safety Intpector P. Brann, Assistant Attorney General.
U. Vanags, Maine State Planning Office C.'Brinkman, combustion Engineering,=Inc.
First Selectmen of Wiscasset Maine State Planning officer-PUBLIC Nuclear Safety Information Center (NSIC)
K.'Xbraham, PA0 (2 copies)
NRC. Resident Inspector-State of Maine, SLO Designee N BIT
. CASE NO.
1-90-040 PAGE / OF,./a_PAGE(S)
/
I
& f7/Jrd$[
}pj s
MaineYankee M U ABL E E tt CimCIT Y SmCE 1977 329 BATH ROAD BRUNSWICK, MAINE 04011 * (207) 79B-4100
($
November 15, 1994 HN-94-lll JRH-94-262 UNITED STATES NUCLEAR REGULATOM C0fti!SS10N Attention:
Document Control Desk Washington, DC 20555
References:
(a)
License No. DPR-36-(Docket No. 50-309)
(b)
USNRC Letter to MYAPCo dated October 20, 1994, Notice of Violation for NRC Inspection Report 50-309/94-15
Subject:
Reply to Notice of Violation Associated with NRC Inspection Report No. 50-309/94-15 Gentlemen:
Our respon des to these violations were outlined by members of the Maine Yankee staff at an En/orcement Conference held at Region I on October 14, 1994.
The attachment to this letter responds in detail to the Notice of Violation contained in Reference (b).
In this attachment, we have restated the violations, provided our
{.
response, and have addressed our actions taken.and planned to prevent recurrence.
Please contact us should you have any questions regarding this matter.
Very truly yours,
>t: %
M d
James R. Hebert, Manager L
Licensing & Engineering Support Department JMC/ jag Attachment j
l c:
Mr.. Thomas T. Martin Mr. J..l. Yerokun Mr. E. H. Trottier Mr. Patrick J.=Dostie l
[-
CASE NO.
1-96-040 M
({
EXHIBIT l
PAGE > CF (a PAGE(S) l L:\\94*n\\94111 l-Ifll?? O /no 57VJ
3-.4J$
tM c
+
u Reply to Notice of Violation Violat' ion Al Inadeouate Post Maintenance Testina-
,(
10 CTR-Part 50, Appendix B, Criterion XI, requires that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service, is identified and performed, and incorporates the requirements and acceptance limits contained in applicable design documentation.
Contrary to the above,'on August 4,1994, the test program did not assure that all testing, required to demonstrate that the emergency feedwater valves will satisfactorily isolate a faulted steam generator, was identified and performed, to incorporate the requirements and acceptance limits contained in applicable 4
design documentation.
As a result, the post maintenance testing, conducted after the April 1992 maintenance of emergency feedwater valve EFW-A-338, did not identify the incorrect reassembly.
Maine Yankee Resoonse to Violation A The specification of adequate post maintenance testing is the responsibility of engineering. The post maintenance testing specified for EFW-A-338 in 1992 was limited to IST Stroke Timing. This testing was not adequate to demonstrate that the valve would perform its intended function satisfactorily in service.
Imediate Corrective Actions
~~
The following actions were taken after finding that the post maintenance testing perfonned on EFW-A-338 was not adequate to demonstrate that'the valve would perform its intended function satisfactorily in service.
i ~
Determined an acceptable leak rate.
Tested and maintained valves to satisfy the acceptance criteria.
~
____ Imposed administrative controls to require post maintenance seat leakage
' check of the applicable EFW valves.
Initiated a root cause determination.
Corrective Actions Taken to Avoid Further Violations 1.
The following corrective actions have been taken to avoid further violations:
Reviewed Maintenance Department valve procedures to determine adequacy of post maintenance testing.
Issued written interiin directives providing additional guidance on how to specify post maintenance testing.
E O-1 - 9 G ~ () 4 ()
EXHIBIT PAGE 3 OF 6 PAGE(S)
L:\\94m \\94111
J o
Will develop a cew procedure by April,1995, which will contain 1: proved guidance en the specification of post maintenance testing to replace the
, interim guidance.
(
- e Provided root cause training for all plant engineers.
~
Implemented a program to automatically trigger root cause for functional failures.-
Assessed current closure functionality of air / motor operated rotating valves.
e.
Assessed valves in.the IST Program to reasonably assure that valves are assembled correctly.
2.
The following/ corrective actions will be taken to avoid further violations:
The adequacy of testing requirements in.the present design change process will be reviewed.
' ^
The IST Program-interpretation of category A and B valves is currently under review.
Industry standards and Ha.ine Yankee specific test controls associated with functional testing are being reassessed.
Full Comoliance Date
- [
l i\\
Full compliance was achieved on August 11,'1994, when an acceptable leak rate was determined and the valve was maintained and tested to that 3.cceptance criteria.
CMNO.
1.on 04 o
('
EXHIBlT k PAGE 9 OF 6-PAGE(S)
L:\\94am\\94111
L
- Violation B.
Inacorocriate Maintenance Procedure 10 CFR. Part 50,. Appendix B, Criterien V. requires that activities affecting L
+
quality be prescribed by written. instructions appropriate to the circumstances.'
'.h Contrary to the abon, _between March 31, 1992, and April 2, 1992, maintenance L
- on emergency feedwater valve EFW-A-338, an activity affecting quality was not prescribed by written instructions appropriate to the circumstances, 'in that 1
. Maine Yankee Procedure 5-55-10, Revision 2, Maintenance of EFW Air Operated Trip Valves (EFW-A-338, - 339 and-340), did not provide written instruction that' assured the proper reassembly of the emergency feedwater valves. As a result.
the disc for valve EFW-A 338 was connected 180 degrees out of alignment with-the
-actuator.
. llaine Yankee Resoonse to Violation B l
Maintenance procedure provided inadequate guidance 'to ensure consistent and proper valve installation and assembly.
This included inadequate procedural guidance to ensure proper valve orientation + as well as inadequate procedural guidance to properly couple the stem to the actuator.
Inimediate Corrective Actions c
-Upon discovery of the improper re-assembly of EFW-A-338, the following innediate corrective actions were performed:
Properly assembled EFW-A-338.
]
Inspected EFW-A-339 and 340 to ensure correct orientation of valve seat.
l
'e i
Marked valves externally to indicate proper position and orientation.
l -
e Corrective Actions Taken to Avoid Further Violations F
1.
Actions taken to avoid further violations include:
'Provided improved procedural guidance for assembly of these specific valves.
Improved as-found data documentation requirements.
l l
Specified valve _ installation orientation.
Specified external match marking requirements.
Included I&C verification of v'alve position prior to actuator installation.
Provided sufficient guidance to ensure proper valve-to-actuator assembly.
CEN1
].- 9 G 04 0 N
gxgig;7 I-
~
PAGE I OF 6-PAGE(S)
Li\\f4an\\94111 T
1 i
.2.*
The foll.owing corrective action will be taken t'o avoid furth,er violations:
Developing consistent process for mechanical, electrical, and I&C to
{
properly identify and verify internal disk-to-seat orientation, Full Como11ance Dat?
Full compliance was achieved on October 13, 1994 when Maintenance Procedure 5-55-10 with improved guidance was reviewed by PORC and approved by the Plant Manager.
s I
U- ]-90-049 EXHlBIT //
('
PAGE 6 _OF 6 PAGERS)
.L:\\94mn\\94111
.i.
f 4
(
EXHIBIT 14 g
il '
EXHIBIT 14
.