ML20205A813
| ML20205A813 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/17/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Randazza J Maine Yankee |
| Shared Package | |
| ML20205A818 | List: |
| References | |
| EA-88-206, NUDOCS 8810260102 | |
| Download: ML20205A813 (5) | |
See also: IR 05000309/1987016
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October 17, 1983
Docket No. 50-309
License No. OPR-36
EA 88-206
Maine Yankee Atomic Power Company
ATTN: Mr. J. B. Randazza
83 Edison Drive
Augusta, Maine 04336
Gentlemen:
Subject:
NOTICE OF VIOLATION (N.'C Inspection Report No. 50-309/87-16)
This refers to the NRC inspection conducted on July 20-24, 1997, to review the
program for the environmental qualification (EQ) of equipment at Maine Yankee.
The inspection report was sent to you on November 19, 1987.
During the inspec-
tion, the NRC reviewed violations of NRC requirements identified by your staff
involving the lack of qualification of certain items of electric equipment.
Ca August 22, 1988, an enforcement conference was conducted with members of
your staff to discuss the significance and extent of the violations, causes
of the violations, and the corrective actions taken or planned.
Further,
application of the enforcement policy set forth in Generic Letter 88-07 was
m considered.
Ons 9f the violations, which is described in Section I of the e,1 closed Notice
of Violation, tr.volved the use of certain items of electrical equipment at the
facility which were not included on the list of electrical equipment important
to safety, and for which q'.alification files did not exist to verify that
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these items would perform their intended functions during the postulated
environmental conditions that would exist during an accident. The specifte
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ttens consisted of: (1) Continental Cable used in four of the Reactor
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Coolant System hot and cold leg Resistance Teeperature Detectors (RTD); and
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(2) a States Terminal Block used in one of the four affected RTDs. The RTOs
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are used to monitor long term Reactor Coolant System temperature as a part of
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the Post Accident Sampling System and they also provide temperati.re inputs
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to the Reactor Regulating System and the Appendix R Alternee Safe Shutdown
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System. The violation occurred because the initial plant wa hdowns were rot
controlled by adequate procedures.
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The NRC recognizes that these deficiencies were (1) ider.tified by your staff
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during an upgrade of qualified splices in response to an internal audit
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conducted at your facility, and (2) promptly corrected by replacement of the
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cable with qJalified cable, and elimination of tha need for the termiiial block.
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Further, the NRC also rocognizes that documentation of equipment qualification
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at Maine Yankee has in general been goad, and *, hat the qualification files were
rs idtly auditable at the time of the inspection. Nonetheless, these deficien-
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cies clearly should have been known to you prior to November 30, 1985, which
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was the deadline for being in compliance with the EQ requirements, because NRC
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CERTIFIED MAIL
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RUITRDEfEWT REQUESTED
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Maine Yankee Atomic Power Co.
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D0R Guidelines, Section 3.0, specifically identified electrical cable to be one
of the components to be included in the qualification list and because IE
Circular 78-08 (Item 3), Information Notice 82-03 and Information Notice 84-47
were sent to all licensees on May 31, 1978, March 4, 1982 ar.: June 15, 1984,
respectively, to alert licensees of the need to qualify terminal blocks.
However, the Continental cable and the States Terminal Block were not identified
during the initial plant walkdowns and the NRC maintains that
reasonable
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walkdown clearly should have identified deficiencies such as lack of qualifi-
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cation for such fundamental components as able and terminal blocks.
In accoraance with the "Modified r
. ment Policy Relating to 10 CFR 50.49,"
contained in Generic Letter 88
'osure 2), the violation described in
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Section I of the enclosed Notice i , seen determined to be isolated and to
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have affected a few systems and components, and-therefore, is considered to
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be an EQ Category ^ problem. The base value of a civil penalty for an EQ
Category C problem is $75,000.
However, after consultation with the Diretor,
Office of Enforcement and the Deputy Executive Director for Regional Operations,
I have decided that the civil penalty in this case should be mitigated in its
entirety for reasons set forth herein. Although Section IV.B of the Enclosure
to the Generic Letter 88-07, states that a minimum $50,000 should normally be
issued, full mitigation of the civil penalty is appropriate, in accordance
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with the specific guidance described therein, because (1) the violations were
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isolated and affected only a few systems; (2) the violations were identified
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Sv your staff and promptly reported to the N ,C; (3) the violations were
corrected within a reasonable amount of time; and (4) Maine Yankee made best
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efforts using external groups to support, audit, and upgrade the plant EQ
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program to complete Ey within the November 30, 1988 deadline.
Certain items of unqualified equipment, subsequently replaced, were determined
to be qualifiable within a reasonable period. These items constitute a
separate violation which is classified at Severity Level IV in accordance with
the "General *tatement of Policy and Procedure for NRC Enforcement Action,"
10 CFR 2, Arv+ dix C (Enforcement Policy) (1988).
This violation is set forth
in Section 2
of the enclosed Notice.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosures
will be placed in the NRC Public Document Reom.
Because the violations set forth in the enclosed Notice were identified, corrected,
as well as reported, as required, by the Maine Yankee Atomic Power Company, no
response to the Notice is required.
Sincerely,
Original Sicnod By
WII.LII.'. 7. T.USSZLL
William T. Russell
Regional Administrator
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Maine Yankee Atomic Power Co.
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Enclosures:
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2.
cc w/ enc 1: See Next Page
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Maine Yankee Atomic Power Co.
DISTRIBUTION:
bec w/ enc 1:
Region I Docket Room (with concurren:es)
Management Assistant, ORMA (w/o enc 1)
DRP Section Chief
Robert J. Bores, DRSS
SECY
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J. Taylor, DED0
J. Lieberman, OE
W. Russell, RI
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T. Murley, NRR
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D. Holody, RI
J. Wiggins, RI
J. Glodberg, OGC
T. Martin, DEDRO
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Enforcement Officers, RII-III
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Enforcement Officers, RIV-RV
F. Ingram, PA
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J. Bradburne, CA
E. Jordon, AE00
B. Hayes, 01
S. Connelly, OIA
H. Wong, OE
DE FILES (3 copies + ltr bc)
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L. Tripp, ORP
D. Limroth, ORP
H. Eichenholz, SRI - Yankee
P. Sears, LPM, NRR
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R. Bores, Technical Assistant, DRSS
PA0 (9) SALP Reports Only
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cc w/ enc 1:
C. D. Frizzle, Vice President, Operations
John Garrity, Vice President, Quality Programs and Engineering
Dr. E. i. Boulette, Plant Manager
P. L. Anderson, Project Manager
G. D. Whittier, Licensing Section Head
J. A. Ritsher, Attorney (Ropes and Gray)
Philip Ahrens, Esquire
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Maine
0FFICIAL RECORD COPY
0004.0.0
10/17/88