ML20235V771
| ML20235V771 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/21/1989 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GDW-89-55, MN-89-20, NUDOCS 8903100325 | |
| Download: ML20235V771 (2) | |
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'Ma.meYan.kee-RELIABLE ELECTRICITY FOR MAINE SINCE 1972 EDISON DRIVE. AUGUSTA, MAINE 04330.(207) 622-4868.
February 21, 1989 MN-89-20 GDH-89-55 t
b LRegion I.
UNITED. STATES NUCLEAR REGULATORY COMMISSION 475'A11endale Road King of' Prussia, Pennsylvania. 19406 LAttintion:: Mr. William T. Russell, Regional Administrator.
References:
(a)' License No. DPR-36 (Docket No.:50-309)
(b) USNRC Letter to MYAPCo dat'ed January 20, 19E'),
Inspection Report No. 50-309/88-21
Subject:
' Response to Notice of Violation - Inspection Report 50-309/88-21
-Gentlemen:
This letter. responds to the Notice of Violation contained in Reference (b).
For completeness, we have restated the violation with our response following.
Notice of Violation:
Technical' Specification 5.8.1 requires procedures be established, maintained and implemented covering the applicable procedures recommended i
in Appendix "A" to Regulatory Guide 1.33. Revision 2 February 1978.
Appendix "A of Regulatory Guide 1.33, Revision 2, February 1978, recommends procedures for the control of maintenance, repair, replacement and modification work.
Plant Engineering Department procedure 17-23-1 " Design Change Installation Instructions" General Precaution 7 requires any deviation from
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Installation Instructions to be authorized by the Field Engineer, and i
documented by a FCN (Field Change Notice).
I Contrary to the above, contractor employees deviated from the Installation
' Instructions to insta11' electrical conduit in accordance with Job Order 88-26-1-2, when a support for the instrument tubing associated with the Primary Inventory Trend System was removed and improperly reinstalled without authorization of the Field Engineer nor documentation in a Field Change Notice.
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4 MameYankee' United--StatesNuclearRegu1AtoryCommission-Page Two Attention:.Mr. Hilliam H. Russell.
MN-89-20 Maine YaheeResponse:
1.
The following corrective steps were taken, with the-results as indicated::
The conduit was removed from the support.
Re-analysis determined
-that the support was not required to properly support the conduit.
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- Subsequently, the tubing support was properly re-installed and
.re-torqued.,The modified support was re-analyzed and determined,to be acceptable, as modified.
Additionally, a-walkdown of the conduit run.was performed and verified to conform to the instructions.
2.-
The following corrective steps will be taken to avoid further violations:
The contractor training manual willbe revised by December 31, 1989 to ensure that craft personnel associated with modification work are
. trained.to'not modify existing supports, systems, structures, or components without prior engineering assessment and approval.
The engineering installation instruction procedure will be revised to provide' additional instructions.to engineering personnel on precautions..to be specified in work' packages when installing conduit
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runs.
The procedure will be revised by 04/01/89.
3.
Full 1 compliance was achieved before the affected systems were required to.be operable.
Should~you have questions on this matter, please contact me.
Very truly yours, MAINE YANKEE h))'AVh G. D. Whittier, Manager Nuclear Engineering and Licensing c: Mr. Richard H. Nessman i
Mr. Patrick M. Sears Mr. Corneli;Js F. Holden 1046L-RCC L'
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