ML20236G544

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Responds to NRC Re Violations Noted in Insp Rept 50-309/87-22.Corrective actions:post-accident Sampling Sys Drill Completed,Procedure 2.50.23 Revised to Improve Review of Emergency Drills & Exercises & Documentation Reviewed
ML20236G544
Person / Time
Site: Maine Yankee
Issue date: 10/26/1987
From: Whittier G
Maine Yankee
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
9253L-JMT, GDW-87-244, MN-87-117, NUDOCS 8711030069
Download: ML20236G544 (4)


Text

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MaineVankee 4

AEllABLE ELEC91 CITY FOR MAINE SINCE 1972 EDISON DRIVE. AUGUSTA. MAINE 04330.(207) 622 4868

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l October 26, 1987 MN-87-117 GDH-87-244 i

Region I United States Nuclear Regulatory Commission 631' Park Avenue 4

King of Prussia, Pennsylvania 19406

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Attention:

Mr. Thomas T. Martin, Director Division of Reactor Safety and Safeguards

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo, Inspection Report 87-22 dated September 23, 1987

Subject:

Response to Inspection Report 87-22 Gentlemen:

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Reference (b) contained an apparent violation of NRC requirements. Our response to that apparent violation is enclosed.

VIOLATION i

10 CFR 50.54(q) requires in part that, nuclear power reactors shall. follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements of Appendix E to this part.

Procedure 2.50.23, " Emergency Preparedness Drills and Exercises", requires annual drills in Post Accident Sampling and Sample Analysis. The procedure also specifies the documentation that must accompany each drill performed.

Contrary to the above, drill records examined for 1985 and 1986 indicate I

that the annual drill for Post Accident Sampling and Sample Analysis had l

not been performed. Additionally, required documentation and management review / approval is incomplete.

This is a Severity Level IV Violation (Supplement B).

I MAINE YANKEE RESPONSE He have determined that this apparent violation of our procedure was I

caused by failure to strictly follow certain specific procedural requirements.

8711030069 971026 PDR ADDCK 05000309 l

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i United States Nuclear Regulatory Commission Page Two Attention: Mr. Thomas T. Martin, Director MN-87-ll7 To correct this procedural violation, we completed a Post Accident Sampling system (PASS) drill on Tuesday, October 13, 1987. He were in full compliance with our own procedure as of that date.

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However, we do not believe this procedural violation constitutes a violation of Commission requirements contained in 10 CFR 50 or a violation of our approved Emergency Plan, for the following reasons.

10 CFR 50(q) requires that licensees shall follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E.

10 CFR 50.47(b) requires that periodic drills be conducted to develop and maintain key skills, while Appendix E requires that a training program, which includes training and exercises, be described in the Emergency Plan.

No mention of PASS drills appears to be included in these sections of 10 CFR.

Further, our upproved Emergency Plan states, in Section 8.1.3 (Drills and Exercises) that we shall conduct semi-annual Health Physics Drills.

Again, no specific mention is made of a requirement for a PASS drill.

It appears therefore, that our procedural requirement for conducting an annual PASS drill was not based upon any requirement in 10 CFR or any requirement in our Emergency Plan.

CORRECTIVE ACTIONS TAKEN We have implemented the following corrective actions to preclude future violations.

Procedure 2.50.23 has been revised to improve plant and corporate review of Emergency Plan drills and exercises.

Frequent planning meetings are now conducted between corporate and plant staff, in part, to review the documentation of required on site activities.

Responsibility for coordinating on site emergency preparedness activities has been transferred to the Assistant to the Technical Support Department Manager.

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f United States Nuclear Regulatory Commission Page Three Attention: Mr. Thomas T. Martin, Director HN-87-ll7 l

1 He trust this information is satisfactory.

Should you require more information, or have any questions, please contact me at any time.

Very truly yours, MAINE-YANKEE Nh/W

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G. D. Whittier, Manager' Nuclear Engineering and Licensing 1

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cc: Mr,.. Cecil _0.

Thomas fMr.?Hillia'm:T..

' Mr: Pat l Sears',Russelltf Mr. Cornelius F. Holden i

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