IR 05000309/1987022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-309/87-22.Violation Re Failure to Follow Procedural Requirements of Procedure 2.50.23 Occurred as Stated

ML20237E483
Person / Time
Site:	Maine Yankee
Issue date:	12/22/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Randazza J Maine Yankee
References
NUDOCS 8712290024
Download: ML20237E483 (2)

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DEC 2 2.19g7 Docket No:- 50-309 i

Maine Yankee Atomic Power Company

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ATTN: Mr. J. B. Randazza l Vice President Nuclear Operations 1 l

83 Edison Drive Augusta, Maine 04336 Gentlemen:

Subject: Inspection 50-309/87-22 Your letter dated October 26, 1987, responded to our letter of S etember 23, 1987, concerning a Notice of Violation-for failure to conduct and appropriately document drills involving your Post Accident Sampling and-Analysis System . The Notice of Violation was-issued against requirements of- 1 your emergency plan implementing procedures which delineate your drill and '

exercise requirements. 10 CFR 50.54(q) requires' that you follow and maintain in effect, emergency plans which meets the requirements of 10.CFR 50 Appendix CFR 50, Appendix E. Part V specifically states the requirements to have implementing procedures to the emergency plan. ' As you stated in the above referenced response, you failed to follow the procedural requirements of'

Procedure 2.50.23 " Emergency Preparedness Exercises and Drills". . The fact that the regulations do not specifically: stipulate drill requirements for your Post Accident Sampling and Analysis System does not negate the basis for the Notice _of Violation. Therefore, it is our conclusion that the violation occurred as state Your response included corrective actions for the Notice of Violation, and ;

these corrective actions wil be reviewed in a future inspection of your i licensed program. No additional response is require !

i Your cooperation with us is appreciated, j

Sincerely, j

Original Signed By:  ;

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Ronald R. Bcilamy Thomas T. Martin, Director .

Division of Radiation' Safety and Safeguards i

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l 0FFICIAL RECORD COPY r

~8712290024 871222 9 3 ,

PDR, ADOCK 05000309 g , g -

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Maine Yankee Atomic 2 2 1937 Power Company cc: l C. E. Monty, President i C. D. Frizzle, Assistant Vice President / Manager of Operations  !

J. H. Garrity, Plant Manager P. L. Anderson, Project Manager g I

G. D. Whittier, Licensin Section Head j J. A. Ritsher, Attorney Ropes and Gray)

Phillip Ahrens, Esquire Public Document Room (PDR)

local Public Document Room (LPDR) {

Nuclear Safety Information Center (NSIC) i NRC Resident Inspector State of Maine bec:

Region I Docket Room (with concurrences)

DRP Section Chief H. Eichenholz, SRI, Yankee  !

P. Sears, LPM, NRR Robert J. Bores, DRSS Dave Matthews, NRR, PEPB

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h N RI:DRSS RI:DRSS RI:DRSS Conklin Lazarus Bellamy 12/ /87 12/ /87 12 /87 0FFICIAL RECORD COPY rl my 87-22 12/19/87

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mEL>ABLE ELECTAiCITV 80m MAINE SiNCE '9'2

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EDISON DetlVE e AUGUSTA MAINE 04330. #20h 622 4668

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October 26, 1987 MN-87-ll? - GDH-87-244 Region I United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 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 HYAPCo, Inspection Report 87-22 dated September 23, 1987 Subject: Response to Inspection Report 87-22 Gentlemen:

Reference (b) contained an apparent violation of NRC requirements. Our response to that apparent violation is enclose VIOLATION 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 par Procedure 2.50.23. " Emergency Preparedness Drills and Exercises", requires

, annual drills in Post Accident Supling and Sample Analysis. The procedure also specifies the documentation that must accompany each drill performe Contrary to the above, drill records examined for 1985 and 1986 indicate that the annual drill for Post Accident Sampling and Sample Analysis had not been performed. Additionally, required documentation and management review / approval is incomplet This is a Severity Level IV Violation (Supplement B).

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

caused by failure to strictly follow certain specific procedural i requirement x M%-

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Un'ited States Nuclear Regulatory Commission Page Two .

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. Attention: Mr. Thomas T. Martin, Director MN-87-Il7 l l

To correct'this procedural violation, we completed a Post Accident Sampling system (PASS) drill on Tuesday, October 13, 198 He were in full compliance with our own procedure as of that dat 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 reason CFR 50(q) requires that licensees shall follow and maintain in effect l 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 CF ;

Further, our approved Emergency Plan states, in Section 8.1.3 (Orills and ]

Exercises) that we shall conduct semi-annual Health Physics Drill j Again, no specific mention is made of a' requirement for a PASS dril j i

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It appears therefore, that our procedural requirement for conducting an l I

annual PASS drill was not based upon any requirement in 10 CFR or any i requirement in our Emergency Pla CORRECTIVE ACTIONS TAKEN l l

He have implemented the following corrective actions to preclude future j violation I

Procedure 2.50.23 has been revised to improve plant and corporate review of Emergency Plan drills and exercise *

Frequent planning meetings are now conducted between corporate and

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plant staff, in part, to review the documentation of required on site 1 activitie *

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

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U'nited States Nuclear Regulatory Commission Page Three

• Attention: Mr. Thomas T. Martin, Director MN-87-Il7 i

We trust this information is satisfactor Should you require more information, or have any questions, please contact me at any tim i Very truly yours, HAINE YANKEE

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hh/W G. D. Whittier, Manager Nuclear Engineering and Licensing GDW/bjp cc: Mr. Cecil 0. Thomas Mr. William T. Russell "

Mr. Pat Sears Mr. Cornelius F. Holden i

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