ML20235V771

Responds to NRC Re Violations Noted in Insp Rept 50-309/88-21.Corrective Actions:Conduit Removed from Support & re-analysis Determined Support Not Required to Properly Support Conduit.Tubing Support Reinstalled & Retorqued

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)

Text

. _ _ _ - _ _ _ _ _ - - _

, f .. v . .. .

5 { ," '&'t* '

.y;

. '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 )

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.

DbS$$$$$$30, PDC y} l g

.1046L-RCC b '

l

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 4

-that the support was not required to properly support the conduit.

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 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' -

i