IR 05000029/1975017
| ML19345A282 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/05/1976 |
| From: | Durr J, Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19345A281 | List: |
| References | |
| 50-029-75-17, 50-29-75-17, NUDOCS 8011180555 | |
| Download: ML19345A282 (17) | |
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IE:I Torm 12
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Qan 75) (Rev)
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U. 5. NUCLEAR RECUL\\ TORY CCOfISSICN OFFICE OF INSPECTION AND E:.70RCDfENT
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REGION I
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50-29 3-Docket No:
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IE Inspection Report No:
Licensee:
Yankee Atomic Electric Ceepany Licensa No: DPR-3
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20 Turnpike Rd Priority:
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C West Borough. h ssachusetts 01581 Categorf:
Safeguards
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Iscation:
Row, &ss.
PWR 175 MWe (U)
Type. of Licensce:
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Routine, An*nounced
T,,.: of inspection:
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December 7-11, 1975 Dates of Inspection:
November 4-7, 1975 Dates of Previous Inspection:
I Reporting Inspector: jg26)gj c q,.yjj
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J.D6rr,Reac:orInspector Accompanying Inspectors:
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DATZ,
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DATE
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Other Acconpanying Personnel:
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Reviewed By:
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EE R. Haynes, Secticn-beader
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SUMMARY OF FINDINGS-
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Enforcement Action
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Items of Noncompliance None B.
Deviations
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None Licensee Action on Previous 1v Identified Enforcement Items Not applicable e
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Design Changes A.
Modifications Recuired to Meet Proposed Change No. 117, Supplement 3(E), 5 and 6.
EDCR 75-28 EDCR 75-28 was developed to implement the changes set forth in the
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Core XII ECCS Performance Safety. Evaluation. 'This was accomplished
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l with a series of attachments to EDCR175-28 (OP-5000.36): that addressed
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each area of the plant syste=s requiring changes. The areas affected
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1.
Electrical power supply modifications to valves CH-MOV-522, 523, and 524.
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2.
Mbdification to Ac,cumulator Relief Valves SI-SV-56 and 57, 3.
Modification to Charging Pump Control Circuits.
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Modification to Loop Isolatica and Safety Injection MOV's.
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Modification to Emergency MCC No. 2.
'(Details,. Paragraphs
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3.a. (2) (a))
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B.
Hot Leg Injection Modification EDCR 75-21 EDCR 75-21. involved the installation of a piping connection between
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the charging and purification systems to provide a hot leg flow path for.long term' cooling of the reactor.
(Details, Paragraphs 3.a. (2)(b))
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4 Unusual Occurrences None reported
- Other Significant Findings A.
Current Findings 1..
Acceptable Items
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(a) _ Safety Evaluation Ieoacted Procedures The inspector reviewed the Plant Operating Procedures to assure consonance with the safety evaluation.
(Details, paragraph 3.a. (1)(a) and 3.a. (1)(c) 1 and 2)
(b) ' 3 Loop Operatien -
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f An inconsistency between the Technical Specifications, the Operati g Procedures, and a licensee memorandum concerning j-3' loop speration was resolved by the implementatiun of.the j
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Proposed Technical Specification ':o.125 and the licensee's
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commitment to change procedures.- (Details, Paragraphs.
3.a. (1)(b) and 3.a.- (l)(c) 3)
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.(c) Resolution of Safety Evaluation Recuirements
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(1) Emergency Procedures were changed to eliminate the
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" Cutback" mode of injection.- (Details, Paragraph 3.b. (1))
(2) During power operation power will be removed from selected safety injection valves.
(Details, Paragraph 3.b. (2))
(3) The wiring of CH-MOV-522, 523, and 524 was modified and the valves left in the open position at power operation.
Valves CH-MOV-522 and 523 will be periodically monitored
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to assure their proper positioning.
(Details, Paragraphs
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3.b(3) and 3.b. (4))
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(4)_ During power operation, electrical power will be re=oved
- from selected charging system and = sin coolant loop
valver.
(Details, Paragraph 3.b. (5))
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-3-(5) During power -operation, electrical power will be-removed from valve CS-MOV-532.
(Details, Paragraph 3.b. (6))
(6) Modifications were performed on the control circuitry of SI-SV-56 and 57.
(Details, Paragraph 3.b. (7)
(7) -Modifications were performed on the power supply circuitry to each charging pump.
(Details, Paragraph 3.b. (8))
(8) The licen'see has proposed to rack out and lock the alternate supply breakers to the No. 1 and 2 Auto-thrower Emergency MCC.
(Details, Paragraph 3.b.(9))
(9) Provisions were =ade to provide for " Hot Leg Injection."
(Details, Paragraph 3.b. (10))
(10) The accu =ulator will contain a minimum of 700 ft of water.
(Details, Paragraph 3.b. (ll))
2.
Unresolved Items a.
Modification Drawings
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The inspector observed that two drawings of the modifications being installed to implement the Safety Evaluation of Core
XII ECCS Perfor=ance (SE) were marked "Not Approved Copy"
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and that the revision approval block was not completed.
This item is considered unresolved pending verification that the drawings were reviewed and approved in accordance with the licensee's procedures.
(Details, Paragraph 3.a(2)(c))
b.
Completion of SE Cermittents The licensee had not completed the quality assurance document review of the =odifications installed to_ implement the SE.
This item is unresolved pending the completion of the quality assurance review'and notification of NRC, Region I.
(Details, Paragraph 3.a. (2)(d))
c.
Steam Generator Tube Failure OP-3107, Steam Generator Tube Failure, ster 6 requires the realigneent of certain valves addressed in t he SE and, thus,~~
a possible unrevfewed sa'fe't'y questio.-
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-4-This item is unresolved pending a determination that the valve changes required do not constitute an un-reviewed safety question.
(Details, Paragraph 4)
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Management Interview At the conclusion of the inspection, the inspector held an exit interview to discuss the. inspection findings.
The following persons were present:
Yankee Atomic Electric Company H. Autio, Plant Superintendent T.-Danek, Operation Supervisor P. Laird, Maintenance Supervisor-L. Reed, Operation Quality Contrcl and Audit J. Staub,. Technical' Assistant to the Plant Superintendent N. St. Laurent, Assistant Plant Superintendent The items discussed by the inspector were:
1.
The purpose of this routine, announced inspection was to confirm that certain plant =edifications and operating procedure changes
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have been =ade to comply with the limitation s imposed lor the Safety Evaluation of the Core XII ECCS Performance.
(Details, Paragraph 2.b)
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2.
The inspector stated that no items of noncompliance or deviction had been-identified.
3.
The inspector noted that two items had been identified as unresolved.
a.
Modification drawings 9699-FE-9D-1 and 9699-ESK-6AB were marked
"Not Approved Copy" and the revision blocks were not co=pleted.
t (Details, Paragraph 3.a.(2) (c))
b.
The Steam Generator Tube Failure Procedure appears to be in conflict with the safety evaluation ccncerning valve realignment.
(Details, Paragraph 4)
4.
The inspector reviewed the individual items of change required by the safety evaluation and their resolution with the licensee 'and.noted these to be acceptable.
(Details, Paragraph 3.b)
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- The inspector' reviewed the licensee's commitment to:
(a) Review and rewrite those procedures, OP-3600 to 0P-3899 affected by. Change ~No.'117 not later than January 1, 1976.
(Details, Paragraph 3.a(1)(c) 1,.)
(b) Review and rewrite those procedures allowing or i= plying 3 loop operation not later than January 1,1976..
(Details,
Paragraph 3.a.(1)(c) 3)
(c)
OP-5101,~ Maintenance of Motor Operated Valves (MOV) will be rewritten to include reinstallation directions for MOV cables
' lifted to comply with Change No. 117.
(Details, Paragraph 3,a,(1)(c). 2)
(d) Disarm the auto /throwover feature of alternate power supplies No. 1 and No. 2 within 60 days.
(Details, Paragraph 3.a. (2)(a)2)
(e) To confirm the completion of the installation of Proposed Change No.117 modifications and verify that they cceply with the EDCR's, approved ~ drawings (expedited), and the quality assurance
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require =ents before."close of business" December 12, 1975. This
is'to include.the completion'of the applicable reviews of the
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i job orders and OP-5000.36 - attachments A, B, and C.
(Details,
- Paragraph. 3. a. (2) (d))
I 6.
The inspector reaffirmed the NRC's position that 3 loop operation is not permitted as per Proposed Change No.-125.
(Details, Paragraph 3.a(1)(b))
The licensee acknowledged the inspector's findings.
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DETAILS'
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Persons contacted
. Yankee Atomic Electric'Comnany-
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H. Autio,-Plant Superintendent R. Durfey, Assistant Maintenance Supervisor P. Laird, Maintenance-Supervisor J. Staub, Technical Assistanc'to'the Ilant Superintendent N. St. Laurent, Assistant Plant Superintendent J.-Thayer, Associate Engineer 2.
' General a.
Plant Status The plant was shutdown for refueling and maintenance.
b.
Purpose of the Inspection The purpose of this routine, announced inspection was to confirm
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that certain plant modifications and operating procedure changes-
.have been made to ecmply with the li=itations imposed by the Safety Evaluation of the Core XII ECCS Performance.
3.
Core XII ECCS Performance Safety Evaluation (SE)
a.
General (1) Operating Procedures Review i
(a)
SE Impacted Procedures
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The inspector reviewed those operating. procedures for the Yankee Rowe Nuclear Power Station that could have
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been affected by the SE limitations. The review was specifically directed-toward identifying misaligned valves and breakers, and to preclude the operator from entering a procedure or procedures at some point which could lead to noncompliance with the SE.
The review included the12000 series, Operation Procedures; the
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3000 ' series, Emergency Procedures; and selected 4000 series, Surveillance Procedures.
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The licensee presented 16 procedures for review that had been updated to comply with the SE._ The inspector identified 3 of these as having procedural or substantive typographical errors, which the licensee corrected.
The inspector examined. the balance of the plant.
l operating procedures which were applicable and found 3 additional procedures which were inconsistent with the SE.
These also were corrected by the licensee t
prior to the inspector leaving the site.
(b) Three Loop Operation
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The inspector observed, during the review of plant operating procedures, certain procedures which i= ply that 3 loop operation is possible. A review of the Technical Specifications proved that 3 loop operation
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is not prohibited (ref. Appendix
"A", page 5. paragraph
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2.b.(2) of the Te'chnical Specification),
The licensee presented a memorandum dated May. 14, 1975, which states, in part: "...part loop operation...would
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be permitted only if a full LOCA break spectrum is analyzed under these conditions....
The inspectog relayed this information to NRC, Region If
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The inspector <was then informed by the Regional Office that the " Proposed Change to the Technical Spe:ifications No. 125, Supplement 1 specifically prohibits 2 loop operation and that thisHis considered to be a requireren:
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The inspector transmitted this information to the
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licensee.
(c) Procedure Changes
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The licensee. stated that changes to the Annunciator Alarm Procedures, series OP-3600 to OP-3899, resultinc from imolementation of the SE would be conoleted
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by January 1, 1976.
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The licensee stated that OP-5101, " Maintenance
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of Motor Operated Valves" would be changed to
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reflect the installation procedures for electrical leads on those' valves affected by the SE.
3.
The licensee stated that a review of_the plant operating : procedures would be conducted by
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January.1, 1976, to remove references to 3 loop operation.
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(2) Modifications Review (a) Modifications Reauired to Meet Procosed Change No. 117, Supplement 3(b), 5 and 6 (EDCR 75-28) ::cvember 26, 1975 1.
The licensee developed the installation procedure OP-5000.36, " Installation of Modifications to
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Prevent Single Failure" to comply with the Engineer Design Change Request (EDCR) 75-28.
s OP-5000.36 includes a series ef attachments which address:
Attachment A - Modification to CH-MOV 522, 523, and 52
Series breakers installation and. trcnsi to Emergency Mo' tor Control'. Center
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(MCC) No. 1.
Installed 12,4/75
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Attachment B.--Modifications to Accumulator Relief
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Valves SI-SV-56 and 57.
Installed 12/6/75 Attachment C - Modifications to the charging pump control circuit redundant trip.
Installed 12/4/75 Attachment D - Modification to loop isolation and safety injection (SI) motor operated
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valves (MOV).
CS-MOV-533, 535, 536, 537, 538, 539 ; MC-MOV-301, 302, 309.
310, 318, 319, 325, 326.
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Attachment E - Modification to Emergency MCC No. 2, remove breakers to SI-MOV-1, 4, 22, 23, 24, 25, 46,-49 and CH-MOV 522.
At the-time of-che _ inspection, attachments A, 3.-and C had been installed but the supporting quality
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i-9-assurance documentation and management reviews had not been completed. Attachments D and E will be completed prior to the plant ascending to power.
2.
The inspector noted that the licensee had made provisions for racking out and locking the alter-nate pcwer supplies to No. 1 and 2 AutothrovcVer switches (ref. D.1d(9) of SE) but did not provide for removing the automatic transfer feature. The licensee's position being that it would be redundant to disarm the auto-transfer feature, contacted Mr. R Fitzpatrick, Electrical Instrumentation and Control Eranch, Tachnical Review, Nuclear Reactor Regulation, who inforced the inspector that it was not the intention to require the auto-transfer feature be disarmed at this time but that it should be accomplished within sixty days of the plants return to power.
(b) Hot leg Injection Modification EDCR 75-21 OP-5000.35, Installation of Hot Leg Injection System,
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dated November 22, 1975, i=plemented EDCR 75-21.
This modification provides for " Hot Leg Injection" to the reactor coolant systes during long term cooling to prevent excessive boric acid build up by diverting - a portion of the purification pu=p output into the suction of the charging pumps.
The inspector reviewed the weld data for EDCR 75-21, Ect Leg Injection Modification, and verified the welder's qualification for weld joint number 194-3, 3" schedule 10, 316L stainless steel pipe to coupling.
Welder identifi-cation number YR-7 was qualified to perform welding pro-cedure YA-WP-4 as required by the weld joint specification.
(c) Modification Drawings The inspector observed that two drawings associated with the modifications, described in paragraph 3.a(2)(a) above
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were stamped "Not Approved Copy."
To wit, drawing No.
9699-FE-90-1, titled " Wiring Diagram-Motor Control Center 1 - Rear Section" and drawing No. 9699-ESK-6AB, titled
" Hot Leg Injection Mod."
He also noted the revisien olocks did not reflect the modifications in progress nor were the~re sign'ature approvals. The licensee stated -
that these drawings were expedited through the,ormal i
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system because of the late notification of the
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required plant changes.
l This item is considered unresolved pending verification that the drawings were reviewed and approved in accord-ance with the licensee's procedures.
(d) Comoletion of SE Commit ents
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i The licensee stated that a canagement review of the
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quality assurance documentation and the drawings for EDCR's 75'21 and 75-28 would be performed to assure l
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that the modifications had been installed correctly and'
that they meet with the quality standards set forth in
the EDCR's, prior to power operation of the plant and
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close of business December 12, 1975. Also, because of the question raised 'concerning the drawings' being stamped
"Not Approved Copy"-(reference: paragraph b above) that a verification would be performed to assure the drawings were those intended for the modification.
This item is unresolved pending completion of management
reviews of quality assurance documentation.
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b.
Resolution'of SE Recuirements
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(1) Recuirement i.
The present Emergency Operating Procedures will be modified
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to eliminate the ECCS " cutback" mode of operaticn by valve i
manipulation (tripping pumps is acceptable).
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Resolution OP-3106, Loss of Main Coolant, revision 2, dated Dece=ber
5,.1975, now states in paragraph 8.: "After recirculation flow is verified, secure safety injection af ter a minimum of. 77,000 gal. of' safety injection water has been injected by shutting
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'down the operating safety injection pump."
(2) Requirement
During power operation, a.c. power will be removed from the
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following motor-operated valves with the valves in their
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normally opened position by removal of the circuit breaker from.the motor control: SI-MOV-1, SI-MOV-4, Si-MOV-22, SI-MOV-23, SI-MOV-24, SI.-M.O.V-25. SI-MOV-46 and SI-MOV-49
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Resolution OP-2652, Preparation of the' Safety Injection (SI) System for Normal Operation, revision 3, dated December 5, 1975,
. reads in part, in paragraph 27.d.: "Before the reactor
'is at power the following motor operated valve ACB's
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shall be removed from their MCC and the valve hand wheel
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' locked in-the position indicated....
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f SI-MOV'- 1 Ope.1 SI-MOV -'4.0 pen SI-MOV - 22 Open SI-MOV - 46 Open
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SI-MOV - 23 Open
'SI-MOV - 49 Open SI-MOV - 24 Open SI-MOV - 25 Open-
Attachment E of procedure OP-5000.36 (ref. 3.a.(2)(a)
above) addresses the initial removal and verification of this requirement.
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(3) Requ,irement Valves CH-MOV-522, CH-MOV-523, and CH-POV-524 will be
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rewired to a common circuit breaker tnd a second seriea
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breaker.will be installed. During power operation, a.c.
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power will be renoved from CH-MCV-522, CH-MOV-523, and CH-MOV-524 with Ch-MOV-522~ in its normally closed position and _ CH-MOV-523 and CH-MOV-524 'in their normally_ ope'ned
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position by^ opening both of the series breakers.
Resolution OP-2100, Plant Startup fica Cold Shutdown, revision 5, dated December 5, 1975, paragraph 38 reads: "Before the reactor
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is at power the following charging system valves will be positioned as indicated and both of their motor operated valve
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j series breakers will be in the open' position.
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CH-MCV-522 Closed
CH-MOV-523 open CH-MOV-524 open
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Both MOV series breakers open."
b Attachment A of procedure OP-5000.36 (ref. 3.a.(2)(a)
above) addresses the~ installation of the second, series j
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-12-(4) Requirement Using EICSS Branch Technical Position 18 as guidance, position indication for valves CH-MOV-522, CH-MOV-523, and CH-MOV-524 will be provided by rewiring, making the position indication features independent of breaker position. Valve positien indication-for these valves
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will be provided by operator monitoring of flow through flow indicator FI-2 and. in addition, valves CH-MOV-522 and CH-MOV-523 will be placed under periodic operator surveillcnce to verify their proper align =ent.
Resolution (a) OP-5000.36, attachment A (ref. 3.a. (2)(a) above)
which address the installation of the second, series breaker for valves CH-MOV-522, 323, and 524 also shews i
the installation of circuitry for the valve position indicators which are independent of the power to the valves.
(b) OP-4203, Weekly Valve Check, revision 5, dated December 5, 1975, requires the above listed valves be checked for position.
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(5) Recuirement During power operation, a.c. power will be removed from the following motor-operated valves with the valves in-their normally opened position by disconnecting the power cables as they leave the motor-starters: CS-MOV-533, CS-MOV-535, CS-MOV-536, CS-MOV-537, CS-MOV-538, CS-MOV-539, MC-MOV-301, MC-MOV-302, MC-MCV-309, MC-MOV-310, MC-MOV-318,
MC-MOV-319, MC-MOV-325, MC-MOV-326.
Resolution (a) OP-2652, Preparation of the Safety Injection System for Normal Operation, revision 3, dated December 5,1975, paragraph 35, states: "Before the reactor is at power the following motor operated valve power cables will be disconnected as they leave the motor starter and the valves will be locked in the position indicated."
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-13-CS-MOV-533 Open CS-MOV-538 Open C5-MOV-535 Open CS-MOV-539 Open CS-MOV-536 Open CS-MOV-532 Closed (see (6) below)
CS-MOV-537 Open
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(b) _ OP-2100, Plant Startup from Cold Shutdown, revision
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5, dated Decetber 5, 1975, reads, in part: "Eefore the reactor is at power, the power cables to the following motor operated valves will be disconnected as they leave the motor starter:
MC-MOV-301 MC-MOV-318 MC-MOV-302 MC-MOV-319 MC-MOV-309 MC-MOV 325 MC-MOV-310 MC-MOV-326 The position of the "MC" series valves is defined by the " Weekly Valve Check," CP-4203, which is a required step,, step 16, in OP-2100. This is prior to bringing the reactor critical.
OP-5000.36, attachment D, describes the initial removal
- of wiring leads to the above listed valves. This attachment was not scheduled to be accomplished until just prior to the plant ascending to power operatien.
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(6) Requirement During power operation, a.c. power will be recoved from motor-operated valve CS-MOV-532 with the valve in its normally closed
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position by disconnecting the power cables as they leave the
motor starter.
In addition, this valve will be per=1tted to
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be opened to provide the capability for mixing of the coolant
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in the Safe' y Injection tank on a monthly basis for a period ~
of approximately thirty minutes.
Resolution (a) The resolution of the disconnecting of the power cables and valve position is discussed in paragraph 3.b. (5) (a)
above.
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(b). OP-4204, Monthly Test or Special Operation of the Safety Injection Pumps, revision 4, dated December 5,1975, states, under " Precautions":
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"5. The maximum amount of time CS-MOV-532 may be electrically operable during safety injection tank recirculation or maintenance operation is 30. minutes on a monthly basis. "
(7) Requirement i
The control circuitry.to each of the accumulator pilot operated relief valves, SI-SV-56 and SI-SV-57, will be modified to include level switch contacts in each of the conductors to and from the valve solenoid operators..This
.will preclude 'a single failure from opening the accumulator relief valves before termination of the injection mode of operation.
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Resolution OP-5000.36, attachment. B, " Modification to Accu =ulator~ Relief Valves SI-SV-56 and 57" was completed December 6, 1975. This attachment references drawing 9699-ESR-6A3 which shows level
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switches in each of the conductors to the L.P.~ Tank relief valves.
(8) Requirement
In order to provide the required tripping function and meet
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the single failure criterion, the licensee has preposed to provide two series contacters - in the power supply circuitry to each charging pump. The "A" safety inj ection signal initi-ates a trip to one contactor while the "B" safety injection signal initiates a trip to the other contactor.
This modi-
.fication will assure that charging pump flew will.be provided to the hot legs only when required for normal charging and long term recirculation, and prevent hot leg injection during the injection phase of operation.
Resolution OP-5000.36, Attachment C, " Modification to Charging Pump
Control Circuits Redundant Trip" was installed on December 4, 1975. This attachment references drawing 9699-FE-4B,
" Elementary Diagram 480 V circuits" - sheet 2, which'shows a set of series contacts, each activated by separate Safety Injection signals WL-1 and WL l-1, in the motor power leads
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to each charging pump.
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(9) Requirement The licensee has proposed to rack out and lock the alternate Supply Br'eakers to No. l' and 2 autothrower Emergency MCC.
Resolution OP-2652, Preparation of the S1 System for. Normal Operation
'(ref. 3.b. (2) above) paragraph 27.b reads, in part:
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"b. Check the alternate power supplies to No. 1 and 2
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autothrowaver are deenergized and locked."
(10) Requirement.
... This will1be accomnlished hv diverting a cortion of the purification pu=p output into the suction of the charging pumps which will deliver the flow to the hot legs. A hot'
leg injection flow of 25.2 gpm is required
.o control the boric acid concentration in the core.
d We have reviewed the procedure and concluded that they will
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satisfactorily maintain the coneantration of boric acid in the core below the solubility limit provided that:
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(1) Power is disconnected to motor-operated valves CH-MOV-523 and CH-MOV-524 with the valves in their normally opened position to assure the delivery of the required het leg injectant, t.nd (2) The licensee utilizes existing flow metering instrumenta-tion for measuring and controlling the hot leg recircula-tion flow to' assure that the hot leg. recirculation ficw required'to control-the boric acid concentration in the core is provided.
Resolution a.
OP-2100, Step 38 (See 3.b. (3) above), addresses dis-
-connecting power to the MOV's.
b.~
OP-3106 (See 3.b. (1) above) Loss of Main Coolant, under
" Subsequent Action," paragraph 10.a reads, in part:
" Start one charging * pump... Verify >25.2 gpm flow to loop 4."
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(11) Requirement
... maintain the accumulator water level at a minimum of 700 f t3...
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Resolut ion The inspector read the level instrumentation _for the-
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accumulator which read.87%, where 86.6% is equal to
800 ft3 4.
Steam Generator Tube Failure OP-3107, Secan Generator Tube Failure, revision " Original," Dece=ber 5,1975, describes the actions to be taken in the event of tube failures in a steam generator. The inspecter observed that in step 6, of the procedure, it calls for closing the affected loop cain coolant stop valves and the safety injection valves which is contrary to the configuration required by the Safety' Evaluation for Core XII
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ECCS Performance. The closing of these valves is not'a procedural step in OP-3106, Loss of Main Coolant, for similar isolable LOCA's.
i This item is considered unresolved pending a determination that the
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valve changes required by OP-3107 do not constitute an unrevievel=
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safety question.
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