IR 05000309/1992001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-309/92-01

ML20198D669
Person / Time
Site:	Maine Yankee
Issue date:	05/11/1992
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Frizzle C Maine Yankee
References
NUDOCS 9205210109
Download: ML20198D669 (3)

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NAY 111992

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. Docket No. 50-309 Mr. C. ;

- President

~ Maine Yankee Atomic Power Company -

83 Edison Drive Augusta, Maine. 04336

Dear Mr. Frizzle:

SUIMECT; INSPECTION NO. 50-309/92-01 This i

_., to your letter dated April 15, 1992, in response to our letter dated March 17, 1992.

U-Thank you for informing us of the corrective and preventive actions documented in your letter.

These actions will be examined during a future inspection of your licensed program.

~.-In regard to your re_ quest for a meeting to discuss use of and adherence to instructions for safety related activities,' we will contact you in the near future to arrange a mutually agreeable time.

Your cooperation with us is appreciated.

Sincerely, L

Original Signed By:

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James C. Linville; Chief Projects Branch No. 3 Division of Reactor Projects

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I OFFICIAL RECORD COM-nan 0no Il

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MAY 111992 M r. C. D.1,n.zzle

cc:

G. D. Whittier, Vice President, Licensing and Engineering Vice President, Operations P. L. Anderson, Project Manager (Yankee Atomic Electric Company) (w/cy of Licensee's Response Letter)

J. D. Firth, Vice President, Public and Governmental Affairs S. E. Nichols, Manager, Nuclear Engineering and Licensing R. W. Blackmore, Plant Manager J. A. Ritsher, Attorney (Ropes and Gray) (w/cy of Licensee's Response Letter)

P. Dostie, State Nuclear Safety Inspector (w/cy of Licenste's Response Letter)

Peter Brann, Assistant Attorney General (w/cy of Licensee's Response Letter)

U. Vanags, Maine State Planning Office (w/cy of Licensee's Response Letter)

C. Brinkman, Combustion Engineering, Inc. (w/cy of Licensee's Response Letter)

First Selectmen of Wiscasset (w/cy of Licensee's Response Letter)

l Maine State Planning Officer (w/cy of Licensee's Response Letter)

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Public Document Room (PDR) (w/cy of Licensee's Response Letter)

Local Public Document Room (LPDR) (w/cy of Licensee's Response Letter)

Nuclear Safety information Center (NSIC) (w/cy of Licensee's Response Letter)

NRC Resident inspector (w/cy of Licensee's Response Letter)

State of Maine, SLO Designee (w/cy of Licensee's Response Letter)

OFFICIAL RECORD COPY

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MAY 111992 Mr. C. bec w/cy of Licensee's Response Letter:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRS SALP Coordinator DRSS SALP Coordinator J. Linville, DRP W. Lazarus, DRP C. Marschall, SRI - Maine Yankee H. Eichenholz, SRI - Vermont Yankee E. Trottier, LPM, NRR W. Butler, NRR Rl(; RP RI:0,RP RI:DRP (

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Mar hall /meo lifkrrs LiklviJle 3/l'l/92 gf@'

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OFFICI AL, RECORD COPY A: REP 9201.MEO

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MaineYankee

. StELIABLE ELECTAiCITY MR VA!NE SINCE 1972 -

EDISON DRIVE e' AUGUSTA; MAINE 04330.(207) 622-4668 April 15,-1992

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MN-92-39 SEN-92-123 UNITED STATES NUCLEAR REGULATORY COMMISSION l Attention: : Document Control Desk Washington,r DC :20555-Reference:

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

(b).USNRC Letter 'to MYAPCo dated March 17, 1992 -- Resident-Inspection 50-309/92-01 a

Subject:

Inspection 92-01: = Response to-Notice of Violation Associated.with the

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Replacement of the Feader Breaker from Bus 14 to Motor Control Center 14A Gentlemen:

Attachment A to this letter responds to the Notice of Violation contained in Reference - (b).

In-this attachment, w3 have restated the violation, provided our-

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response,.and have addressed our actions-taken and planned to prevent recurrence.

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This-inspection report also discussed the use of and adherence to instructions for-control ofl safety-related activities.

We would appreciate the opportunity to discuss this matter with the;NRC at your earliest convenience.

Please contact-us should you.have any. questions regarding this-matter.

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Very truly yours,

.S, E. Nichols, Manager Licensing & Engineering Support Department SEN/sjj'

Attachment l Mr. -Thomas-T. Martin /

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Mr.; Charles S. Marschall'

Mr. E. H. Trottier Mr.' Patrick J. Dostie

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__T_TACMMENT A-A

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' Notice of Violation:

l10 CFR 50.59 requires,-in part, that the holder of a license may make changes

inithe facility as described in the safety analysis report unless the proposed

' change involves an = unreviewed ? safety question.

The licensee shall maintain records of changes-it the facility. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to'the above, on February 9,1992, plant personnel replaced the feeder

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breaker from bus 114 to Motor Control Center 14A, part of the electrical distribution _ system described in the safety analysis report, with a breaker of different capacity without performing a safety evaluation to determine that-the change did-not involve an unreviewed safety question.

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-Maine' Yankee Response:

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As described in the inspection report on February 9,1992 Maine Yankee planned'

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to perform pre-outage maintenance on bus 13.

To support this activity, Maine Yankee. conducted a load analysis on Motor Control Center (MCC) 13A and MCC 14A.

-The maximum-amperage calculated for the feeder (supply) bresker from bus 14 to MCC-14A was 415 amps in the ' cross tied configuration and the normal rating for

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this breaker is 420 amps.

Electrical engineering was requested to perform an evaluation to support the-temporary changing of the feeder breaker trip setpoint from 420 amps-'to a 600 amp setting to prevent an inadvertent breaker trip.

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The engineer performed an engineering evaluation on increasing the _ feeder breaker trip setpoint. This engineering evaluation included an assessment of the feeder cable ampacity and considered the feeder breaker coordini. tion with-the bus 14 supply breaker. The engineer concluded that the temporary breaker change / replacement. was acceptable provided the feeder cable insulation temperature and load amps were monitored. This would ensure-that the loading on_the feeder cable would not cause the temperature of the-cable insulation to exceed the design _rr 19 of 90*C, thereby assuring that the cable would not be

degraded. The insulation resistance of the feeder cable was also to be checked

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Lin.a subsequent preventative maintenance activity.

Maine Yankee controls the performance of maintenance under Procedure 0-16-3 (Rev. 6), Work Order Processing. _In thi.s procedure, maintenance on safety-class and selected NNS equipment; and changes to an equipment setpoint or range that is ; noticovered ' by _a' specific Class A procedure _is characterized as - Level I

maintenance. By procedure, level I maintenance receives an engineering review.

Engineering review and approval of work order technical and functional test

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instructions is performed-in accordance with-Attachment D of Procedure 0-16-3, Plant' Engineering Department (PED) Review and Approval of Technical and Functional Test Instructions.

Under Section D.II.e of Attachment D, the engineer is directed to " identify proposed modifications and ensure compliance with the additional requirements of Section III (of -this Attachment)" which includes setpoint/ range changes, facility upgrades, and on-line temporary modifications or temporary repairs of Safety Class components. Should the activity fall into one of those categories, the procedure requires the following controls:

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Work Order

Technical Instructions or Installation Instructions

F.inctional Test instruction (if applicable)

Technical Evaluation

Work Order to Correct Temporary Repair

i The engin9er involved with the breaker maintenance activity failed to recognize that the breaker substitution would amount to a breaker setting change which would fall under the "setpoint/ range changes" or a " temporary modification *

criteria of 0-16-3.

Once identified, the engineer would be directed to the Technical Evaluation Procedure (17-226) which includes a requirement for conducting a 10 CFR 50.59 screening evaluation.

A 10 CFR 50.59 Determination, in accordance with Procedure 0-06 # (Dev. 4),10 CFR 50.59 Determintion, would then be required if the results of the screening so dictate.

In addition to the procedural path described above, Attachment D of Procedure 0-16-3 also directs the engineer to Procedure 0-14-2 (Rev. 12), Temporary Modification Control, for any work that is considered a temporary modification.

Proceiure 0-14-2 also includes the requirement for a 10 CFR 50.59 Determination.

In summary. Procedure 0-16-3 provides the directica and criteria for engineering personnel to either perform a Terhnical Ec41utm:n in accordance with Procedure 17-22o or use a temporary modification in accordance with Procedure 0-14-2.

Both procedures provide the procedural guidance that will ensure a 10 CFR 50.59 Determination is addressed or rerformed when appropriate.

l Maine Yankee believes that the e/isting administrative controls are adequate to properly control and evaluate circumstances of this type. The root cause of the failure to perform a 50.59 screenicg was an error in judgment on the electrical engineer's part.

Immediate Corrective Actions and the Relult s Achieved:

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Toa feeder breaker from bus 14 to MCC-14A was returned to its normal 420 amperage trip setpoint before re-energizing thereby restoring the breaker to the original condition.

The electrical engineer is in the process of writing a technical evaluation to formally document the engineering evaluation and veify that this activity did not involve an unreviewed sa.~ety question.

d Corrective Actions Taken to Avoid Further Vi slation:

The engineer involved was counselled on the need to consider work in process when evaluating maintenance activities for possible impact on the systems, components aqd structures described in the FSAR.

Engineering management discussed this matter with department personnel and concluded this to be an isolated event, and that no procedural modifications were necessary.

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Full Comoliance Date:

Full con.pliance was achieved when the original feeder. breaker with tha 420

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amperage trip setpoint was reinstalled and energized on February 10, 1992 at approximately 0406.

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