ML042080170
| ML042080170 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/26/2004 |
| From: | Hamer M Vermont Yankee |
| To: | Callaghan J, Devincentis J, Goodwin S, David Pelton, Beth Sienel NRC Region 1, Vermont Yankee |
| References | |
| CR-VTY-2004-00981, FOIA/PA-2004-0267 | |
| Download: ML042080170 (9) | |
Text
Sienel, Beth From:
Sent:
To:
Subject:
Hamer, Mike Monday, April 26, 2004 2:09 PM Devincentis, Jim; Goodwin, Scott; Callaghan, James; Pelton, David; Sienel, Beth PRO for CR-VTY-2004-00981 The attached PRO is for the discovery of a missing piece of shoot-out steel. This condition has been evaluated as "not reportable".
PRO-040981.pdf (275 KB)
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INTEROFFICE MEMORANDUM REGULATORY COMPLIANCE POTENTIALLY REPORTABLE OCCURRENCE REPORT TO:
MIKE DESILETS, TECHNICAL SUPPORT MANAGER FROM:
JIM DEVINCENTIS, MANAGER LICENG ING>7.
SUBJECT:
CR-VTY-2004-0981 A PIECE OF SHOOT-OUT STEEL NOT INSTALLED DATE:
APRIL 19, 2004 PRO NUMBER: PRO-040981 EVENT DESCRIPTION:
On April 9, 2004, during CRD change-out, an observation was made that a piece of the CRD Housing support shoot-out steel was missing. An investigation revealed that the piece was probably not*
.reinstalled during a prior outage. This support structure is required to be operable per TS 3.3.B.2 (attached).
The following 1 OCFR50.73 criterion was considered potentially applicable when determining reportability of this event:
Operation or Condition Prohibited by Technical Specifications
§50.73(a)(2)(i)(B) The licensee shall report "Any operation or condition which was prohibited by the plants Technical Specifications (TS) except when: (1) The TS is administrative in nature;(2)
The event consists solely of a late surveillance test where the oversight was corrected, the test was performed and the equipment was found to be capable of performing its specified safety function; or (3) The TS was revised prior to the discovery of the event such that the operation or condition was no longer prohibited at the time of discovery of the event."
DISCUSSION NUREG 1022, Rev. 2, page 37 (attached) provides additional guidance via an example of the extent to which conditions that are potentially applicable to this criterion should be reported. Example (4) discusses the identification of a component that was missing the required seismic restraint and concluded it would be reportable only if it was determined that the missing restraint caused the component to be inoperable.
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In this case, Mechanical/Structural Engineering evaluated the as-found condition with the subject missing clamp and determined, based on engineering judgment, that the shoot out steel would have performed its intended function (attached). Based on this, no safety related equipment was made inoperable by the condition.
Based on this, this event is not reportable under 10CFR50.73 (a)(2)(i)(B). There Is no corresponding 1 OCFR50.72 criterion.
CONCLUSION:
this event is not reportable under 1 OCFR50.72 or 50.73.
RECOMMENDED:
el lel VManager, Licensing APPROVED:
Mechal P. Desaets Date Technical Support Manager 2
VYNPS 3.3 LIMITING CONDITIONS FOR OPERATION 4.3 SURVEILLANCE REQUIREMENTS opebhe Control Rod Drive fHousing Support System shall be in place when the Reactor Coolant System is pressurized above atmospheric pressure with fuel in the reactor vessel unless all operable control rods are
- 3. While the reactor is below 20% power, the Rod Worth Minimizer (RWM) shall be operating while moving control rods except that:
(a) If after withdrawal of at least 12 control rods during a startup, the RWM fails, the startup may continue provided a second licensed operator verifies that the operator at the reactor console is following the control rod program; or (b) If all rods, except.
those that cannot be moved with control rod drive positive coupling and the results of each test shall be recorded. The drive and blade shall be coupled and fully withdrawn.
The position and over-travel lights Housing Support System shall be inspected'after reassembly and the results of the inspection record.
- 3. Prior to control rod withdrawal for startup the Rod Worth Minimizer (RWM) shall be verified as operable by performing the following:
(a) Verify that the control rod withdrawal sequence for the Rod Worth Minimizer computer is correct.
I (b) The Rod Worth Minimizer diagnostic test shall be performed.
Amendment No. -9, 4.49, 196 83
I If the discrepancies are large enough that multiple valves are Inoperable the event may also be reportable under § 50.73(a)(2)(vii) 'Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent trains or channels to become inoperable in a single system....
(4) Seismic Restraints Assume it is found that an exciter panel for one EDG lacked appropriate seismic resrit a
since the plant was constructed, because of a design, analysis, or construction inadequacy. Upon evaluation. the EQG is determined to be inoperable because it is not capable of performing its specified safety functions during and after an SSE.
An LER would be required because the plant was5 outside of its design basis-the EQGwa
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inoperable for a period of time longer than allowed by TS.
U6 Vulnerability to Loss of Offsite Power Assume that during a design review it is found that a loss of offsite power could cause a loss of instrument air and, as a result. auxiliary feedwater (AFW) flow control valves could fail open. Then for low steam generator pressure. such as could occur for certain main steam line breaks, high AFW flow rates could result in tripping the motor driven AFW pumps on thermal overload. Therefore, the motor-driven AFW pumps are determined to be inoperable. The single turbine driven AFW 1ump is not affected.
An LER would be required because the motor-driven portion of AFW was inoperable for a period of time longer than allowed by the technical specifications.
3.2.3 Deviation from Technical Specifications under § 50.54(x)
§ 50.72(b)(1)
§ 50.73(a)(2)(i)(C)
' any deviation from the plant's
- Any deviation from the plant's Technical Specifications authorized Technical Specifications authorized pursuant to § 50.54(x) of this part."
pursuant to § 50.54(x) of this part."
An
.E sr q i e o e i to u h rz d pu s a tt e to 0 5 ( )
fn tr p re An LER is required for a deviation authorized pursuant to Section 50.54(x). If not reported under § 50.72(a), an ENS notification is also required.
Discussion 10 CFR 50.54(x) generally permits'licensees to take reasonable action in an emergency even though the action departs from the license conditions or plant technical specifications if.(1) the action is Immediately needed to protect the public health and safety, including plant personnel, and (2) no action consistent with the license conditions and technical specifications is 37 NUREG-1022, Rev. 2 M-kid$.'-'.
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I w:_
U There is a connecting rod (or long bolt) that connects the crab to the clam shell.
After you remove the rod and the crab and clam shell, you can then remove 2 bars or "steel".
The Support Bars are not removed and the nuts that are threaded on the Support Rods are not adjusted.
CRAB 1
LOWER H Bar or "Steel" Support Nuts Support Bar SUPPORT BARS (REMOVABLE ONE SECTION AT Figure 1-5.
Lower Control Rod Drive Housing 1-14
Devincentis, 'Jim From:
Goodwin, Scott Sent:
Saturday, April 1D, 2004 4:46 PM To:
Devincentis, Jim Cc:
Callaghan, James; Meyer, Jeff; Hamer, Mike; Wanczyk, Robert; Daflucas, Ronda; Oliver, Bob; O'Connor, Tom; Todd, Jon; McKenney, Mike
Subject:
RE: Shoot out steel Spoke with Jon Todd today regarding extent of condition related to this issue. Jon said that it is limited to one Clamshell piece associated with a CRD housing that was not worked this outage. Therefore, the missing piece has been missing for some indeterminate period.
See enclosed figure depicting configuration. The shootout'steel is a latticed assembly supported by rods that have
'Incorporated stacked disc springs into them; The assembly functions to resist the downward loads generated as a result*
of a' postulated full circumferential break of a'CRDHousing at fullpower operations. -The Clamshell is centered'beneath the Crab on the short Steel Bars that run between the Support Bars and Rods: The Clamshell includes a single bolt that
.protrudes through it from-the underside and engages the Crab. Both the Clamshell and the Crab are configured with a notch, or recess, to fit snug across adjacent pieces of the Steel Bars to align the shootout steel as a lattice and to vertically align the CRD Housings. Based on the input received from Jon, the Clamshell was missing but the Crab was in place, engaged across the adjacent Steel Bars and performing its alignment function for the lattice assembly and CRD Housing positioning. Since the forces resultant of a postulated rupture of a CRD Housing are transferred directly to the structural framing (Steel bars, Support bars and Rods) making up the lattice/rod assembly and since that load transfer is not affected
- with the Clarmshell alone being found missing, the prior function of the shootout steel remains assured.
- -Jon has discussed his intent for obtaining a replacement Clamshell and has initiated discussion with Procurement to buy.
br fabricate'a replacement piece to re-install where the missing one was found. '
Based on my conversatio-with Jon, I believe this e-mail satisfies the EDM log item, number 59, and it cah be closed.
shootout steel.df
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Scott Goodwin ENVY Design Engineering
'MechanicaVStructural This e mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any*'
disseminati6n, distribution, or copying of this -mail and anj attachments thereto is strictly prohibited.. If you have reiceived this e-mail in error,' please notify me and permanently delete the original and ary copy of any e-mail and any printout thereof.
-OriginalhMessage-From: Goodwin, Scott Sent: Friday, April 09, 2004 7:56 PM To: Devincentis, Jim Cc: Callaghan, James; Meyer, Jeff; Hamer, Mike; Wanczyk, Robert; Daflucas, Ronda; Oliver, Bob; O'Connor, Tom
Subject:
RE: Shoot out steel Tend to agree that if missing piece Is isolated to a single clam shell and upper crab piece was still present. We are still awaiting Input from Maint Support as to the extent of missing steel and what steel it was. Turnover day-to-night has occurred between TU'C and Bob 0.
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Scott Goodwin ENVY Design Engineering Mechanical/Structu ral This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution, or copying of this e-mail and any attachments thereto is strictly prohibited. If you have received this e-mail in error, please notify me and permanently delete the original and any copy of any e-mail and any printout thereof.
-Original Message-From: Devincentis, Jim Sent: Friday, April 09, 2004 3:26 PM To: Goodwin, Scott Cc: Callaghan, James; Meyer, Jeff; Hamer, Mike; Wanczyk, Robert; Daflucas, Ronda
Subject:
Shoot out steel Scott-I saw the CR on the missing piece of shoot-out steel. Since this is a potential LER (condition prohibited by TS 3.3.B.2) I will need an assessment of impact on past functionally. I believe it will not be reportable f we.
can say it was functional. My sense in looking at some pictures with BC is that it will not impact functionally I'll need you to agree.
I understand that the eng duty mgr has been asked to assess.
Please keep rme Informed.
Jim.
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