ML19352A846
| ML19352A846 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/30/1981 |
| From: | Randazza J Maine Yankee |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19352A844 | List: |
| References | |
| FMY-81-49, NUDOCS 8106020213 | |
| Download: ML19352A846 (3) | |
Text
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2.C.2.ll NO PO AUGUSTA A NE 6
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(207) 623-3521 O
March 30, 1981 FMY 81-49 United States t4Jclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Mr. Boyce H. Grier, Director
References:
(a) Licnese No. DFR-36 (Docket No. 50-309)
(b) UStRC Letter to MYAPC cated February 70, 1981 Inspection 50-309/80-19
Subject:
Response to IE Inspection 50-309/80-19
Dear Sir:
In reply to Refercqce (b), the following information is hereby submitted.
ITEM Ci NONCOMPLIANCE As a result of the inspection conducted on December 1-26, 1980 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the following violation was identified:
10 CFR 50.59 states in part, "The holder of a license...may (i) make changes in the facility as described in the safety analysis report...without prior commission approval, unless the proposed change involves...an unreviewed safety question. Further, 10 CFR 50.59 requires the licensee to maintain records of changes in the facility, which include written safety evaluations which, provide the basis for the determination that an unreviewed safety question is not involved.
Technical Specification (TS) 5.5. A.6.d states in part, "The Plant Operation Review Committee (PORC) shall be responsible for... Review of all proposed changes to plant systems that affect nuclear sa fety".
TS 3.6.A.2 requires one operable ECCS train whenever the reactor 1
coolant system temperature and pressure exceed 2100F and 400 psig.
Contrary to the above the reactor coolant system temperature and pressure were taken above 2100F and 400 psig on Decemoer 15, 1980, without an operable ECCS train, since both ECCS trains contained valves whose stroke times exceeded Final Safety Analysis specified values and the licensee had not made a determination based on a written safety evaluation that no unreviewed safety question was involved, nor had the PORC reviewed the proposed change.
8106 02 0 k]
United States M; clear Regulatory Commission March 30, 1981 Attention: Mr. Boyce H. Grier, Director
RESPONSE
Investigation into the_ events of December 15, 1980 which led to this Item of Noncompliance reveals the following pertinent information.
1.
Amendment 35 to the Maine ' ankee FSAR dated July 27, 1972 states in part Y
in Paragraph 6.2.3.4 "The motor operators automatically drive the valves to the full open position in less than 13 seconds following the SIAS.
2.
This Mended statement was not entered in Paragraph 6.2.3.4 of the copy of the FSAR in the control room on December 15, 1980.
3.
The Maine Yankee Cycle 5 reload analysis assumed a opening time of SIAS plus 10 seconds in the Steam Line Break Accident Analysis, based upon valve specification.
This value was used to determine the acceptability of Baron delivery times. For LOCA analysis SIAS plus 30 seconds is the assumed opening time.
4.
Upon receipt of the results of ECC injection valve tests on 12/15/80, it was determined that the opening times experienced would not affect the Boron delivery times assumed in the cycle 5 analysis by those responsible for the analysis.
The evaluation that no change was necessary to the plant or the safety analysis and thus no unreviewed safety questions existed was relayed to the Plant Operations Supervisor and the Plant Manager prior to raising temperatures above 2100F.
This evaluation result was documented in a memorandum cated December 16, 1980.
5.
The Maine Yankee Technical Specification makes no mention of valve opening times as a criteria for ECCS systems operability.
Based upon the above information the reactor coolant system temperature and pressure were not taken above 2100F and 400 PSIG without an operable ECCS train. Since no changes to the plant or analysis are required, no written Safety Analysis is necessary.
It is hereby requested that this item of non-compliance be withdrawn.
- o United States toclear Regulatory Commission March 30, 1981 Attention: Mr. Boyce H. Grier, Director We trust this information is satisfactory. Should you have any further questions, please feel free to contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY
,l h M 5y.
J.
B.' Randazza Vice President, Operations STATE OF MAINE
)
)ss COUNTY OF KENNEBEC)
Then personnally appeared befcre me, J. B. Randazza who, being duly sworn, did
' state tnat he is a Vice President of Maine Yankee Atomic Power Company, that he.is duly authorized to execute and file the foregoing request in the name and on the behalf of Maine Yankee Atomic Power Company, and that the statements thardin are true to the best of his knowledge and belief.
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CN Notary Public M$ggmenSSW EXMRSD 30003T 8. '.937.
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