ML20010A626
| ML20010A626 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/13/1981 |
| From: | Randazza J Maine Yankee |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20010A618 | List: |
| References | |
| FMY-81-104, NUDOCS 8108110616 | |
| Download: ML20010A626 (5) | |
Text
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July 13, 1981 FMY 81-104 United States tAJclear 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 tb. OPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPC dated June 19, 1981 Inspection 50-309/81-12
Subject:
Response to IE Inspection 50-309/81-12
Dear Sir:
In reply to Reference (b), the following information is hereby submitted.
ITEM OF NONCOMPLIANCE 1.
Technical Specification 5.8.1.a states, in part, " Written procedures shall be established, implemented and maintained covering...the applicable procedures recommended in Appendix "A" oi Regulatory Guide 1.33, tbvember 1972".
Regulatory Guide 1.33, Appendix A, Paragraph C.8.a, requires that instructions for maintaining containment integrity be prepared.
I 10CFR50, Appendix B, Criterion II, states, in part. "The applicant shall establish...a quality assurance r!ogram which complies with the requirements of this Appendix".
The Maine Yankee Operational Quality Assurance Program states, in Section II.C, " Establishment of an effective Operational Quality Assurance Program l
1s assured through conformance with the ANSI Standards...specified in this section of the QA Program.. 2. ANSI N18.7-1976.
ANSI N18.7-1976, Section 5.2.11, states, "The program shall provide measures to ensure that conditions adverse to safety...are promptly identified and corrected".
Contrary to the above, the program established for maintaining containment integrity did not provide measures to ensure prompt identification and correction of containment leak rate in excess of the Technical Specification 3.11. A limit of 0.15 weight percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 50 psig.
8108110616 810806 PDR ADOCK 05000309 G
F M AINE Y ANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission.bly 13, 1981 Attention: Mr. Boyce H. Grier, Director As a result, from April 8, 1981 to April 17, 1981, a containment leak rate equivalent to an average of 0.32 weight percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 50 psig existed.
This is a Severity Level IV Violation.
(Supplement I.D.3)
RESPONSE
Supplement I.D.3 to the Interim Enforcement Policy, 45 FR 66754, defines this Severity Level IV Violation as a " Failure to meet requirements not covered in Severity Levels I, II, or III that measurably degrades the safety of operations, incident response or the environment".
Maine Yankee hereby objects to the severity level into which this occurrence has been categorized, as contrary to the above. At no time did Maine Yankee " fail to meet requirements," and at no time was the safety of operations, incident response or the environment measurably degraded.
The Notice of Violation attached to your letter of June 19, 1981, and quoted above, incorrectly states the limit of Technical Specification 3.ll.A.
This specification actually states that "The reactor shall not be critical if the known containment leak rate is greater than that equivalent to 0.15 weight percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 50 psig" (emphasis added).
As can be seen from a review of this event, no containment leak, of any magnitude, was known to exist until April 17.
Further, the actual magnitude of the leak was never measured.
It was conservatively calculated to have been in excess of the Tech. Spec. 3.11. A value several hours after it had been isolated.
Thus, the reactor was never critical with a known containment leak rate in excess of Specification 3.ll.A.
The Specification was, therefore, never violated and we object to the inference that it was.
Further, it is questionable whether Specification 3.ll.A applies to this situation.
The basis for Tech. Spec. 3 ll. A states that the leakage rate of 0.15 weight percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 50 psig represents a limit which assures that public exposure will be maintained within acceptable limits for a hypothetial Major Loss of Coolant Accident.
The location of the subject leak was external to the Containment Isolation Trip Valves. Thus, during the hypothetical accident situation to which this specification limit is applicable, this leak would not have existed at all.
A review of the design description of the containment weight of air monitoring system in the Maine Yankee FSAR shows that it is a very sensitive system designed to accurately determine containment leakage rates over long periods of time, typically 60 days.
The same features that make this system sensitive to very small leak rates also makes it susceptible to spurious false indications.
The total drop in containment weight of air from the time the valve was left open, to the time it was
MAINE YANKEE ATOMIC POWEf? COMPANY United States Nuclear Regulatory Commission & ly 13, 1981 Attention: Mr. Boyce H. Grier,, Director discovered and closed, amounted to less than 500 lbs.
In applying the weight of air calcualtion, this is equivalent to a change of 20F in average containment temperature or 0.1 in. Hg change in containment pressure. There are many examples of changes in the containment weight of air plot caused by temperature, humidity, or pressure fluctuations, measurement inaccuracies, instrument failures or operating transients.
From April 3 to 8 the containment weight of air plot fluctuated widely due to changes in the CEDM cooling fan
.ignment and the effect of this on temperature input to the computer. The weight of air plot dropped more or less steadily from April 8-13.
However, the drop was not recognized as a leak because of the previous CEDM cooling problem, and the past overall history of the system. From April 13-16 the plot hovered around the notification point. However, engineering personnel were not notified because of the previous weeks history and the appearance that the plot was stabilizing. On April 17, with two consecutive data points below the notification line, engineering personnel and the STA were notified. While the engineering investigation was in progress, the leak path was discovered and isolated.
The available data was subsequently reviewed and the leakage rate conservatively calculated to be in excess of the Tech.
Spec. 3.11.A value.
(0.15 weight percent per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 50 psig).
It is evident from the above discussion that none of the criteria for a Severity Level IV Violation, as defined in Supplement I to the Interim Enforcement Policy, applies to this event.
In fact, since there was no violation, none of the Interim Enforcement Policy severity levels apply.
Maine Yankee also points out that its predecessor Yankee companies did much of the pioneering work in developing the on-line leakage monitoring system.
It was voluntarily added to the Maine Yankee des!.gn at additional cost to orovide an added measure of safety assurance. tbt all PWR's have such a system and a minor leak such as was experienced at Maine Yankee may have gone undetected for a much longer period of time.
Tne enforcement criteria should not be applied so as to dissuade utilities from incorporating safety improvements into their designs.
Notwithstading the above, Maine Yankee has begun incorporating changes in the containment leakage monitoring system and associated administrative controls that we believe will improve system reliability and result in earlier detection and correction of leaks.
a.
Operations personnel were reminded of the importance of bringing anomalies in the containnent weight of air plot to the attention of engineering personnel by memo dated April 28, 1981.
b.
The containment weight of air plot maintained by the operators will be reviewed on a weekly basis by Engineering Personnel.
This review will commence upon establishment of containment integrity following the current refueling outage.
.-----------_------.-__------__.----___--____J
MAINE YANKEE ATOMIC POWER COMPANY United States MJclear Regulatory Commission July 13, 1981 Attention: Mr. Boyce H. Grier, Director c.
The procedure for determining containment weight of air will be modified to include more specific criteria for notifying engineering personnel for evaluation of anomalies. These revisions will be implemented by October 1, 1981.
d.
An evaluation of the program for determining leakage will be performed by Engineering personnel to ensure that provisions are made for d..tecting leakage within as short a time span as is consistent with the sensitivity and accuracy of the containment weight of air measuring system. This evaluation will be completed by October 1, 1981.
ITEM OF NONCOMPLIANCE 2.
Technical Specification 5.8.1.a states, in part that, " Written procedures shall be established, implemented and maintained covering...the applicable procedures recommended in Appendix "A" of Regulatory QJide 1.33, November 1972". Regulatory Guide 1.33, Appendix A, Paragraph J, " Chemical and Radiochemical Control Procedures," requires that procedures be written to prescribe the nature and frequency of sampling and analyses.
I Contrary to the above, a temporary sampling device was installed on February 21, 1981 and samples of containment air were obtained on April 7 and 8, 1981 without procedures established and implemented for these evolutions.
This is a Severity Level IV Violation.
(Supplement I.D.3)
RESPONSE
Again, Maine Yankee hereby objects to the severity level into which this occurrence has been categorized.
A review of the cited referencs 3, pecifically Regulatory Guide 1.33, reveals that while it is true tnat procedures must be written to prescribe the natura and frequency of sampling and analyses, such procedures a:e only required for surveillar.ce tests, inspections or callbarations required to be performed by Technical Specifications. The tests being conducted via the subject temporary sampling device were not tests that were required by Technical Specifications.
Therefore, no specific requirement was violated and, again, the criteria for a Severity Level IV Violation are not applicable nor are any of the Interim Enforcement Policy severity levels applicable.
Nonetheless, recognizing the fact that formal written procedures could serve to lessen the probability of a reoccurance of this type of event, Maine Yankee is taking the following actions:
MAINE VARKEE QTOMIC POWER COMPANY o
b l
United States tbclear Regulatory Commission July 13, 1981 Attention: Mr. Boyce H. Grier, Director a.
The Maine Yankee Design Change & Alteration Procedure shall be revised to ensure that any modification of any system that could potentially result in the release of radioactive gas or liquid shall be accomplished under either (a) a formal Plant Aleration, or (b) an appropriately approved procedure which specifically addresses Final Conditions.
l b.
Operation of installed systems that could potentially result in the release of radioactive gas or liquid for the purpose of obtaining samples shall be accomplished pursuant to an appropriately approved procedure.
Maine Yankee herewith requests that on the basis of this response that the Notice of Violation be withdrawn or modified. Should you have any further questions or require additional information, please feel free to contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY v
J. B. Randazz 4
Vice President, Operations JBR/bjp STATE OF MAINE
)
)ss COUNTY OF KENNEBEC)
Then personnally appeare d before me, J. B. Randazza, who being duly sworn, did state that he is 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 therein are true to the best of his knowledge and belief.
/Wd W6 (W
Notary Publigg E6 L. #A rc fp ; <gjer
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