ML20029A880
| ML20029A880 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/22/1990 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20029A871 | List: |
| References | |
| GDW-90-31, MN-90-11, NUDOCS 9103050047 | |
| Download: ML20029A880 (6) | |
Text
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MaineYankee 4psIJipkyh lO]QGpgyKu :
Edison DR!VE
- AUGUSTA. MAINE 04336 * (20D 622 4606 January 22, 1990 MN-90-ll GDW-90-31 Region 1 UNITED STATES NULLEAR REGULATOP.Y COMMISSION 475 Allendale Rosd King of Prussia, PA 19406 Attention: Mr. William I. Russell, Regional Administrator
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b)
USNRC Letter to Maine Yankee dated December 13, 1989, Inspection Report No. 50-309/89-20 (c) USNRC Letter to Maine Yankee dated March 13, 1986, Technical Evaluation Report of Maine Yankee Conformance to Regu13 tory Guide 1.97 (d) Maine Yankee Letter to USNRC dated February 28. 1985 (MN 43), Regulatcry Guide 1.97 Report
Subject:
Response to Notice of Violation and Notice oi Deviation Inspection Report No. 50-309/89-20, Design Changes Gentlemen:
This letter responds to the Notice of Violation and Notice of Deviation contained in Reference (b).
For completeness, we have restated the violation and deviation with our responses foilowing.
Our response is attached.
Should you have any questions on this matter, please contaut us.
Very truly yours, hA0hY0 5'
ho NOch000bobo9 G. D. Whittier, Manager O
PDR Nuclear Engineerirg and Licensing GOW:SJJ
Attachment:
Response to Notice of Violatten and Deviation c:
Mr. Eric J. Leeds Mr. Cornelius F. Holden Document Control Desk Gos9031.LTR
's ATTACHMENT NOTICE OF VIOLATION I The Maine Yankee Atomic Power Company Technical Specification, Section 5.8.1 1
states in Part, "that written procedures shall be established, implemented and maintained covering the test activities of safety related equipment....."
The Quality A surance Policy for Maine Yankee,Section XI states, in part, "that measures be t:iken to establish a test program to demonstrate that systems and components will perform satisfactorily in service....."
The Quality Assurance Implementing Procedure No. 0-11-1, Revision 0, states in Part, "that functional tests shall be performed to verify that a system or component which has been changed or repaired satisfies the specified design /f unctional requirements..... "
Contrary to the above, on October 25, 1989, the inspectors identified that the design document, EDCR-89-802, contained an inadequate functional test of the component cooling outlet valves to the RHR heat exchangers (PCC-M-43, SCC-M-165).
The functional test did not verify that these valves would open during accident conditions.
MAINE YANKM RESPONSE Maine Yankee requests reconsideration of this item.
Functional testing was performed following the modifications to the component cooling outlet valves to the RHR heat exchangers (PCC-M-43 and SCC-M-165).
This testing was adequate to verify tht.t the modifications satisfied specified design' and~ functional-requirements.
The post modification testing was nr.c 11 tended to verify component or system design-and functional requirements whi.h were not affected by the modification.
.S' We do not believe that there is_any.MC requirement that post modification testing vEriTi desNP:leAturECnot affected oy tfie miliifiHtTinZ Tolo so in this case wolu OtrEVe necenitated a plant ~ shutdown orTeTiT~of improvements the NRC had
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urged us to complet0 as soon as possible.
The modifications to SCC-M-165, which were installed to resolve a concern raised by the NRC's Safety System Functional Inspection (SSFI) team, included installation of a mid-span gnde to reduce reach rod deflection and modifications to the motor operator limit switch arrangement to improve operational control.
The mid-span guide was inspected during the post modification functional test to determine if the guide introduced any additional frictional loads from contact i
i with the reach rod.
Minimum contact was noted and the shaft could be easily l
recentered with slight finger pressure. We feel that this check was adequate to ensure the mechanical drive function iemained fully operatle and this judgment has subsequently been verified through M0 VATS testing.
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.. The modificati'ns did not affect the operabilit' of the valves with the exception of the control circuit associated with the lir.t switches. The limit switch circuits were tested subsequent to the modifi,ations to assure proper operation.
The valves were tested in the opening and cl; sing directions and also with a simulated RAS signal.
In addition, the valves were stroke tested in accordance with the IST surveillance procedure which verifies proper operation cf the valves at pre-established plant conditions.
Motor current data and reach rod deflection measurements were obtained and evaluated.
During this evaluation, M0 VATS diagnostic equipment vas employed to verify the valves were seating properly.
The valves satisfactorily passed the test and data evaluatiotrindicated proper operation of the valves.
In summary, we believe this testing was adequate to verify the design modification functioned as intended and that the testing met NRC requirements related to post modification testing..
Nevertheless, our review of the subject design package indicates that improved documentation of the functional test assessment to design basis is warranted.
Maine Yankee will revise its design precess control procedures to provide improved assesst.ent documentation for futura design changes.
These procedure changes will be coup ated by June 30, 1990.
NOTICE DEVIATION In a letter from Maine Yankee Atomic Power Company to NRC, dated February 28, 1985, the licensee identified that the steam generator pressure variable Type A, Category 1 met the Regulatory Guide (RG) 1.97 guideline and, except for the range, no deviations were identified.
Regulatory Guide 1.97, Revision 3, Table 1, requires; 1)
Section 2, independent channels be p'tovided to preclude single failures.
2)
Section 6, recording of continuous, real time displays.
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Section 8, specific idertification of types A, B and C variables for ease of operator identification.
Contrary-to the above, on October 27, 1989, during the review of Engineering Design Change Request 88-51, the wide range steam generator pressure varichle did not have independent-channels, did not have recording of continuous real time i
displays and did not have specific identificatior, of type A variable for ease of operator identification.
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y MAINE YANKEE RESPONSE The three issues ((1) independent channels; (2) recording; and (3) identification) are addressed separately below.
(1)
Independent Channels:
Independence (redundancy) for this instrumentation is provided in that there is one channel of each variable per Reactor Coolent System Loop.
Maine Yankee has three loops / steam generators and only one loop / steam generator is necessary to remove post-accident decay heat.
Under accident conditions, two loops will he available, therefore independence is provided between loops. This is consistent with Maine Yankee's Reactor Coolant System Cold leg Temperature instruments (variables A9 and B6) and Hot Leg Temperature instruments (variables A8 and B5),
described in reference (d).
In October of 1989, Maine Yankee recognized that there was insufficient documentation describing channel independence in the Regulatory Guide 1.97 steam generator level design change package (EDCR 88-53).
Ir response to that finding, Maine Yankee identified that the same was true for steam generator pressure (EDCR 88-51).
Proper documentation was added to botn design change packages.
Maine Yankee believes that the independent channel recommer ations of Regulatory Guide 1.97 are satisfied for steam generator p,ssure and level instrumentation, and no deviation from our conynitments (referer.ce d) exists.
(2)
Recordina:
Following is our response to each of the four items requested in the Notice of Deviation associated with recording cf steam generator pressure instrumentation.
1.
Reascn for the deviation:
In developing the EDCR for steam generator pressure instrumentation, the engineer referred to the Regulatory Guide 1.97 document to capture the requirements.
In looking up steam generator pressure in Table 3, page 26, he found that it was a Category 2 Variable. A Category 2 Variable only requires recorders for effluent radioactivity monitors and area monitors (at first glance at Table 1, page 8 under item 6, display and recording).
The next page with item 6 continued refers back to Category 1 for "If direct and immediate trend... ", etc.
The engineer did not believe that this applied to this particular channel.
The engireer did not refer to reference (d); this letter identified steam generator pressure as a type A variable, which automatically made l
it a Category 1 and thus requiring recording capability.
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Immediate corrective steps which have been taken and the results achieved:
Maine-Yankee has scheduled a modification to add recording capability to the steam generator wide range pressure channels, one per loop.
This modification, due to parts delivery and engineering resources, is scheduled for the 1991 Refueling Outage, approximately December of 1991.
3.
Corrective steps which will be taken to avoid further deviations:
Each Engineering Design Change Request (EDCR) package contains a
" Reason for thange" section.
The EOCR procedure will be revised, by Octoter 1,1990, to require that the " Reason for Change" section of each EDCR include description (s) of how the EDCR complies with standerds, regulatory guides, NRC directives, etc., if one (or more) of these was the recson for the chanqn.
Additionally, Maine Yankee intends to develop source document for Regulatory Guide 1.9? instrumentation, to have all design basis information together tc ell w ease of retrievt.1/ review for future design changes.
The Regulatcry Guide 1.97 scurce document is scheduled for completion by the end of m a cycle 12, approximately December of 1991.
4.
Date when full compliance will be achieved:
Full compliance will be achieved with the addition of recording capability to the steam generator wide range pressure channels, addressed ir, item 2 above, approximately December of 1991, (3)
Identification:
In reference (d), Maine Yankee stated (under Generic Response to Criteria of Table 1, Regulatory Guide 1.97, in item 8, " Equipment Identification"):
" Equipment identification is done in accordance with Maine Yankee's Detailed Control Room Design Review (DCROR) Program.
A brief description of the impact of the OCROR on this report is provided in Part 11, Human factors.'
Further, (in Part 11, Human Factors):
" Maine Yankee has conducted a human factors evaluation of the main control board. As part of this effort, the location of some equipment will be changed.
When the implementation of the DCROR changes are completed, a method for identifying the instruments to be used under accident conditions will be chosen."
"0CROR Changes" have not been completed in their entirety, and a method of identification has not been chosen as of yet.
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,, Maine Yankee believes that we are in compliance with our commitments (reference d).
We plan to have all of the DCRDR changes completed by the end of the refueling outage following the end of core cycle 13, approximately June of 1993. We currently intend to have the issue of Regulatory Guide 1.97 instrumentation identification addresseI concurrent with completion of the DCRDR changes.
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