ML20035A402

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Ack Receipt of in Response to NRC Re Violations Noted in Insp Rept 50-309/92-21
ML20035A402
Person / Time
Site: Maine Yankee
Issue date: 03/19/1993
From: Linville J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Frizzle C
Maine Yankee
References
NUDOCS 9303260011
Download: ML20035A402 (3)


See also: IR 05000309/1992021

Text

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Docket No. 50-309

Mr. Charles D. Frizzle

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President

Maine Yankee Atomic Power Company

83 Edison Drive

Augusta, Maine 04336

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Dear Mr. Frizzle:

SUBJECT:

INSPECTION 50-309/92-21

This refers to your February 24,1993 correspondence, in response to our January 26, 1993

letter.

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

regarding verification of engineering design reviews. These actions will be examined during a

future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Ull inal Signed By

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James C. f.inville

James C. Linville, Chief

Projects Branch No. 3

Division of Reactor Projects

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OFFICIAL RECORD COPY

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Mr. Charles D. Frizzle

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cc:

G. Leitch, Vice President, Operations

P. L. Anderson, Project Manager (Yankee Atomic Electric Company) (w/cy of Licensee's

Response Letter)

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 Licensee's Response letter)

Peter Brann, Assistant Attorney General (w/cy of Licensee's Response 12tter)

U. Vanags, Maine State Planning Office (w/cy of Licensee's Response 12tter)

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

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

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

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

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

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

K. Abraham, PAO (2 copies) (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 Ixtter)

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Region I Docket Room (with concurrences nnd IFS Forms)

J. Linsille, DRP

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W. Immms, DRP

C. Marschall, SRI - Maine Yankee (w/ concurrences and IFS Forms)

H. Eichenholz, SRI - Vermont Yankee

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ED:50N DA!VE - AUGUTA MA'NE M33C . ;2Ti 622-4359

February 24, 1993

MN-93-20

JRH-93-37

UNITED STATES NUCLEAR REGULATORY COMMISSION

Attention: Document Control Desk

Washington, DC 20555

References:

(a)

License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated January 26, 1993 - Resident

Inspection Report 50-309/92-21

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Subject:

Inspection Report 92-21: Response to Notice of Violation Associated with

the Verification of an Engineering Design Review

Gentlemen:

The attacliment to this letter responds to the Notice of Violation contained in

Reference (b).

In this attachment, we have restated the violation, provided our

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

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

Very truly yours,

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JJames R. Hebert, Manager

Licensing & Engineering Support Department

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Attachment

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Mr. Thomas T. Martin

Mr. Charles S. Marschall

Mr. E. H. Trottier

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Mr. Patrick J. Dostie

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Notice of Violation:

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During an inspection from November 20 thrcugh December 31, 1992, a violation of NRC

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requirements was identified. In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C (1992), the

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violation is listed below:

A.

10CFR Part 50, Appendix 8, Criterion III, states, in part, that licensees shall

establish design control measures for verifying the adequacy of design reviews.

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Contrary to the above, in December 1989, Maine Yankee failed to properly verify

the adequacy of a design review of the Primary and Secondary Component Cooling

Systems.

As a result, Maine Yankee failed to ensure that the plant operated

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with adequate loss of coolant accident heat removal capacity between December

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1989 and December 1993.

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Maine Yankee Response:

Stone and Webster Engineering Corporation (SWEC) design basis flow calculations for

the component cooling water systems that were performed in 1989 assumed that

Secondary Component Cooling (SCC) flow through valve SCC-T-227 would be negligible

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when the valve closed in response to a Containment Spray Actuation Signal (CSAS).

When SWEC assembled the calculation inputs during 1989, a Maine Yankee engineer

reviewed the post loss of Cooling Accident (LOCA) SCC system lineup and verified that

SCC-T-227 would be closed. However, the engineer overlooked the assumption that SCC-

T-227 was leak tight.

When recent maintenance activities discovered flow through SCC-T-227 in the closed

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position, plant startup was delayed while the SWEC SCC flow calculation was revised

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to include this flow. Maine Yankee calculations determined that for flows through

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SCC-T-227 up to about 150 gpm, flows to the Residual Heat Removal (RHR) heat

exchanger would still be adequate to provide post-LOCA heat removal capacity. Since

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design flow through SCC-T-227 in the closed position is 65 gpm, no change to the

maximum allowable service water inlet temperature was required to incorporate the

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actual design leak rate for the valve. Therefore, the operating limits for maximum

allowable service water temperatures were adequate to ensure SCC heat removal

capacity from December 1989 to December 1992 because the design leak rate for SCC-T-

227 is bounded by the allowable leak rate.

However, the maintenance activities referenced above also determined that leakage

through SCC-1-227 was initially measured at about 400 gpm and could only be improved

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to about 225 gpm by making external adjustments. Therefore, a bounding calculation

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was performed which evaluated current system conditions and, as a result, Maine

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Yankee conservatively reduced maximum allowable service water inlet temperatures by

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20af as an interim measure to allow plant startup to proceed while formal

calculations to change to the SWEC thermal analysis were performed.

The formal

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calculations to change the SWEC thermal analysis are complete and the results require

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a 4' reduction in maximum allowable service water inlet temperature based on a total

leakage flow of 400 gpm to nonsafeguards components.

Operating procedure

restrictions are being revised accordingly.

Substantial margin exists between actual service water inlet temperatures and maximum

allowable service water temperatures.

Maine Yankee has reviewed service water

temperature history for December 1989 through December 1992 and determined that the

revised allowable temperatures based on a 400 gpm leak have not been exceeded.

Therefore, we conclude that the plant has operated with sufficient SCC system heat

removal capacity from 1989 to the present time as indicated in Section 4.2 of the

inspection report, Reference (b), which i^ attached to the NRC Notice of Violation.

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Immediate Corrective Action and Results Achieved:

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The SCC-T-227 leakage was discovered on December 13, 1992, while the plant was

preparing to start up.

Plant start up was delayed until engineering verified that

SCC system capability was adequate at current service water temperatures, which was

completed on December 14, 1992.

Corrective Action Taken to Avoid Further Violations:

The root cause of this violation was a failure to perform an adequate review of an

assumption in an engineering analysis.

Maine Yankee is revising Procedure 17-21-5, ENGINEERING CALCULATIONS / ANALYSES to

include additional guidance to prevent recurrence. This procedure revision should

be completed by March 31, 1993.

In addition, the procedure revisions will be

discussed at future Engineering Department meetings to assure full awareness of this

issue.

The procedure revision will include specific requirements for an engineer reviewing

engineering calculations to ensure that key assumptions and their bases are

identified and to ensure that the assumptions are reasonable.

Full Comoliance Date:

Full compliance for the measured flows through SCC-T-227 was ensured on December 14,

1992, when engineering completed a preliminary calculation showing that SCC System

capability would meet design basis requirements. The formal calculation which added

400 gpm leakage to the SWEC calculations was completed 01/08/93 and resulted in a 4*F

reduction of maximum allowable service water inlet temperature for SCC system

operability.

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