ML20036B068

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Responds to NRC Re Violations Noted in Insp Rept 50-309/93-03.C/As:Operations Dept Procedures Being Reviewed to Ensure Conformance to Policies Governing Locked Valves
ML20036B068
Person / Time
Site: Maine Yankee
Issue date: 05/13/1993
From: Hebert J
Maine Yankee
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JRH-93-102, MN-93-53, NUDOCS 9305180124
Download: ML20036B068 (3)


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EDISON DRNE

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May 13, 1993 MN-93-53 JRH-93-102 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk i

Washington, DC 20555

References:

(a)

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

(b) USNRC Letter to MYAPCo dated April 15, 1993, Resident Inspection t

50-309/93-03 l

Subject:

Inspection Report 93-03: Response to Notice of Violation - Valves in Their Required Positions Without the Required Locking Devices Gentlemen:

The attachment to this letter responds to the Notice of Violation contained in Reference (b). In the attachment to this letter, we have restated the violation and provided our response.

We have addressed our actions taken and those planned to prevent recurrence.

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

Very truly yours, James R. Hebert, Manager Licensing & Engineering Support Department l

JRH/ jag Attachment

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Mr. Thomas T. Martin Mr. Charles S. Marschall Mr. E. H. Trottier i

Mr. Patrick J. Dostie l

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i'70082 9305180124 930513 DR ADOCK 05000309 hI PDR

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a Notice of Violation:

f During an NRC inspection conducted on February 6 through March 22, 1993, one violation of NRC requirements was identified.

In accordance with the " General i

Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Maine Yankee Technical Specifications, section 4.6 B, requires, in part, that l

all manual valves in the emergency and auxiliary feedwater systems necessary to 1

assure emergency and auxiliary feedwater flow from the primary water source to the steam generators be locked in the proper position. Maine Yankee procedure 1-200-1, Administrative Control of Valves, Attachment D, states, in part, that t

interface valves that would adversely impact on system performance if i

incorrectly aligned shall be locked in their required position.

Contrary to the above, on March 8, 1993, the NRC inspector identified five interface valves in the emergency and auxiliary feedwater systems, in the t

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required position without the required locking devices.

This condition has i

existed since April 16, 1992, when the plant achieved initial criticality after the last refueling outage.

j Maine Yankee Response:

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On March 8,1993, while at full power, five manual valves which are interface valves i

that could adversely impact performance of the necessary emergency and auxiliary feedwater system did not have the administrative controls required by Maine Yankee Procedure 1-200-1, ADMINISTRATIVE CONTROL OF VALVES. These five valves were aligned I

and controlled by procedure, but were not locked as required.

The valves provide both alternate feedwater sources and discharge flow paths prior to power operations.

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Prior to commencing operation at power, the valves are required to be aligned and i

locked in position to ensure that an emergency and auxiliary feedwater supply is l

available for reactor core energy removal.

i Upon further evaluation by Maine Yankee, locking devices were immediately fitted to the affected valves.

A subsequent review of all the valves in the emergency and j

auxiliary feedwater flow path identified three additional valves which should have i

been locked but were not. These three valves were immediately fitted with locking l

devices and the procedure controlling the at-power position for all eight valves was revised to require verification that the valves are locked in their at-power position.

Review of the circumstances indicated that the root cause of this event was the i

misinterpretation of the policy governing locked valves as it pertained to the specific procedure controlling the periodic surveillance of these valves.

I immediate Corrective Actions:

When the determination was made on March 8,1993, that the five valves _ required l

locking devices, the locking devices were immediately fitted to the five valves. A further review of the emergency and auxiliary feedwater system revealed three other valves required locking devices, which were also installed.

The procedure controlling the at-power position for the eight valves was revised.

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f Corrective Steps Taken to Avoid Further Violation:

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The Operation Department procedures are being reviewed to ensure that they conform to the policies governing locked valves.

In particular, the interface valves that f

would adversely impact on system performance if incorrectly aligned shall be locked in their required position.

Full Comoliance Date:

l Full compliance was achieved on March 8,1993, when the five manual valves in the emergency and auxiliary feedwater system were fitted with locking devices.

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