ML20045D265
| ML20045D265 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/15/1993 |
| From: | Frizzle C Maine Yankee |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR CDF-93-95, GL-87-02, GL-87-2, MN-93-62, NUDOCS 9306280147 | |
| Download: ML20045D265 (12) | |
Text
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MaineYankee RELIABLE ELECTRICITY FOR MAINE SiNCE 1972 i
Charles D. Fnzzle Edison Dnve President Augusta. Maine 04336 (207) 6224868 June 15, 1993 HN-93-62 CDF-93-95 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation Washington, DC 20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo dated April 29, 1993 - Results of 1
Comparison-MYAPS Seismic Design Margin Program Versus requirements of USI A-46 (c) Maine Yankee Letter to USNRC dated April 30, 1991 - Appeal from Generic Letter 87-02 (d) USNRC Letter to MYAPCo dated August 28, 1991 - Maine Yankee Backfit Claim, A-46 Seismic Issue
Subject:
Comparison of the NRC SDMP to A-46 Dear Dr. Murley.
1 This letter is in response to a letter from your staff dated April 29, 1993, which forwarded the results of a comparison between the Maine Yankee Atomic Power Company Seismic Design Margin Program and the resolution of Unresolved Safety Issue A-46, " Seismic Qualification of Equipment in Operating Plants".
-This report identified nine issues, five of which your staff assessed to have potential safety i
significance. Attachment I to this letter provides Maine Yankee's response to these issues.
For your convenience, our responses to the five potentially significant issues are summarized below.
Issue No. 3 and Issue No. 7:
Maine Yankee's commitment to perform a review of relay chatter coincident with our IPEEE by mid 1995 should be adequate to resolve staff concerns' with respect to these two issues.
Issue No. 4:
The enclosed copy of an apparently overlooked NRC review of equipment modifications should be adequate--to resolve this issue concerning the apparent lack of an NRC review of equipment modifications.
Issue No. 8:
The presence of an-additional seismically designed tank on site with capacity of 100,000 gallons should be adequate to resolve this issue regarding long-term heat removal.
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b3511 lIlkCO UNITED STATES NUCLEAR REGULATORY COMMISSION MN-93-62 Attenti'on: Document Control Desk Page 2 Issue No. 9:
The remaining issue, No.
9, deals with the level of detail contained in the procedures used to perform the plant walkdowns. The resolution of A-46 contemplated the performance of plant walkdowns by plant engineers, not necessarily expert in seismic evaluation.
For this reason, A-46 required detailed, checklist-type procedures for use by these individuals. The Maine Yankee walkdowns were performed by nationally renowned seismic experts (see Attachment 4) who then, utilizing the Maine Yankee walkdown experience, wrote the detailed guidance for the resolution of A-46.
It is Maine Yankee's position that the performance of walkdowns by these seismic experts, with or without detailed procedures, is equivalent to the performance of walkdowns by non-expert engineers with detailed procedures.
We do not believe that performing these walkdowns again with our engineers using checklist-type procedures would result in any significant improvement to the seismic ruggedness of Maine Yankee.
Maine Yankee took a proactive approach by working with the NRC staff to resolve seismic concerns relating to Maine Yankee significantly in advance of the resolution of A-46 for the industry. This resulted in Maine Yankee completing its reviews and implementing significant seismic upgrades to the plant well in advance of the time that these upgrades would have been performed if we had waited for the resolution of A-46. Because we worked proactively with the staff to resolve the seismic issue in advance of A-46, there are differences between the way staff concerns were resolved for Maine Yankee and the generic methods adopted in the resolution of A-46. However, i
we do not believe that performing an A-46 type review for Maine Yankee will result in any significant additional protection to public health and safety.
Further, we believe that requiring such a review will act as a significant disincentive for Maine l
Yankee and other plants to work proactively with the staff in the future to resolve similar generic issues. provides a summary of Maine Yankee's significant milestones and communications related to our seismic margins efforts.
We believe this letter is responsive to the issues raised in Reference (b). We continue to believe that the Maine Yankee seismic design provides an adequate level of protection for public health and safety. We further believe that the continued use of Maine Yankee and NRC resources reviewing this matter is not warranted.
Very truly yours, 7
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Charles D. Frizzle President and Chief Executive Officer l
GDW/ jag Attachments l
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Mr. Thomas T. Martin Mr. Charles S. Marschall Mr. E. H. Trottier Mr. Patrick J. Dostie Document Control Desk l
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ATTACHMENT 1 l
MAINE YANKEE RESPONSE TO ISSUES RAISED IN NRC LETTER DATED APRIL 29, 1993, REGARDING SEISMIC MARGINS AND A-46 The following provides Maine Yankee issue-by-issue comments and responses to the staff list of potential issues summarized in their Table 1 (Reference (b)). Table I has been reproduced as Attachment 3 in this transmittal package te provide a convenient cross reference for the reviewers.
Issues 1, 2, 5 & 6 We agree with the staff that issues (1), (2), (5), and (6) from your Table 1 are very unlikely to be of any significance.
I Issue 3, Omission of Relay and Breaker Chatter We agree that relay chatter is an open issue. Maine Yankee now has four engineers formally trained in the SQUG relay review methods (EPRI NP-7148) and is planning to conduct the relay reviews with the remaining tasks to fulfill the NY commitment for completion of the IPE/EE by mid 1995. We believe this review should resolve staff concerns regarding this issue.
3 Issue 4, No SMA Evaluation of Equipment Modifications and Replacement This issue involves a concern for a perceived lack of a NRC post upgrade audit of Maine Yankee.
Pat Sears, a civil-structural engineer and then Project Manager for 1
Maine Yankee (and a staff principal for A-46 and NRC Margins Program) performed a enmplete walkdown and calculational package review of these upgrades.
This review was documented by a letter from Pat Sears to Maine Yankee Executive Vice President, John Randazza on August 31, 1987.
A copy of this letter is attached for your convenience.
This review, which was apparently overlooked in the preparation of i
Reference (b), should resolve staff concerns in this area.
Note that this letter reiterates the previous NRC conclusions by quote, namely that "all the issues associated with the design basis for MYAPS and hence the design adequacy of the plant are considered resolved."
This letter, which reports a favorable NRC review of the committed upgrades, is considered a closure document.
Issue 7, Loss of Offsite Power Always Assumed This issue questions the' conservatism of the assumption of loss of offsite power.
We presume the issue to be a potential for certain additional spurious actuations to occur if offsite power were to remain available.
This potential for spurious actuations will be evaluated as a part of the relay chatter assessment, which will 1
not be limited to the loss of offsite power scenario. We believe the relay chatter review which we previously agreed to perform (see our response to Issue 3 above) should resolve staff concerns in this area.
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Issue 8, Long Term Heat Removal This issue involves a "possible" concern for long term (72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) decay heat removal capability. We agree, with small differences, with the staff's estimates for decay heat removal water requirements using either feed and bleed, or steaming through the steam generator safeties, with the water drawn from the RWST and DWST/PWST, respectively.
However, the staff may not be aware that Maine Yankee has another 100,000 gallons of water onsite in the Condensate Storage Tank (CST).
This is a i
seismically designed tank constructed at the plant in late 1984. The CST does not appear in the SMA as the PWST and DWST provided more than adequate water to meet the SMA short term cooling requirements.
With this extra water, it is conservatively estimated that Maine Yankee can remove decay heat by steaming alone for about 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. By using a combination of steaming and feed and bleed, sufficient inventory would be available from seismic tanks to meet the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> guideline.
Maine Yankee also has proceduralized, via an Abnormal Operation Procedure (AOP),
replenishing-the DWST from the fire system using seismically rugged equipment. Maine Yankee operators are trained to maintain water inventories.
Finally, Maine Yankee also has a proceduralized ontion for directly feeding the steam generators with the fire water system within the A0Ps.
We believe that Maine Yankee has a sufficient number of seismically rugged alternatives for decay heat removal so that issue (8) can be eliminated as a staff concern.
Issue (9), Seismic Fragility / Capacity Estimates and Walkdown We agree with the staff that there are differences in level of detail and prescription between the NRC SMA program implemented at Maine Yankee and the A-46 GIP pertaining to fragility estimates and walkdowns.
Those of the staff who were involved in the developmental stage of the seismic review programs (which have roots in the late seventies) will recall the discussions over the tradeoff between the use of nationally accredited seismic engineers to perform plant seismic reviews and the sole use of utility staff engineers.
The NRC staff at that time appeared to prefer the use of nationally accredited seismic experts. It is our belief that had the option of using experts been chosen, prescriptive review procedures would not have been required.
As a body, the industry strongly preferred the use of its own engineering staff.
Senior NRC staff involved in these discussions would accept the use of utility engineers only if a very detailed (i.e., prescriptive) set of review procedures and formal training programs were developed.
The result is today's GIP and the SQUG training programs.
Implementation of the NRC margins program at Maine Yankee was the culmination of a series of plant seismic reviews and upgrades that were initiated in 1982. We believe it is important that the NRC staff fully appreciate the level of expertise involved in this extensive series of Maine Yankee seismic reviews. These. consulting engineers and senior managers (see Attachment 4) who performed the Maine Yankee review and walkdowns literally wrote the book for today's plant seismic review programs, both A-46 and IPE/EE.
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It is Maine Yankee's position that'the performance of walkdowns using seismic experts l-without detailed procedures is equivalent to the performance of walkdowns.by non-expert' engineers with detailed procedures.. We-believe that performing the review again using procedures written by the same individuals who performed our plant review J
would not result in a substantial increase in the overall protection of public health.
and safety.
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l ATTACHMENT 2 CHRON0 LOGY OF SIGNIFICANT MILESTONES AND COMMUNICATIONS PERTAINING TO MAINE YANKEE SEISMIC MARGINS J
1982 First expert seismic margins walkdown (review to greater than SSE) conducted by Dr's. Stevenson and Cornell, with support from NY staff.
Several anchorage upgrades were effected following this walkdown.
Results of this review were presented to the staff.
1984 Second expert seismic margins walkdown.
This walkdown was conducted by Dr.
Robert Kennedy.
Dr. Kennedy concludad that Maine Yankee was "certainly.more than adequate to resist a 0.lg RG 1.60 event" and indicated that he had a high confidence of performance at double this figure (i.e., estimated HCLPF of about 0.2g).
Several additional anchorage upgrades resulted from this walkdown.
Results of this review were presented to the staff.
1985 Third seismic margins expert walkdown.
This walkdown was conducted by Peter Yanev and Sam Swan of EQE.
This walkdown provided further support to the conclusions of Dr. Kennedy.
No modifications were prompted by this review.
Results of this review were presented to the staff.
March 4, 1986 Maine Yankee commits to be the NRC's trial plant for.their SDMP with the understanding that upon completian of the program, the NRC would issue "a Safety Evaluation which documents the resolution of the seismic issue for Maine Yankee." Several additional anchorage modifications were prompted as a product of this review, upgrading the plant to a HCLPF of 0.27.
9 February 19, 1987 NRC Staff issues A-46 Generic Letter 87-02.
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March'26, 1987 NRC staff issues SER to Maine Yankee for SDMP.
Importantly it states, "we conclude that the upgraded MYAPS will have the HCLPF capacity in the range of
.279 This capacity is significantly higher than the earthquake event defined by the 50% spectrum of the NUREG/CR-0098 anchored to a peak acceleration of 0.189. Therefore, all the issues associated with the design basis for the plant are considered resolved."
June 30, 1987 Maine Yankee provides an initial response to GL 87-02, stating that "our participation in the NRC-sponsored Seismic Margins Program (SDMP) and receipt of a favorable Safety Evaluation Report (SER) provides adequate resolution of USI A-46 for the, plant."
August 31, 1987 NRC Maine Yankee Project Manager provides documentation of his " Audit of Plant Changes (10CFR 50.59) for Maine Yankee Atomic Power Station (MYAPS) Seismic Upgrades." The letter reiterates that with these upgrades "the High Confidence of Low Probability of Failure (HCLPF) capacity of MYAPS is in the range of.279, well above any hypothesized earthquake for MYAPS."
It also repeats by quote from the staff SER that "all the issues associated with the design basis for MYAPS and hence the design adequacy of the plant are considered resolved." The letter goes on to state that "The March 26, 1987 letter was the culmination of l
an NRC-sponsored Seismic Margins Program (SDMP), a joint NRR/RES program, the l
purpose of which was to evaluate the seismic ruggedness of MYAPS. SDMP found, that with the previously listed upgrades, MYAPS did in fact have a HCLPF of
.279."
April 23, 1990 NRC staff replies to.1987 letter stating that it is "not prepa ed to conclude that your satisfactory completion of the SDMP satisfied all the issues associated with USI A-46."
l January 4, 1991 Maine Yankee reas::erts its belief that with a limited exception (relay chatter),
the USI A-46 issue should be considered resolved.
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February 13, 1991 NRC replies requesting a more detailed explanation of MY position. The staff includes some discussion indicating that application of USI A-46 to MY was within the scope of the original regulatory analysis and not a backfit.
April 30, 1991 Maine Yankee files a formal backfit appeal concerning the applicability of GL 87-02 to Maine Yankee by appealing the validity of the generic regulatory -
analysis as it applies to Maine Yankee.
In essence, Maine Yankee argued that the generic analysis did not factor in the numerous seismic reviews and upgrades at the plant.
August 28, 1991 The NRC responds to the backfit appeal concluding, in part, that "The. premise on which you base your backfit appeal of April 30, 1991, is correct.
Specifically, the regulatory analysis that formed the basis for Generic' Letter 97-02, ' Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors' did not consider the Maine Yankee Seismic Design Margin Program. Upon considering the seismic evaluation and upgrades that Maine Yankee performed as part of your SDMP, the staff has determined that Maine Yankee need j
not respond to Generic Letter 87-02."
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ATTACHMENT 3 j
l TABLE 1 l
POTENTIAL DIFFERENCES BETWEEN THE
{
MAINE YANKEE SMA AND A-46 CRITERIA i
i CONFORMANCE POTENTIALLY j
ITEM WITH A-46 SIGNIFICANT-REMARKS
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- 1. No access to containment no unlikely Safety and relief valves on NSSS must be examined
- 2. Partial omission of hydraulic yes no These systems and pneumatic systems (except for must be examined valves) for the valves in item 1
- 3. Omission of relay and breaker no yes i
chatter
- 4. No SMA evaluation of no unknown equipment modifications and replacement
- 5. Only two shutdown functions yes no See item 8 for l
f considered (early period) later period
- 6. Different methodology for yes no identifying equipment
- 7. Loss of offsite power always no unknown assumed
- 8. Long term heat removal no possible Depends on requirements for and availability i
of makeup for hot shutdown
- 9. Seismic Fragility / Capacity no yes Estimates and Walkdown L e \\93nm\\9362
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f 1 f ATTACHMENT 4 4
PERSONNEL INVOLVED IN MAINE YANKEE SEISMIC REVIEW PROGRAM 193.2 STEVENSON/ CORNELL SEISMIC REVIEW John Stevenson (S&A)
Allin Cornell Frank Thomas MY))
S&A Bill Henries Joe McCumber MY) 193 1 KENNEDY ANALYSIS AND REVIEW Bob Kennedy (S i
Doug Whittier
)
Bill Henries
.l Joe McCumber Bill Metevia
[
EQE SQUG CLASS-OF-EIGHT REVIEW Peter Yanev ( QE)
William Me(EQE Sam Swan t
tev a MY)
Bill Henries (MY 1986-87.
t SEISMIC DESIGN MARGINS PROGRAM i
1 Authors of the Report and Analysis Team Volume 1.
Summary Report Lawrence Livermore National Laboratory-R. C. Murray, Project Manager P. G. Prassinos G. E. Cummings Volums 2.
Systems Analysis i
Energy Incorporated D.
L'. Moore, Systems Analysis Team Leader l
D. M. Jones M. D. Quilici:
J. Young
-Volume 3.
Fragility Analysis-EQE Incorporated-M..K Ravindra, Fragility Analysis Team Leader M. J. Griffin G. S. Hardy P. S. Hashimoto utsamm\\s362
e O. S. Nuclear Regulatory Commission D. J. Guz, Project Leader A. J. Mur hy, Section Leader, Engineering Branch J. E. Ric ardson, Chief, Engineering Branch, Division of Engineering Safety A. C. Thadani, Diretor, Division of Licensing P. M. Sears, Project Manager, Division of Licensing NRC Seismic Design Margins Working Group i
N. Anderson, Co-Chairman J. Richardson, Co-Chairman G. Bagchi L. Beratan J. Chen N. Chokshi C. Grimes D. Guzy P. K. Niyogi L. Reiter Reviewers Peer Review Group R. J. Budnitz, Chairman, Future Resources Associates M. P. Bohn, Sandia National Laboratories J. W. Reed, Jack R. Benjamin & Associates, Inc.
J. Thomas Duke Power Company L. A. Wyllie, M. J. Degenkolb & Associates Expert Panel on the Quantification of Seismic Margins R. J. Sudnitz, Chairman, Future Resources Associates P. J. Amico Applied Risk Technology Corporation C. A. Cornell, CAC, Inc.
M.Shinozuka,ackR. Benjamin & Associates,Inc.
J. W. Reed J Columbia University Utility Maine Yankee Atomic Power Company G. D. Whittier S. D. Evans P. L. Anderson W. E. Henries J. T. McCumber J. Metevia
'c Kennedy, Consultant
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U. S. Nuclear Regulatory Commission D. J. Guz, Project Leader i
A. J. Mur hy, Section Leader, Engineering Branch J. E. Ric ardson, Chief, Engineering Branch, Division of Engineering Safety A. C. Thadani, Diretor, Division of Licensing P. M. Sears, Project Manager, Division of Licensing NRC Seismic Design Margins Working Group N. Anderson, Co-Chairman J. Richardson, Co-Chairman G. Bagchi L. Beratan J. Chen N. Chokshi C. Grimes D. Guzy P. K. Niyogi L. Reiter Reviewers Peer Review Croup R. J. Budnitz, Chairman, Future Resources Associates M. P. Bohn, Sandia National Laboratories i
J. W. Reed, Jack R. Benjamin & Associates, Inc.
J. Thomas Duke Power Com an L.A.Wyllie,H.J.Degenkolf& Associates Expert Panel on the Quantification of Seismic Margins R. J. Budnitz, Chairman, Future Resources Associates C. A. Cornell,pplied Risk Technology Corporation P. J. Amico A CAC, Inc.
J. W. Reed J M.Shinozuka,ackR. Benjamin & Associates,Inc.
Columbia University Utility Mr.ine Yankee Atomic Power Company i
G. D. Whittier S. D. Evans P. L. Anderson W. E. Henries J. T. McCumber W. J. Metevia i
R. P. Kennedy, Consultant u\\sw\\sur
JUN-22-93 TUE 9:19 MAINE YANKEE
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Docket No.: 50-309 4NS:D:UTY & e Mr. J. B. Randazza Executive Vice President P' ~ ~ *O N D S Y 1 ^ ~ Maine Yankee Atomic Power Company b ug st, M e 04336 NRC DUE DATE l
Dear Mr. Randazza:
I
SUBJECT:
AUDIT OF PLANT CHANGES (10 CFR 50.59) FOR MAINE YANKEE ATOMIC i POWER STATION (MYAPS) SEISMIC UPGRADES By letter dated February 26,'1987, Maine Yankee Atomic Power Company (MYAPCo)- I l indicated that the seismic upgrades listed below would be completed by the ] scheduled completion' dates. also listed below. By pushing the construction 7 j schedule forward, the completion date for the Refueling Water Storage' Tank. l anchorage upgrade was implemented approximately 18 months earlier than 'h-promi sed. Description Schedule Completion - Change Date i Diesel fuel day tank. anchorage uparade done Control Room cooler anchorage upgrade done Welding cart / gas bottle tiedown. done Security lighting tiedown done j Main control board alarm tiedown done Strengthen blockwall VE 21-1 1987 Outage (done) Upgrade anchors for fans 44A & D 1987 Outage (done) Install internal anchors for t ra ns formers 507 & 608 1987 Outage.(done) Replace safety class batteries 1 & 3. 1987 Outage (done) Replace safety class batteries 7 & 4 1988 Outage i Replace water storage tank anchorage upgrade 1988 Outage-(done) By letter dated March 26, 1987, the staff indicated that those seismic upgrades listed would be reviewed during a 10 CFR-50.59 inspection. Also in that i letter, the staff indicated that with these upgrades, the High Confidence of j Low Probability of Failure (hcl.PFI capacity of MYAPS is in the range of.279, well above any hypothesized earthquake for MYAPS. In that letter it was also stated that "all the issues associated with the design basis for MYAPS and hence the design adequacy of the plant are considered resolved." The March 26, 1987 letter was the culmination of an NRC-sponsored Seismic Design Margins Program (SDMP), 'a joint NRR/RES program, the purpose of which was to evaluate the seismic ruggedness of MYAPS, 50MP found, that with the previously listed upgrades, MYAPS did in fact have HCLPF of.27g. Qd7df 4 / 72 --
JUll-22-93 TUE 9:19 liAII4E YAI4KEE FAX t10. 2076225163 P. 03 ' Design packages for the above items were reviewed and found to be completed and technically acceptable. All of the items previously listed were physically inspected for proper installation according to construction i drawings and/or instructions. A complete walkdown showed completed installation of all items except the replacement of safety class batteries 2 and 4, which are scheduled for replacement during the 1988 refueling outage. A check of records showed proper quality control during installation and use of correct materials. The Refueling Water Storage Tank upgrade package included detailed, sequenced instructions for welding various members and the pretorque of anchor bolts af ter the chair installations. All of the above listed items are considered complete with the exception of the replacement of safety class batteries 2 and 4 which will be reviewed as part of a 10 CFR 50.59 inspection af ter their installation. Si nce rely, 4 Patrick M. Sears, Project Manager Project Directorate I-3 Division of Reactor Projects, I/II cc: See next page 1 l l L
~ JUti-22-93 TUE 9:20 tiAl!1E YAtiKEE FAX 140. 2076225163 P.04 a Mr. J. B. Randazza Maine Yankee Atomic Power Company Maine Yankee Atomic Power Station cc: Charles E. Monty, President Mr. P. L. Anderson, Pro.1ect Manager Maine Yankee A.tomic Power Company Yankee Atomic Electric Company 83 Edison Drive 1671 Worchester Road Augusta, Maine 04336 Framingham, Massachusetts 07101 Mr. Charles B. Brinkman Mr. G. D. Whittier Manager - Washington Nuclear Licensing Section Head Ope ra tions Maine Yankee Atomic Fower Company Canbustion Engineering, Inc. 83 Edison Drive i 7910 Woodmont Avenue Augusta, Maine 04336 Bethesda, Maryland 20814 Mr. J. B. Randazza John A. Ritsher, Esquire Executive Vice President Ropes & Gray Maine Yankee Atomic Power Company ( 225 Franklin Street 83 Edison Drive Boston, Massachusetts 02110 August, Maine 04336 State Planning Officer ) Executive Department i 189 State Street Augusta, Maine 04330 t Mr. John H. Garrity, Plant Manager Maine Yankee Atomic Power Company P. O. Box 408 Wiscasset, Maine 0d578 Regional Administrator, Region i U.S. Nuclear Regulatory Conmission 631 Park Avenue King of Prussia, Pennsylvania 19406 First Selectman of Wiscasset Municipal Building U.S. Route 1 Wiscasset, Maine 04578 Mr. Cornelius F. Holden Resident Inspector c/o U.S. Nuclear Regulatory Conmission P. O. Box E Wiscasset, Maine 04578 .}}