ML20046B847
| ML20046B847 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/26/1993 |
| From: | Gody A Office of Nuclear Reactor Regulation |
| To: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| References | |
| NUDOCS 9308060301 | |
| Download: ML20046B847 (5) | |
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UNITED STATES
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E IWl E NUCLEAR REGULATORY COMMISSION
%-g-WASHINGTON, D.C. 20555-0001 l
%.D May 26, 1993 i
r Mr. Don Edwards Director of Industry Affairs Yankee Atomic Electric Company 580 Main Street l
Bolton, MA 01740-1398
Dear Mr. Edwards:
I This is in response to your letter of February 1,1993, addressed to Mr. Richard H. Vollmer regarding the NRC inspections conducted under Temporary Instruction 2515/118, " Service Water System Operational Performance Inspection (SWSOPI). We recognize the impact that a major inspection effort such as the SWSOPI has on licensee and NRC resources.
The costs of conducting the inspec-tions are considered in relation to the safety aspects of the issue being addressed.
With respect to the SWSOPI, NRC senior managers decided to initiate team inspections to examine service water systems (SWS) based on the large number of problems that have occurred in these systems over the last 20 years.
An evaluation conducted by the Office for Analysis and Evaluation of Operational Data of plant operating experience recognized that the loss of the SWS can represent a sjgnificant contribution to core damage frequency - in the range of 10'3 to 10' per reactor year.
The proposed SWSOPI was discussed in a Commission paper, SECY-92-355,' dated October 20, 1992 (Enclosure 1). The Commission directed the staff to make every attempt to reduce the number of people on each team to only those essen-tial to perform an effective inspection. See memorandum dated November 23, 1992, from Samuel J. Chilk (Enclosure 2).
Section 11.04 of Temporary Instruction 2515/118 specifies that a program i
effectiveness review will be performed after a number of inspections have been l
l completed. This review will be performed by September 1993, some nine months after initiation of the program.
In addition to program effectiveness, costs to both NRC and licensees will be considered.
1 The NRC is developing a pilot program in which a licensee may he able to conduct the equivalent of an NRC area of emphasis inspection (e.g., SWSOPI) as an alter-native to NRC conducting that area of emphasis inspection. The NRC inspection resources to review theslicensee's effort, which may include independent sampling j
by the NRC, would vary depending on such factors as the licensee's recent SALP 9308060301 90526 PDR ADDCK.3000029 P
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POLICY ISSUE SECW92-355 October 20, 1992 (NEGATIVE CONSENT)
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The Comissioners From:
James M. Taylor Executive Director for Operations Sub_iec t :
IMPLEMENTING SERVICE WATER SYSTEM OPERATIONAL PERFORMANCE INSPECTIONS (SWSOPIs)
Purpose:
To apprise the Comission of the progress made in developing j
Service Water System Operational Performance Inspections, and to request Comission approval of the staff's intent to perform the inspection at sites with perceived service water system problems, problem plants, and older facilities.
Commission approval is required based upon Chairman Carr's memorandum to me dated April 12, 1991, which commented on the five-year plan, and stated that Commission approval will be required before new major generic team inspection programs are undertaken.
Backoround:
The service water system (SWS) typically removes heat from safety-related equipment and reactor decay heat during shutdown operations. An increasing number of service water system (SWS) events in the late 1970's and early 1980's resulted in the issuance of Bulletin 81-03 related to flow blockage by Asiatic clams and mussels. A number of follow, up information notices discussed other fouling and flow blockage concerns.
The above events were evaluated by the Office for Analysis and Evaluation of Operational Data and the Office of Nuclear Regulatory Research. These evaluations were published in NUREG-1275, Volume 3 November 1988, " Operating Experience feedback Report - Service Water System failures and Degradations," and NUREG/CR-5379, Volume 1 June 1989,
" Nuclear Plant Service Water System Aging Degradation Assessment," respectively. Both evaluations concluded that the majority of the SWS events were due to fouling mechanisms including corrosion and erosion, biofouling,
Contact:
NOTE:
TO BE MADE PUBLICLY AVisiLABLE Don Norkin, NRR WHEN Tile TI!:AL SRM IS Mt.DE (301) 504-2954 AVAILABLE k
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The Commissioners,
foreign material and debris intrusion, sediment deposition, pipe coating failure, and calcium carbonate deposition. The second most frequently observed cause was personnel and procedural error.
The AEOD study recognized that loss of the SWS can represent a significant contribution to core damage frequency (C0F).
NUREG J275, Vglume 3 estimated the C0F to be in the range of 10' to 10' per reactor year, based on plant operating experience.
in response to the above indicated operating experience and studies, Generic Letter (GL) 89-13, " Service Water System Problems Affecting Safety Related Equipment," provided the following recommended licensee actions:
1.
For open-cycle SWSs, implement and maintain surveillance and control techniques to significantly reduce the incidence of flow blockage due to biofouling.
Conduct a test program to verify the heat transfer capability of all safety-related heat exchangers i
cooled by service water.
111. Establish a routine inspection and maintenance program for open-cycle service water piping and components to ensure that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety-related systems supplied by service water.
IV.
Confirm that the SWS will perform its intended functions in accordance with the licensing basis of the plant, including consideration of the ability to prrform required safety functions in the event of failure of a single active component.
V.
Confirm that maintenance practices, operating and emergency procedures, and training that involves the SWS are adequate to ensure that safety-related equipment cooled by the SWS will function as intended and that operators of this equipment will perform effectively.
Since GL 89-13 a number of plant specific SWS design and operational concerns have been identified in licensee event reports, during inspections, and as a result of licensee imple n tation of GL 89-13. Due to these continuing
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l problems, the Special Inspection Branch of the Office of i
Nuclear Reactor Regulation was tasked to develop an j
inspection to assess the operational performance of the SWS j
at operating plants.
4 Discussion:
The Service Water System Operational Performance Inspection
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l (SWSOPI) was developed to achieve the following objectives:
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to verify that the SWS is capable of meeting thermal and j
hydraulic design requirements
- to identify and evaluate SWS design vulnerabilities to assess the SWS operation, maintenance, surveillance, i
testing, and associated personnel training l
to assess the unavailability of the SWS due to planned maintenance and surveillance and component failures
- to assess the licensee's planned or completed actions in response to GL 89-13 One pilot inspection is to be conducted in each region since the pilots serve to train the regional inspectors who will conduct the inspections as well as to develop the inspection methodology. Pilot inspections have been completed at the following sites:
l St. Lucie, Region 11 (9/91)
- Ginna, Region 1 (12/91)
- Quad Cities, Region !!! (3/92)
- South Texas, Region IV (7/92) l A pilot inspection is planned at a Region V site in January 1993. The spectrum of findings identified during the pilot j
inspections ranged from potential operability concerns to
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less significant issues. The following three examples were identified where licensees had not properly accounted for single failures of active components:
- The licensee had not evaluated the potential loss of operability due to single failure of a discharge check valve while the SWS was cross-connected.
(Ginna)
- A single failure of a check valve at the interface between the normal and emergency SW systems could prevent adequate flow to room coolers during an accident.
(Quad Cities)
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i The technical specification requirement for two of four i
SWS pumps to be operable did not account for single, failure modes and their effect on ensuring required flow j
during the accident recirculation phase.
(Ginna)
Additional findings included:
Licensee practices allowed SW equipment to be taken out of service for raintenance while the redundant train was 2
i being tested and may not have been able to perform its safety function.
(Ginna)
Lack of data on flow distribution and fouling conditions in individual emergency core cooling system pump room coolers resulted in failure to ensure adequate flows to each cooler.
(Quad Cities)
- Four of eight residual heat removai (RHR) heat exchanger flow control valves were not certified as being environmentally qualified although operating instructions called for their use during harsh environment accident conditions.
(Quad Cities)
- Flow restrictions in Unit 1 RHR heat exchanger room coolers were not properly addressed regarding operability and applicability to Unit 2 components.
(Quad Cities)
- lhe licensee credited the Intake Cooling Water Pump as operable without having adequately tested the pump and its actuation circuitry.
(St. Lucie)
The manual and check valves located on each of the three seismic Category I emergency strainer wash discharge lines perform a safety function, but were not included in the inservice testing program. (South Texas)
The planned course of action is to conduct the SWSOP1 at most sites. Fewer significant findings were identified at St. Lucie and South Texas, which are newer plants, in addition, South Texas had performed an effective safety system functional assessment which addressed GL 89-13 issues. Plants which are perceived to have SWS problems or more general maintenance, engineering or technical support problems as well as all plants licensed before 1979 will be inspected. Newer plants which have performed effective safety system functional assessments on the SWS may not be inspected. As a minimum, this inspection will be conducted at 62 percent of the sites, based upon the 1979 criterion and sites already inspected under the pilot program.
Some
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of the additional 38 percent which have problems, as noted abova, will be inspected.
The inspection teams will be comprised of a team leader, a mechanical systems design engineer, an operations specialist, a maintenance specialist, and a surveillance /
testing specialist. At least one member of the team will have had previous experience with GL 89-13 issues. For plants with complex electrical distribution system supplies to SWS equipment, an electrical engineer may be added to the team. The NRC resource estimate for each SWSOPI is 34 staff-weeks, including management participation and contractors. Of this,15 staf f-weeks involve site inspection, which will directly impact licensees.
The results of the first three pilot inspections were discussed at the Senior Management Meeting in June and a decision was made to proceed with the SWSOPIs as an area of emphasis, subject to Comission approval. The shutdown risk inspection will be discussed at the next Senior Management Meeting and this topic or another topic may be proposed for parallel implementation with the SWSOPI. SWSOPIs would be initiated by the regions in fiscal year 1993 and would take place over about a three yett period. The remaining electrical distribution system functional inspections will be completed in fiscal year 1993 in parallei with the first SW inspections.
Recommendation:
Unless advised to the contrary, by the Commission, within 10 working days from the date of this paper, the staff plans to proceed with the SWSOPIs as an area of emphasis inspection at sites with perceived service water problems, problem plant., and older facilities.
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M M. T hior ecutive Director for Operations i
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In the absence of anstruct1ons to the contrary, SCCY ws11 notify the ataff on Wedncaday, November 4,
- 1992, i
that the Cornmission, by negatave consent., assent s to the action proposed in this paper.
DISTH111UTION:
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cFFact of WI November 23. 1992 l
secatf*RY MEMORANDUM FOR:
James M. Taylor Executive Director for Opy ations FROM:
Samuel J. Chilk, Secret
SUBJECT:
SECY-92-355 - IMPLEMENTFNG SERVICE WATER I
SYSTEM OPERATION PERFORIAN:E INSPECTIONS (SWSOPIs)
This is to advise you that the Commission has not objected to the staff plans to proceed with the SWSOPIs as an area of emphasis inspection at sites with perceived service water system problems, l
problem plants, and other facilities.
However, before initiating the inspection program, the staff should seriously reconsider how l
many people are truly needed to perform each inspection.
Every attempt should be made to reduce the number of people on each i
team to only those essential to perform an effective inspection.
In view of the resource requirements for the inspections, the Commission would like to see a progress report at the end of FY 93 discussing the staff's findings and the need for continuing SWSOPIs at the currently planned resource expenditure rate.
(EDO)
(SECY Suspense:
9/30/93) cc:
The Chairman i
Commissioner Rogers Commissioner Curtiss commissioner Remick commissioner de Planque OGC OIG Office Directors, Regions (vis E-Mail)
OP, SDBU/CR, ASLBP (via FAX) l 5E'CY NOTE:
THIS SRM AND SECY-92-355 WILL BE MADE PUBLICLY AVAILABLE 10 WORKING DAYS FROM THE DATE OF THIS l
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+ Mr. Don Edwards May 26, 1993 performance, the quality of the self-assessment planned by the licensee, and NRC observations during in-process monitoring of the self-assessment. This program is designed to reduce the NRC regulatory impact on selected licensees and to allow more efficient utilization of NRC resources. As you may know, j
the Maine Yankee facility is being considered for inclusion in the pilot program.
Sincerely, l
original signed by Marylee Slosson for i
Anthony T. Gody, Acting Director Program Management, Policy Development and Analysis Staff Office of Nuclear Reactor Regulation
Enclosures:
- 1. SECY-92-355
- 2. Memo from S. J. Chilk, SECY dtd 11/23/92 Distribution NRR Mailroom (0930027)
ILPB RF Central Files /PDR R. Vollmer T. Murley F. Miraglia J. Partlow W. Russell T. Martin, RI A. Gody E. Rossi i
R. Zimmerman M. Slcsson l
M. Peranich l
R. Paulus l
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- SEE PREVIOT CONCURRENCE 0FC ORIS/ILPB C/0RIS/ILPB C/ILRB/PMAS DD/DRIL/NRR D/DRIL/NRR p/EMAS/NRR NAME RPaulus*
MPeranich*
MSlosh RZimmerman*
(1io(din YGodd_
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DATE 5/10/93 5/10/93 5/ 17/,93 5/12/93 5//3/93 5/>1,/93 l
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l performance, the quality of the self-astessment planned by the lige see, and l
NRC observations during in-process monitoring of the self-assessment.
These 1
factors would be used by the NRC to determine the degree of re, duction, if any, l
to the NRC's inspection effort. This program is designed tofreduce the NRC l
regulatory impact on licensees and to allow more efficient,dtilization of NRC l
resources. As you may know, the Maine Yankee facility i being considered for l
inclusion in the pilot program.
Sincerely,
/
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l Anthony J Gody, Acting Director Program' Management, Policy Development and/ Analysis Staff Off)te of Nuclear Reactor Regulation
Enclosures:
l
- 1. SECY-92-355
/
- 2. Memo from S. J. Chilk, SECY
/
dtd 11/23/92
/
Distribution NRR Mailroom (0930027)
ILPB RF l
Central Filesj/PDR f
R. Vollmer T. Murley
/
F. Miraglia
^
J. Partlow W. Russell T. Martin, RI A. Gody E. Rossi R. Zimmerman M. Slosson l
M. Peranich R. Paulus
- SEE PREVIOUS CONCURRENCE OFC ORIS/ILPB C/0RIS/ILPB C/ILPB/PMAS DD/DRIL/NRR D/DRIL/NRR D/PMAS/NRR NAME RPaulus*
MPeranich*
MSlosson RZimnkfm3n ERossi AGody DATE 5/10/93 5/10/93 5/ /93 5/lp/93 5/ /93 5/ /93
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l audit the licensee's self-assessment. This program is designed to, educe the NRC regulatory impact on licensees and to allow more efficient utflization of i
NRC resources. As yot may know, the Maine Yankee facility is being considered
]
for inclusion in the pilot program.
Sincerely,
/
/
Anthony T. Gody Acting Director Program Management, Policy Development and Analysis 5taff Office of N6 clear Reactor Regulation
Enclosures:
- 1. SECY-92-355
/
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- 2. Memo from S. J. Chilk, SECY
/
dtd 11/23/92
/
j
/
1
/
i Distribution
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NRR Mailroom (0930027)
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ILPB RF
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Central Files
/
R. Vollmer
/
T. Murley e
F. Miraglia
/'
J. Partlow
/
W. Russell 7
j T. Martin, RI j
A. Gody
/
E. Rossi
/
R. Zimmerman
/
M. Slosson
/
M. Peranich
/
R. Paulus
/
/
i
/
/
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J
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n, )/2 0FC ORIS'/11,PB kI[/ILPB C/ILPB/PMAS DD/DRIL/NRR D/DRIL/NRR D/PMAS/NRR' NAME RP5 N MPeranich MSlosson RZimmermand ERossi AGody DATE 5//g/93 5///)/93 5/ /93 5/ /93 5/ /93 5/ /93 l
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