ML20134G965

Responds to to Chairman Jackson,Expressing Concerns That Staff Should Make Certain Info Available Prior to 970204 Meeting

ML20134G965
Person / Time
Site:	Maine Yankee
Issue date:	02/03/1997
From:	Zwolinski J NRC (Affiliation Not Assigned)
To:	Myers H AFFILIATION NOT ASSIGNED
Shared Package
ML20134G967	List: ML20134G965 ML20134G999
References
NUDOCS 9702110100
Download: ML20134G965 (3)

Text

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i Ng g'*gi p UNITED STATES

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g j NUCLF AR REGULATORY COMMISSION g WASHINGTON, D.C. *naan nang

...+/ February 3,1997 Mr. Henry R. Myers Post Office Box 88 Peaks Island, ME 04108

Dear Mr. Myers:

I am responding to your letter to Chairman Jackson dated January 22, 1997, in which you expressed your view that the staff should make certain information available prior to the meeting of February 4,1997. The staff notes that the February 4th meeting has been requested to obtain information regarding Maine Yankee's activities in response to our recently completed Independent Safety Assessment Team (ISAT) inspection and the staff's related activities. The meeting is not being conducted in order to make any decisions at this time.

Therefore, the information you requested is not critical to the Commission prior to the meeting.

You requested a list enumerating noncomplying conditions at Maine Yankee and the associated violations. At the February 4 meeting, the staff will discuss nonconforming conditions to the extent that they relate to restart of Maine Yankee from its current maintenance outage. These issues are addressed in the '

staff's Confirmatory Action Letter (CAL) 1-96-015, dated December 18, 1996, as supplemented by letter dated January 30, 1997 (enclosed). In addition, the staff will conduct a predecisional enforcement conference, open for public observation, in the vicinity of the Maine Yankee site during early March 1997.

, That conference will address issues related to the ISAT. x(Oi C

You requested a list of outstanding maintenance items and incomplete corrective astions. The staff does not maintain such a list. The staff's inspectors have access to this information at the licensee's facility. The I[

staff will be conducting an inspection of the licensee's corrective action processes during February 1997. The results of that inspection will be made publicly available.

You requested "a listing of particulars with respect to which the Maine Yanke licensee has failed to demonstrate compliance with requirements based on TMI Action Plan Items II.K.3.30 and II.K.3.31." As noted in the Commission's

Order dated January 3, 1996, the licensee did not demonstrate "that the code .Pf1 will reliably calculate the peak cladding temperature for all break sizes in the small-break loss-of-coolant accident spectrum for haine Yankee." These matters are related to an NRC investigation. It would, therefore, be premature to discuss them further in conjunction with the February 4th meeting.

You asked whether licensing action would be required in relation to recent announcements of a pending contractual relationship between Maine Yankee Atomic Power Company and Entergy Operations. The staff has notified the m#m 100056 i

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Mr. Henry R. Myers licensee of the need to provide, through docketed correspondence, information regarding the nature of such a centractual arrangement in order to ascertain the need for licensing action.

Finally, you requested the Commission's rationale for permitting Maine Yankee to continue to operate. Maine Yankee is currently shut down under the conditions of the CAL and the CAL supplement. Approval of the NRC Regional Administrator is required prior to restart. Before making such a decision, the staff must be satisfied that there is reasonable assurance that the facility will be operated in a manner that poses no undue risk to public health and safety.

Sincerely, Rk r -

John A. Zwolinski, Deputy Director Divi ion of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

Confirmatory Action Letters

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! Mr. Henry R. Myers  !  !

licensee of the need to provide, through docketed correspondence, information regarding the nature of such a contractual arrangement in order to ascertain

the need for licensing action.

Finally, you requested the Commission's rationale for permitting Maine Yankee i to continue to operate. Maine Yankee is currently shut down under the conditions of the CAL and the CAL supplement. Approval of the NRC Regional Administrator is required prior to restart. Before making such a decision, the staff must be satisfied that there is reasonable assurance that the facility will be operated in a manner that poses no undue risk to public j health and safety.

, Sincerely, k6 -

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" John A. Zwolinski, Deputy Director Divi ion of Reactor Projects - I/II  !

Office of Nuclear Reactor Regulation

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Enclosures:

Confirmatory Action Letters DOCUMENT: G:\DORMAN\ CRC 97110.GRN 1 DISTRIBUTION:

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1 PUBLIC (w/ incoming) RZimmerman JGoldberg, OGC PDI-3 Reading (w/inc) . TMartin, DRPM N01 son

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FMiraglia/AThadani DDorman CNorsworthy I PMilano HMiller, R-I EPeyton  ;

SECY (CRC-97-0110)  !

OfC 99-0//o To receive a copy of this document. indicate in the box: 'C' - Copy without attachment / enclosure

• E* - Copy with attachment / enclosure *N" - No copy *See Previous Concurrence 0FFICE PM:PDl-3 l PD4-2:LA l DD:DRPE l D:DRPE l l ADPR l

. NAME DDorman:* EPeyton JZwolinski* SVarga* RZimmerman* l l DATE 01/31/97 01/ /97 01/31/97 01/31/97 01/31/97 mum meu a NAME FMiraglia* LChandler(NLO)* HThompson)( SJackson DATE 01/31/97 01/31/97 01/ 3 I /97 01/ /97 OFFICIAL RECORD COPY

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. i DIcember 18,1996 CAL No.1-96-015 l

Mr. Charles D. Frizzle President

! Maine Yankee Atomic Power Company 329 Bath Road i

Brunswick, Maine 04011 i

SUBJECT:

CONFlRMATORY ACTION LETTER i

Dear Mr. Frizzle:

On December 5,1996, you identified that the control wiring associated with the redundant trains of reactor manual trip pushbuttons was not separated, rendering both trains inoperable. You followed your Technical Specification and shut down the plant.

This cable separation problem was found during the conduct of reviews associated with Generic Letter 96-01, Testing of Safety-Related Logic Circuits. Subsequently, you developed and implemented technical approaches to determine the extent of this problem at Maine Yankee. On at least two occasions over a 5-day period (December 6-10,1996),

you believed that the scope and breadth of your approaches had been sufficient to identify additional vulnerabilities in the plant, when in fact they were not. When additional cable separation problems were identified on December 13,1996 that were determined to be outside of the boundary conditions for modification review you had established for determining the extent of conditions in the plant, you reevaluated and significantly revised your approach.

As of December 13,1996, you had identified the following cable separation and testing problems:

inadequate separation of 125 voit DC control cables to four of eight reactor trip breakers.

Inadequate separation of control cables from reactor trip breakers to all four manual  !

reactor trip pushbuttons in the control room, inadequate separation of control cables for the containment hydrogen analyzer system (Bendix Model).

1 Inadequate train separation between control and instrument cables for the two '

containment hydrogen analyzer routing systems (Bendix and Compsip Models).

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inadequate routing of a cable for the steam generator blowdown system trip valve.

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!' inadequate separation of control cables for an auxiliary steam system isolation 2

valve (High Energy Line Break function).

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• Inadequate testing of station power supply breaker auxiliary contacts in Emergency Diesel Generator, EDG 1 A and EDG-1B circuits.

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! Inadequate testing of the reactor trip breakers undervoltage and shunt trip coils.

To provide a high degree of confidence that you have identified and appropriately j dispositioned or resolved all safety significant cable separation and logic testing i vulnerabilities at Maine Yankee, and pursuant to a telephone conversation between

! Mr. G. Leitch, Vice President - Operations and Mr. R. Cooper, Director, Division of Reactor 1

Projects in the Region I office on December 17,1996, you agreed to complete the following actions prior to restarting (achieving criticality) the facility:

1. Complete the initial review, as previously committed for December 31,1996, of Maine Yankee's testing of safety-related logic circuits pursuant to NRC Generic Letter No. 96-01.

2. Develop a plan and methodology for expanding your review to determine the extent of the cable separation problem at the facility. This plan shall ensure that all safety significant cable separation problems are identified and appropriately dispositioned j or resolved pursuant to your licensing and design bases. '

3. Perform, concurrently with items 1 and 2, root cause evaluations that will address all hardware deficiencies identified, and utilize this information to validate the comprehensiveness of your corrective actions.

4. Meet with NRC representatives to describe the results and conclusions, as they '

pertain to the actions described above, and to gain my agreement that Maine Yankee is sufficiently prepared to restart the facility. At this meeting, you should also be prepared to discuss the actions that you took during the first several days after the December 5,1996 plant shutdown to understand the extent of cable separation problems at Maine Yankee.

A final written report on your root cause evaluations and corrective actions will be completed at a mutually agreeable date to be discussed at the meeting noted in item 4 above.

Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C 2232, you are required to:

1. Notify me immediately if your understanding differs from that set forth above;

2. Notify me if for any reason you cannot complete the actions within the specified schedule and advise me in writing of your modified schedule in advance of the change; and

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3. Notify me in writing when you have completed the actions addressed in this

),! Confirmatory Action Letter. 1 Issuance of this Cor.firmatory Action Letter does not preclude issuance of an order  !

formalizing the above commitments or requiring other actions on the part of the licensee- l nor does it preclude the NRC from taking enforcement action for violations of NRC i

} requirements that may have prompted the issuance of this letter. In addition, failure to I take the actions addressed in this Confirmatory Action Letter may result in enforcement i action.

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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this lette ,

its enclosure (s), and your response will be placed in the NRC Public Document Room j

' (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be 'placed in the PDR without i

redaction. If personal privacy or proprietary information is necessary to provide an i acceptable response, then please provide a bracketed copy of your response that identifies I

the information that should be protected and a redacted copy of your response that

! deletes such information. If you request withholding of such material, you mugl l specifically identify the portions of your response that you seek to have withheld and j provide in detail the bases for your claim of withholding (e.g., explain why the disclosure

! of information will create an unwarranted invasion of personal privacy or provide the i information required by 10 CFR 2.790(b) to support a request for withholding confidential j commercial or financial information). If safeguards information is necessary to provide an i.

acceptable response, please provide the level of protection described in 10 CFR 73.21.

3 Sincerely, Original Signed By:

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Charles W. Hehl i Hubert J. Miller Regional Administrator ,

i I j Docket No. 50 309 i i i

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January 30,1997 i l

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CAL No.1-96-015, Supplement No.1 ,

Mr. Charles D. Frizzle i President l Maine Yankee Atomic Power Compsny l

1 329 Bath Road ,

i Brunswick, Maine 04011 '

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SUBJECT:

CONFIRMATORY ACTION LETTER (NO. 1-96-015, SUPPLEMENT NO.1) 4

Dear Mr. Frizzle:

The purpose of this letter is to supplement the Confirmatory Action Letter (CAL) )

No.1 96-015, issued on December 18,1996, to include actions that you have i committed to take to resolve additionalissues prior to restart of the plant. In the ]

l original CAL, you committed to specific actions to address design related and 1 l configuration control problems for cabis separation and logic circuit testing i deficiencies, including determining the extent of condition of these problems at Maine Yankee, and the root causes of their existence.

j On November 9,1996, Maine Yankee experienced a complete loss of offsite power.

j The ISAT team had previously questioned whether the offsite power system satisfied '

j the facility design and licensing bases. Since that time, the NRC staff has had this

issue under review, and has corresponded with you on the docket about it. Our j review is now complete, and the staff has determined that the existing offsite power capability does not meet the design criterion specified in the Maine Yankee Final

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Safety Analysis Report which is the current licensing basis. Furthermore, the staff has

! concluded that your current Technical Specifications need to be amended to provide

reasonable assurance that Maine Yankee (MY) will operate within that basis. Our

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rationale for these conclusions is enclosed.

Further, during the current outage and as a result of your continuing review of ISAT findings, you identified additional design related and configuration control problems:

A reanalysis (commitment by MY in the response to the ISAT) has recently resulted in a change in the post accident containment flood level that affects additional components inside containment, several of which may need to be relocated above the flood level to remain operable. Among these are components that provide parameter inputs to Post Accident Monitoring instrumentation functions (e.g., steam generator narrow range transmitters provide an input to this instrumentation).

? l-During the ravi3w cf GIneric Lcttsr 96-01, a non-Class 1E lord was found to be l connected to a Class 1E power source without an appropriate isolation device

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and environmental qualifications which are contrary to design requirements (Licensee Event Report No.96-032, dated November 15,1996).

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j. During the ongoing review of the loss of coolant accident (LOCA) analysis to j support power operations up to 2700 MWth, MY identified an error in the l containment not free volume calculation. This volume is used in the post j accident containment pressure analyses and the change results in a higher than

expected containment pressure for the design basis LOCA (Maine Yankee letter j of January 14,1997 to NRC).

j These problems appear to be similar in nature or follow from design related and i configuration control issues identified in the ISAT. On December 10,1996,you j submitted a plan to NRC in response to the ISAT report. Your response is balno reviewed by the NRC staff; results of our review will be provided upon its completion at a later time. From review to date, we note the plan does not provide details on the actions you intend to take to establish the extent and root causes of design related and configuration control problems which are being identified. It is important, however, that before restart you assess the current problems at Maine Yankee and their significance with respect to safe plant operation.

Based on a discussion of these issues on January 29 and 30,1997, between Mr. G. j Leitch of Maine Yankee and W. Kane and J. Zwolinski of the NRC, you committed to:

1. Submit an amendment request to the facility Technical Specifications (TS) to require that, when the reactor is critical, both 115 kV incoming lines shall be operable and allow continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with one line inoperable and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with both. lines inoperable. You will not restart the facility until !

the NRC staff approves revised TS to assure that the facility is operated consistent with the current licensing basis.

2. Assess the other developments discussed above in terms of their overallimpact on safe plant operations. This assessment will address your understanding of the extent of condition of the types of design and configuration controlissues noted above, the root causes of their existence, and a more complete definition of your plans to address these issues including actions that may need to be completed prior to restart of the plant. Meet with the NRC to discuss your response to these issues. You will provide a written response that provides I your assessment prior to the meeting. At the meeting you should also address the information and actions included in the original CAL 1-96-015. )

The provisions of the' original CAL 1-96-015' remain in effect.

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,. Pursu:nt to Section 182 ef th) Atcmic Energy Act,42 U.S.C 2232, you are requirad to:

1. Notify me immediately if your understanding differs from that set forth above;

2. Notify me if for any reason you cannot complete the actions within the specified schedule and advise me in writing of your modified schedule in advance of the change; and

3. Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter, issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.

In accordance with 10 CFR 2.790 of the PMC's " Rules of Practice," a copy of this letter, its enclosure (s), and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mM11 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial er financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Sincerely, ORIGINAL SIGNED BY:

Hubert J. Miller Regional Administrator Docket No. 50-309

Enclosure:

Maine Yankee Atomic Power Station - Offsite Power System i

ENCLOSURE

.s MAINE YANKEE ATOMIC POWER STATION - OFFSITE POWER SYSTEM By letter dated October 7,1996, the Chairman of the U.S. Nuclear Regulatory Commission (NRC) issued the report of the Independent Safety Assessment (ISA) of the Maine Yankee Atomic Power Company (MYAPCo). In the ISA report, Section 2.3.1, "115 kV Offsite l Power Lines," the NRC staff questioned the adequacy of conformance of the offsite power system at Maine Yankee Atomic Power Station (MYAPS) with the MYAPS licensing and design bases. The ISA's concern was based on a 1995 study of the 115 kV offsite power  ;

system conducted by Central Maine Power (CMP). As a result of the CMP study, MYAPCo concluded that one of the two 115 kV lines to MYAPS (referred to as the Suroweic line) would not recover voltage quickly enough after a fast transfer with a safety injection actuation signal and subsequent motor-driven feedwate'r pump auto-start. This would result in disconnection of the offsite reserve power and automatic start and loading of the station emergency diesel generators. This ISA issue was forwarded to the Office of Nuclear Reactor Regulation (NRR) for further staff review.  !

By letter dated November 21,1996, the NRC staff requested that MYAPCo clarify its understanding of the licensing basis of the offsite power system at MYAPS. MYAPCo responded in a letter dated December 12,1996. MYAPCo presented that Criterion 39 as stated in the MYAPS Updated Final Safety Analysis Report (UFSAR) remains as the licensing basis for the offsite power system. The staff understands that MYAPCo believes Criterion 39 is satisfied by the availability of the primary 115 kV line (referred to as the ,

Mason line) and a 345 kV backfeed using the station transformers that can be manually

! established within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

It is the staff's position that Criterion 39 requires two immediately available sources of l

offsite power and that the 345 kV backfeed does not satisfy this requirement. ,

Furthermore, the staff has reviewed the MYAPS docket and concludes that the staff I substantially relied upon the fact that MYAPS was designed to have two immediately available 115 kV power circuits when it granted MYAPCo an operating license.

, Accordingly, the staff concludes that MYAPCo needs to implement corrective actions to ensure operability of the Surowelc line before startup of the plant from the current maintenance outage.

On November 9,1996, with the Suroweic Ime out of service for breaker maintenance, the '

Mason line tripped due to catastrophic failure af a lightning arrestor. For a period of approximately four hours until the Suroweic line was restored, MYAPS operated without availability of offsite power. For over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, the facility operated without the qualified Mason line. The MYAPS technical specifications (TS) allow operation for up to 7 days without any 115 kV offsite power source available.

The staff has reviewed the MYAPS TS in light of the licensing basis concern and the l November 9 event. The staff has concluded that the MYAPS TS need to be amended to l require that both 115 kV lines be operable during reactor power operation. This action is needed to provide reasonable assurance that MYAPS will be operated in conformance with its current licensing basis.

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f EDO Principal Correspondence Control FROMt DUE: / /

i EDO CONTROL: G970078-DOC DT: 01/22/97 Hsnry Myers FINAL REPLY:

t TOs ,

Chairman Jackson i

FOR SIGNATURE OF : ** PRI **

CRC NO: 97-0110 i Zwolinski

,DESCs ROUTING:

MAINE YANKEE'S COMPLIANCE WITH COMMISSION Thompson REGULATIONS Jordan Norry Blaha Miller, RI DATE: 02/04/97 ASSIGNED TO: CONTACT:

NRR Miraglia I SPECIAL INSTRUCTIONS OR REMARKS:

Lotter to Myers signed by John Zwolinski 2/3/97 after review by Commission.

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, OFFICE OF THE SECRETARY  !

CORRESPONDENCE CONTROL TICKET

( PAPER NUMBER: CRC-97-0110 LOGGING DATE: Jan 31 97 ACTION OFFICE: EDO AUTHOR: HENRY MYERS AFFILIATION: MAINE ADDRESSEE: CHAIRMAN JACKSON LETTER DATE: Jan 22 97 FILE CODE: IDR 5 MAINE YANKEE

SUBJECT:

MAINE YANKEE i ACTION: Direct Reply DISTRIBUTION: CHAIRMAN, COMRS, SECY SPECIAL HANDLING: SECY TO ACK CONSTITUENT:

NOTES: CHAIRMAN SHOULE REVIEW RESPONSE PRIOR TO DISPATCH ,

DATE DUE:

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SIGNATURE: . DATE SIGNED:

AFFILIATION:

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l EDO .. G970078