ML20197B607
| ML20197B607 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/19/1997 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sellman M Maine Yankee |
| Shared Package | |
| ML20197B592 | List: |
| References | |
| EA-96-397, EA-97-375, EA-97-559, NUDOCS 9712240011 | |
| Download: ML20197B607 (15) | |
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1 DEC-19-19Fr ser42 u e m e Ri a r e cy a go ag'1 618:3752 4 P.82/26 NucLaAn psE1Ecommissa J
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IGNe of PRuss4. PUNNsnVANIA 1s001441s i
e Decostper 19,1997 i
EAs 80 387; 97 378;97 860 i -
Mr. Michael 5. Sellman, President 5
MeineYankee Atomic Power Company i
P. O, tor 40s Wiecesest, Maine 0457s
SUBJECT:
APPARENT VICLATIONS STEW 4ING FROM NRC OFMCE OF INVESTIGATIONS l
REPORT Nos.10F460,146425, AND 106443 i
l Deer Mr.Senmen:
l l
This refers 5 'M results of three investigstpons conducted by to NRC's Olloe of irweetigations I
(Of) sonoeming (1) the adequacy of your foollity's emell break lossef<noolers ecoldent (SBLOCA) emergency oore cooline eyelem (ECCS) analyses, (2) your submittal to the NRC of inacourate Information portaining to the cepeelty of the facility's atmospheric steam dump valves, and (3) a failure to perform etation test procedurse as required by foollity technleel spoolnestions. The timeframe for these investlestions spanned from December 1995 through Dateber 1997. The synopses of the referenced K 2;M:-r, reports are provided se Enclosures 1 through 3.
With respect to the first metter, beoed upon a technlost review and the results of the NRC OfRoe of investigations (01) Report No.1 06450 pertainin0 to your SBLOCA analyses, the NRC identined several apparord violations of NRC requirements, whleh are providad as Enclosure 4. It appears that Maine Yankee Atomic Power Co. (MYAPCo) failed to use the SBLOCA analysis required by facility technleet spoolfications effootive November 18,1991, to dearmine core operatine hmits for Cycle 12 and Cycle 13 operations, and that.MYAPCo provided inaccurate information material to l
tive NRC in foollity Core Operating Limits Reports, whleh steWd that MYAPCo had used the sulytical methods spoolflod by the facility technloal spealAcetiore to determine operating limits for 1-Cycle 12 and Cycle 13. It appears that omreiss disregard on the part of your staff contributed to l
heee apparent vioistions.
In addition, in apparent vloistion of 10 C.F.R. $ 50.46(e), MrAPCo used unacceptable evolustion models to determine ECCS performance for Cycle 14 opetutions and in the Core Performance Analysis Reports (CPARs) submlued to the NRC to support MYAPCo's islood analyses for Cycle i
14 and Cycle 15. Speelfloally, the ans!yses were not otpeble of accoMably calculatwig ECCS performence for the portion of the break spectrum betwoori 0.30ft' and at east 0.6 ft'. Thus,it was not possible to conArm hat he limit ne break had been idenillied and that the ECCS was onpable i
of m.tigating the most severe postulated socident in edriftion,it appears that MYAPCe maintained a motorielly - incomplete and innocurate Mns! Safety An@ sis Report and submitted meterially inecourste information to be NRC in that the assoolsted Cyo e 14 and Cycle 15 Core Performance Analysis Reporte did not reveal his inability to analyze me complete break spectrum, in vicistion of 10 C.F.R. 550.s(e), it also appears that MYAPCo used an unseele ECCs evaluation model for Cycle 14 operations and in the reload analyses for Cycle 14 and Cycle 15 in vlotation of l
- 10 C.F.R. $ 50.46(a), in that the 89LOCA analysis incorrec9y coloulated penetration factors and misapplied the Alt 4hambre correlation, tus overprod' ting core cooling and overstating the e
9712240011 971219 PDR ADOCK 05000309
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MC-19-19M 88142 (JgE Q!4FCOFIEG 421 61033752 4 P.83/16 Maine Yankee Atomic 2-l Power Company sonnenelem of the evaluation model. Pinah, il appears that MYAPCo used en unsoceptable "Seet EsWmste* SSLOCA enalysis, in vlotellon of 10 C.F.R. 6 50.46(a), to amiculste ECCS performance in eennection with a 10 C.F.R. I 80.00 anC ele of the eNeots of a reduction in steam generator
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Although the analyses Irwolved in the apparent violations dinouseed in he preceding peregraph were performed by your contreetor Yankee Atomic Electric Company (YAEC), it is apparent, based W the NRC technical review and Irwestige5on, met MYAPCo's oversight of YAEC modynies was not uficient to ensure compliance with regulatory requiremones. In partlouler, it appears met durine Cycle 14 operations N oculd not be determined whether the ECCS were capable of miliestine he moet severe postuisted sooident These apparent violations colleathely represent a potentish i
signmcent inck of attenson or onreieseness toward licensed responsibilmes and a failure to conduct adequale oversight of a vendor, renunin0 in the use of servloes of defoopve or indeterminate quelh.
1 With respect to the eeoond tratter, beood on the informston developed by of Report No.106426, i
it appears that, in vloistion of NRC requirements, MYAPCo willfuh provided motortah inecourote information regarding the cepeelty of the Atmospheric Steam Dump Valve (ASDV) to the NRC in a March 1988 submittel of the Procedures Generstion Pookage (PGP), which ir,eerperrM N reference revised Emergency Operating Procedures (dOPs).
Foollity personnel know at the f.n.o of the 1986 submittal of th PGp that the ASDV had a cepecify of 21/r%, and not 5% as refloated in the submittal. The apparent violation is provided as Enclosure 5.
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Whh respect to the third matter, bened on information developed tr/ 01 Report No.106443, it i
appears that MYAPCo vafully violated Technical Spoolflestion 5.8.2 and 10 C.F.R. I 50.9(a). Work orders speomed that spoemc contacts be vermed as open with a voll. ohm meter (VOM). The field enelneers performing the tests, however, obtained a quantmoble electrical resistonos value, Indicatine e pioblem instead of stopping the test and reconolling the discrepancy, the engineers documented that they vertfled even contacts ui the VOM, when, in actustity, they visually vermed that the contacts were open. The apparer. violates are provided as Erralosure 6.
Based on the extensiveness of the Irwestiestions, the NRC does not consider that further
- ,,: arder,is necessary to make en informed enforcement dealelon. However, enforcement ac6on wtl not be taken for these apparent vioistions until you have been provided on opportunity to either (1) respond to me apparent vlola6ons described above whhin mirty days or (2) request a predecisional enforcement conference. ConounenUy with this letter, the NRC stuff is issuing a Demand for Information (Demand) to YAEC and to Duke Engineering & Serviose Co. (DEAS)
(Enclosure 7). The Demand details the results of he NRC's imentigation into the ECCS matters discussed herein and requires that YAEC and DESS explain why the NRC should permit any NRC licenses to use their servkas to perform L.ess of Coolant Acoldent analyses or any esfoty rolsted enstyees to mest NMC requirements. Should you elect to request an enforcement conference, it is requested that you bring responsible personnel frorr, YAEC and/or DE&S. As part of any l
response or presentation at a predeciolonal enforcemord conference, you should address why the NRC should not consider het certain apparent violations desertbed herein were not the result of willfulness, defibersteness and/or careless disregard, on the part of your personnel. Consistent i
with the Enforcement Policy, a conference, if held, would be closed to public observation since the findings are based on Omos Of Investigation reports that have not been publicly disclosed. Please contact R Bellamy, Chief, Decommissioning and LAB Branch, at (610) 337-8200 within 7 days of me date of this letter to nopfy the NRC of your intended respones, t
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MC-19-1997 00:43 UpftC Ol/DFC OF IEG ADr1 6103375248 P.84/16 Mahe Yankee Atomic 3-Power Cortyny Please be advloed thet the encioned apporord violetions are in draft and may ohenge substantiety upon fur %r review of your response or your presentation et a p,wdeciolonel enforcement conference. You will be advised by separete correspondence of the results of our deliberstions on his mettei.
In accordance with 10 C.F.R. I 2.700 of the NRC's
- Rules of Practice,' e copy of this leger, ks enclosures, and your response wel be pieced in the NRC Pubile Document Room (PDR). To the extent pos91ble, your response shounci not include any personal putvooy, proprietary, nr esfoguards information so that h con be placed in the PDR without redsabon.
- SincerWy,
,w
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HubertJ. Miller Regional Administretor Dockat No. 60 300 Uoense No. DPR 36
Enclosures:
(1)
Synopsis of 01 Report 195450 (2)
Synopsis of 01 Report 196025 (3)
Synopsis of 01 Report 196443 (4)
Apparent Violations Assooleted wtth SBLOCA ECCS Analysis (5)
Apparent Violation Associeted with ASDV (6)
Apparent Violations Associated with Safety System Logic Testing (7)
Demand for Information (EA 97 387)
DEC-1F1W7 On 43 UEMC Cl/tFC OF EG Atri 6103375241 P.95/26 Maine Yar*ee Atomic 4
Power Company ocudensis:
D. Devis, Prealdent, Yankee Atomic IUectric Company (YAEC)
G. Lahoh, Moe Preeldent, Operations, WYAPCo M. Melaner, Mes President, Uneneing and Reguletory C;.T;"m, MYAPCo R. Freeer, Dweator o1En i
P. Anderson, Project U.;gineertne
+;+r. YAEC W.Odell, Director o10perations M. Ferri, Director of C+:eT.rd:55,:rg L DieN, Manager o1 Putdic and Govemmental Afleirs, MYAPCo J.Reinhor, Ropes and orey P. DoeWe, State of Maine Nuclear Saisty inopostor U. Venegs, State 01 Maine Nuclear Saisty Achisor C. Brinkman, Combust 4n En0 nes:ing, Inc.
l W. Meinert, Nucisar En0ineer, (nome of company)
First Selectmen eiWaconnet State of Meine Planniry 05cor Nuoleer Seisty Advisor State elMaine, SLO Dealenes State ot Maine Planning 05cor. Executive Departmord R. Shadis, Friends of the Coast l
t 0
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DEC-1F198/P 88:43 UDMC Ol/tFC OF MEG @i 6803375241 P.06/a6 1
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ENCLOSURE 1 S'HOPSIS OF OFFICE OF INVES11GATIONS REPORT No.196 60, WINE YANKEE A10MIC POWER STATION: ALLEGED DELIBERATE FAILURE TO COMPLY WITH NRC REQUIAEMENTS REGARDING THE ADEQUACY OF THE PLANTS EMERGENCY CORE OOOUNG SYSTEM AND MATERIAL OMISSIONS BY THE LICENSEE,' DATED SEPTEMBER 6 1996 On December 8,1995, the Nuclear Reputatory Commisolon's (NRC) Office of invoobgabons (OI),
Region I, initiated thi6 investigation in response to anonymous allegations that were made public in early December 1995, r*0erding, among other things, the adequeoy of the Emergency Core Cooling System (ECCS) at the Malro Yankee (MY) Atomic Power Station Wiscosset, Maine.
Generally, it was alleged that Maine Yankee Atomic Power Company (MYAPCo), in concert with Yankee Atemic Electric Company (YAEC), Knowingly performed inodoquate small break loss.of-ooolant accident (SBLOCA) analyses of the ECCS and deliberately misrepresented the anahoes to th6 NhC.
SpecMcally, the 01 investigation soupit to dete'mine: (1) whether MYAPCo deliberately failed to implement, for fuel Cycles 12 and 13, the RELAP5YA SBLOCA analysis, as accepted and approved by the NRC in a January 1989 Safety Evolustien Report (SER): and (2) If
- the RELAP5YA computer code was deliberately implemented in June 1993, for Cycle 14, in a manner that did not conform with the SER and the requirements of 10 C.F.R. 50.48.
Based on the evidence developed during this investigation, Of concludes that (1) for the period June 1990 through May 1993 (during Cycles 12 and 13), MYAPCo willfully failed to implement an acceptable EM (the REl.AP5YA SBLOCA analysis approved by the NRC via a January 1989 SER) as required by 10 C.F.R. 50A6; and (2) MYAPCoryAEC willfully failed to implement the RELAP5YA EM, in the June 1993 enalysis for cycle 14, in a manner consistent with the NRC's January 1989 SER and the requirements of 10 C.F.R. 50.46.
DEC-19-1997 98543 ISRC Ql/OFC OF REG ADM 6803T/534a F,07/16 I
ENCLOSURE 2 POWER STATeON: INACCURATE IN CAPACITY OF THE ATMOSPHERIC 6 TEAM DUMP,* DATED JUNE 27,199 Imrestigations (OI), Region 1, on JJy 11,1996This investig&5 Atmospheric Steam Dump vsVe (ASDV) to the N Generation Package (PGP), whloh incorpointed, tr/ reierence, rev Procedures (EOPs).
Based upon the evidence developed during this investigation, k is concl provided inaccurate inbrmation regarding the capachy o1 the ASDV to th y
submittaleithe PGP.
MCpN De
- U!Ntc Rl/DFC OF REG ADr1 680M4 P.08/%
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l ENCLOSURE 3 SYNOPSIS OF OFFICE OF INVESTIGATION REPORT NO.196443,'MAlh* YANKF?, ATOM!C POWER STATION: FALSIFICATION OF TEST RECORDS DY UCENSEE ENGINEERS,' DATED OCTOBER 31,1997 This invee6gstion was initiated by the Nuclear Reguistory Commisalon (NRC), 05ce of Irwes5ga6ons (Of}, Region I, on November 14,1996, to determine whether two electrical engineers (EEs) of the Meine Yankee (MY) Atomic Power Company, working at the MY Atomic Power Station, Wiseasset, Maine, Wstied separate test records in August 1996, which irwolved the electrical testing of equipment important to saisty.
Based on the evidence developed during this investigation, it is concluded that the two EEs isisNed test records by deliberately violating technical spec 5cetion required procedures that controlled saiety related testing. SpecMes!!y, Ol's investigation determined that the EEs imited to conduct an electrical test as written in an approved work order, initiated the test record gMng the appearance that the test was satisimetorily conducted as written, and intled to note the change in the test method that was actually implemented.
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DEC-19-8977 88 44 USMtC Rl/0FC OF REG Atri 618337524a P,09/16 l
ENCLOSURE 4 l
APPARENT VIOLATIONS ASSOCIATED WITH ECCS ANALYSES (01 REPOR 1 95 060)
A.
APPARENT VIOLATIONS RELATING TO OPERATING CYCLE 12 l
1.
Technical Spectication (TS) 5.14.2, ' Core Opers6ng Limns Report," ior me Maine Yankee Atomic Power 8te6en (MYAPS) become eflective November 18,1991, and requires, in part, that analytical methods used to determine operating limits shall be l
timited to those previously invlowed and =gs.d by NRC, as listed by TB 3.10.
l TS.3.10 lists a Small.8reak Loss 45 Coolant (S8LOCA) anefysis, "YAEC 1300P, RELAP5YA A Computer Pmeram ior Light Water Reactor System Thermal-Hydraulic Anotysis, Volumes 1,2,3, dated October 1982"(RELAP5YA). TS.3.10.
does not spec 4 any saLOCA analytical method deve'oped by Combusbon A. mering Corpore 6on (CE)ior SBLOCA analysis.
haaver, between November 18,1991, and February 14,1992 (during Cycle 12 operations), Maine Yankee Atomic Power Company did not determine operating limits ior Cycie 12 opers6ons using the RELAP5YA SBLOCA analysis required by TS 5.14.2. In iset, a CE SBLOCA code was used to prepare the reload analysis, as stated in the Core Petrmance Analysis Report 1or Cycle 12 at Sectum 5.5.5.3.
2.
10 C.F.R. I 50.9(a) reqvtres, in part, that iniormation provided to the Commission by a licensee shall be complete and accurate in all material respects However, on December 18, 1991, Maine Yankee Atomic Power Company (MYAPCo) pmvided to the Commission MYAPCo's Cycle 12 Core Operating Limits Report (COLR), which contained inecourste information material to the NRC. The COLR stated that MYAPCo used anatytice! methods listed in TS 5.14 to determine operating limits. In tact, MYAPCo used the Combustion Engineering Small Break Loss o$ Coolant Accident (SBLOCA) analytical method, which was not lated in TS 5.14. The SBLOCA analytical method listed by TS 5.14 is "YAEC 1300P, RELAP5YA A Computer Program 1or Light Water Reactor System Thermat-Hydraulic Analyse, Volumes 1, 2, 3, dated October 1982" (RELAP5YA). This innocurate '..LiTr,siion was motorial to the NRC because !! was a representation that RELAP5YA, which had been approved 1or spplication to Maine Yankee Atomic Power Station pursuant to the Three Mile Island Action Plan, item II.K3.30 (NUREG 0737), had boon used in concert with other approved codes to establish more operating limits ior Cycle 12 operations.
G.
APPARENT VIOLATIONS RELATING TO OPERATING CYCLE 13 1.
Technical Specitostion (Ts) 5.14.2, ' core Opowns umits Report," tor the Maine j
Yankee Atomic Power Station WAPS) requires, in part, that analytical methods used to determine operating Emits shall be limited to those previously reviewed and i
approved by NRC se listed by TS 3.10. TS.3.10 speciles a small-Break Loss ci-Coolant (SBLOCA) analysis, "YAEC 1300P, RELAP5YA: A Computer Program ior Light Water Reactor System Thermal-Hydraufic Analysis, Votumes 1,2,3 dated October 1962" (RELAP5YA). TS.3.10. does not specliy any SBLOCA analysis
[
produced by Combustion Engineering Corporation (CE).
n
.DEC-19-1997 80844 UHtC R14FC OF REG ADr1 6803375248 P.1B/16 However, between Aptti 19,1992 and July 7,1993 (durtne Cycle 13 operations),
Maine Yankee Atomic Power Company did not determine operating limits br Cycle 13 operations using the RELAP5YA 88LOCA analysis required by T8 5.14.2. In inct, a CE 88LOCA code was used to prepare the reload analysis, as stated in the Core Perbrmance Analysis Report br Cycle 13 at Sec6cn 5.5.5.3.
2.
10 C.P.R. 5 80.9(a) requires, in part, that iniormsbon provided to the Commission by a Boonsee that! be complete and accurate in all meterial respects.
However, on April 7.1982, Maine Yankee Atomic Power Company (WAPCo) provided to the Commission MYAPCo's Cycle 13 Co o Operating Umhs Report (COLR), which contained inaccurata inbrmation material to the NRC. The COLR stated that MYAPCo used analytical methods listed in TS 5.14 to determine operating Emits, in 1 set, MYAPCo used a Combustion Egineering Srnall-Break Loss 4Coolart (SBLOCA) analysis, which was not listed in TS 5,14.
The SBLOCA analysis Ested by TS 5.14 is "YAEC 1300P, RELAPSYA: A computer Program 1er Ught Water Reactor System ThermeLHydraulic Analysis, Volumes 1, 2, 3, dated October 1982" (REl.AP5YA). This Insecurate intormation was material to the NRC because it was a representation that RELAP5YA, which had been approved br application to MYAPS pursuant to the Three Mile lefand Action Plan, item II.K.3.30 (NUREG 0737), had been used to establish core operatine limits 1or Cycle 13 operations.
C.
APPARENT VIOLATIONS RELATING TO INABILITY iO ANALYZE ENTIRE BREAK SPECTRUM FOR CYCLE 14 10 C.F.R. l 50,46(a)(1) requires, in part, that emergency core cooling system (ECCS) periormance must be calculated with an acceptable evaluation model and must os calculstad br a number of postulated loss ovooolant accidents 01 diflerent sizes, locations, and other properties suficient to provide assurance that the most severe postula:ed loss-of coolant 1
accidents are calculated.
10 C.F.R. Part 50, Appendix K, Section 11.4. requires that to the extent practicable, predictions althe evaluation model, or portions thereci, shall be compared with applicable experimentaliniormabon.
However,1 rom O.:tober 14,1993, through January 25,1995 (during Cycle 14 operations),
and in the Cycle 14 Core Perbrmance Analysis Report (CPAR) submitted August 25,1993, Maine Yankee Atomic Power Company (MYAPCo) inlied to calculate a number 01 postulated loss ovcooiard socidents of diflerent alzes, locations, and other properties au5clent to provide assurance that tw most severe postulated loss.c$. coolant occidents were calculated, because there was a portion c1 the smaff-break spectrum between.35 t' and at loest.St' ior which no ecooptable code was capable ci calculating cooling perbrmance or reliably I
i calculating coolino periormance MYAPCo calculated SmalLBreak Loss-et Coolant Accident (SBLOCA) ECCS perbrmance up to the.35t' break sire, using the code described in "YAEC 1300P, RELAPSYA: A Computer Program br Light Water Reactor System Thermal-Hydraulic Analysis, Volumes 1, 2, 3," dated October 1982 (RELAP5YA) and the plant spectic RELAP5YA SBLOCA evaluation model described in YAEC 1868, %Ine Yankee Small Break LOCA Analysis" (both oi which were described as an Appendix K-2 i
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DEC-19-8997 asi44 UDPC Rl/DFC OF REG ADM 6103375248 P,11/16 i
3-appromoh to RELAPSYA), The RELAPSYA 88LOCA evolus6on m:xsol documented in YAEC-1888 was incapable cicoloulahna ECCS pertormance br breaks of and greater then 0.35 t' boosuse the code terminated stor tw seisty irgeo6en tank actuoson due to numerical convergence errore 1er Die break of.SSW. MYAPCo omlaulated Large-Break 1
Loss-o& Coolant (LBLOCA) ECCS Periormance with the LBLOCA enelysis desertbed in YAEC 1180, " Application o1 Yankee WREM-Based Generic PWR ECCS Evaluation Model to Maine Yankee", dated July 1978 (WREM). Although the WREM LSLOCA evaluation model was demonstrated in 1996 to be capable of coloulatin0 ECCS periormance down to the.Sta break size, the evaluation model was not used to esloutste ECCS perbrmance in the small break region for tie Cycle 14 CPAR, and would not have been acceptable to calculate ECCS periormance for break stees in the small break region of 0.8W and above because the evolustion model was not compereci to appilomble experimental data to honstrate its reliabulty in uniculating ECCS potiormance in the small-break re0 ion.
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C, APPARENT VIOLATIONS RELATING TO INABilJTY TO ANALYZE ENTIRE BREAK SPECTRUM FOR CYCLE 15 10 C.F.R. $ 50.46(a)(1) requires, in part, that emergency more cooling system (ECCS) perbrmance must be calculsted with an ecceptable evaluation model and must be coloulated br a number o1 postulated loss-otoootant scoldents oi dliterent sizes, loostions, and other properties suScient to provide assurance that the most nevere postulated loss.o5 coolant occidents are calculated.
10 C.P.R. Part 50, Appendix K, Section 11.4. requires that to the extent practicable, the predictions of the evalua6an model, or portions therect, shall be compared with applicable exPerimentaliniormation.
However,in tie Cycle 15 Core Periormance Analysis Report (CPAR) submitted December 1, 1995, Maine Yankee Atomic Power Company (MYAPCo) imited to calculate a number ei l
postulated loss-ovcoolant accidents of ditteront stres, loostions, and other proportes suMcient to provide assurance that the most severe postulated loss ovooolant accidents were no!culated, boosuse there was e portion of the small break spectrum between.35 t' and at least.8W ior which no acomptable code was onpable oi calculating cooling performance or reliably osiculati cooling parbrmance. MYAPCo calculated Small-Break 2'
Loss circontent Accident (SBL
) ECCS perbrmance up to the.36t* break sise, uomg the code described in "YAEC 1300P, RELAP5YA: A Cornputer Program br Light Water Reactor System TNiird 44,wille Analysis, Volumsw 1, 2, 3,' dated October 1982 (RELAPSYA) and the plant speclic RELAP5YA 88LOOA evolustion model described in YAEC-1864, " Maine Yankee Small Break LOCA Analysis" (both oi which were described as en Appendix K approach to RELAP5YA). The RELAP5YA 88LOCA evaluebon model i
documorded in YAEC 1868 was incapable of calculating ECC8 perbrmance 1or breaks of and Greater tien 0.35 t' because the code terminated stor the asisty ir(oction tank actuartlen due to numerical convergence errors 1or the break of.35t'. MYAPCo coloutsted Lege Brook Loss-ovCoolant (L8LOCA) ECCS Periormance with the L8LOCA analysis
. desc Ibed in YAEC-1160, " Application of Yankee WREM Based Generic PWR ECCS L
Eva!uation Modo! to Maina Yankee", dated July 1978 (WREM). Although the WREM l
LBLOCA evaluation model was demonstrated in 1996 to be capable ci calculatin0 ECCS periormance down to the.8W break size, the evolus6on model was not used to calculate ECCS porbrmana in the small-break region br the Cyde 15 CPAR, and would not have l
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esc.19 1997 e
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Ertolosure 4 t been encontable to oslaulate ECCS periormanos br 01 0.898 Ond above because the evalueton model was not compa on emportmanisidets to demonstrets its reliabilityin omlaulatin p cable
, break region.
E.
INCOMPLETE AND INACCURATE CORE PERPO i
10 C.F.R. I 80.9(s requirse, in part that informsson pnwi applicant 1er a licen)se or a lloonees o,r inbrma n
re0ulations to be maintained by the llooneee or the applicent in allmeterialroepeats.
10 C.F.R. I 80.71(e)(8) requime each person licensed to op pursuant to 10 C.F.R. 5 50.21 or 50.22 to retain the updated or (FSAR) until the Commisalon terminates the Econes.
10 C.F.R.
portrmanos$ 80A6(s)(1) requires, in part, that br a number o1postuisted loss ovooolant socklents of difleren properties suMcient to provide assurance that the most severe accidents are calculated.
ovatus6on model, or portions thereof, shall information.
meterialtespects. The FSAR incorporates Appendix D. 'lho CPARs used by MYAPCo to support its Cyc relied upon an Emergency Core Cooling Perb ns i
(SBLOCA) ovalua6on model described in YAEC 1868, 'Wlaine AneWis"(YAEC-1888), and incorporated YAEC 1868, which was in all material respects. YAEC 1868 described the plant-specMe Reactor System Thermal-Hydraulic Analysis l
o e
(RELAPSYA). Both YAEC 1868 and RELAPSYA were Appendix I
oi ECCS pertwmanos. YAEC 1868 included the iallowing statements:
a on analysis o1 ECCS performanos] hence cons "Eyslustions [oi "The larg[est break size analyzed ior Maine Yan These statements are incomplete end ineocurat his described by YAEC-1866 ialled to calculate a number of postul aidmorent sites, lomtions, and other properties suWcient to pro severe postuisted loss ovcoolant poddents were calculated, becau 1,
oi the small break spectrum between.35 t' and at least.St' ior w was capable of calculating or re!! ably cooling portrmance. The RELA analysis described in YAEC 1868 was incapable ci calcule6ng EC i
Mc-sea m as:4s.
usme olec or us mor.:
a gag l
t brooks ei and prester than 0.35 f boosues tne code twminated stor the saist tank actustion due to numeriosi sonvergence errors 1or the break at.36f. y::qoction MYAPCo i
coloulsted Larp> Break LasedCW (L8LOCA) ECC3 Periormance with the L8LOCA onelysis described in YAEC-1180, "Appliostion of Yankee WREM-Based Generic PWR ECC8 Evaluation Model to Maine Yankee", dated July 1978 (WREM). Although the WREM 1
LBLOCA evaluation model was demonstrated in 1996 to be sepable of calculating ECG8 periormance down to tie.0F break sire, the evolusilon model wee not used to coloulate ECCS periormanos in the smalkbreak region 1er the Cycle 14 and 15 CPARs, and would not have boon soceptable to coloulate ECCS periormance 1or break stres in the smalktreak region of 0.8f and above boosuse the evaluation model was not compared to applicable superimental data to demonstrate its reliability in coloutsting ECCs periormance in the smalk break region. The inaccurste and incomplete etstements in YAEC 1868 were meierial to the NRC because they concealed that the complete break spectrum had not been analyzed and that, contrary to the requirements o110 C.F.R. I 50.46(a)(1), there was a portion ei the break spectrum between.35W and at least.0f 1or whleh no soceptable code was capable l
ol osiculating cooling p#ss.w or reliably omloulating cooling periormance.
I F.
APPARENT VIOLATION RELATED TO NPROPER APPUCATION OF ALS CHAMBRE CORRELATION FOP. CYCLE 14 l
l 10 C.P'.R. 9 50.46(a)(1) requires, in part, that emergency core cooling system (ECCS) perintmance must be calculsted with an acceptable evolustion model However, tom October 14,1993, through January 26,1995 (during Cycle 14 operations),
and in the Cycle 14 Core Periormance Analysis Report (CPAR) submitted August 25,1993, MYAPCo calculated ECCS periormance 1or 85LOCAa with an unacceptable evaluation model. MYAPCo used the ECCS code described in YAEC-1300P, "RELAP5YA: A Computer i
Program tor Ught Water Reactor System ThermahHydraulic Analysis, Volumes 1,2, 3,"
dated october 1982 (RELAP5YA), and the plant speelle RELAPSYA SBLOCA evaluation model described in YAEC 1868, " Maine Yankee Small Brook LOCA Analysis" (YAEC-1968).
RELAP5YA as applied was not an acceptable evaluation model because the nodalization model oi YAEC 1868 nroorrectly applied the AltrCharnbre correlation, which caused incorrect coloulations ci penetration 1ectors and the oroes 10w resistance 1ector, and which as a result ur-=r*% overpredicted cooling performance and overstated the conservatism c1RELAP5YA.
G.
APPARENT VIOLATION RELATED TO IMPROPER APPLICATION OF ALS CHAMBRE CORRELATION FOR CYCLE 15 10 C.F.R.
periormanc$ 50.46(a)(1) requires, in part, that emergency core cooling system (EC e must be calculsted with an acceptable evaluatica modet However,in the Cycle 15 Core Periormance Analysis Repost (CPAR) eubmitted December 1.
1995, MYAPCo calculsted ECCS pertormance 1or 88LOCAs with an uneoceptatfe evaluation model MYAPCo used the ECCS code described in YAEC-1300P,"RELAP5YA' A Computer Program ior Light Water Reactor System ThermaLHydraulic Analysis, Volumes 1, 2, 3," dated October 1982 (RELAP5YA), and the plant-specite RELAP5YA SBLOCA evaluation moder described in YAEC 1868, Waine Yankee Small Break LOCA Analysis" i
(YAEC 1868). RELAP5YA as applied was not an acceptable evaluation model because the
DEC-19-1997 88146 UpftC QI/0FC CF REG firl 610337524a P.14/16 f.nolosure 4
,6-couesd incorrect *Mwe of penetration factor which as e issuR unsocoptatWy overpredicted cooRnf performa i
ooneervatism of RELAP6YA.
H.
PRESSURE POR CYCLE 14APPAREN1 MOLATIO 10 C.P.R.
performanc$ 50,46(a)(1) requires, in part, that amergency core c e must be esiculated with an ecoeptable evaluation model with the required and soonstable features of Ap 10 C.F.R.
However, in a January 1993 analysis of a doorosse in stamm ge pursuant to the requirements of 10 C.FA $ 50.69, MYAPCo used an evalue60n model to coloulate Small-Break !m 4 Coolant (SBLOCA MYAPCo used a Best Estimate (BE) plant-apecific evatus6on 1,1990, report produced by Yankee Atomic Ebotric Company) to i code deswibed in YAEC 1300P, "RELAPSYA: A Computer Program System Thermat-Hydraulic Anahsla, Volumes 1,2,3," dated O applies 6on to Maine Yankee Atomic Power S i
model. Furthermore, contrary to 10 C,FA Part 50, Appendix K, the B i
amiculated decoy heat with the 1979 ANS Standard rather than 20 percent, and celaufsted the two phase critical flow with the REL i
rather than the Moody critical flow model.
4
.u-.
.~. -
... ~ _
DEC-19-1997 88:46 UlHtC Rl/0FC OF REG RDM 6183375241 P.15/16 ENCLO8URE5 APPARENT VIOLATION ASSOCIATED WITH PROVIDING INACCURATE INFORMATION TO THE NRC RELATIVE TO THE CAPACITY OF THE ATMOSPHERIC 8 TEAM DUMP VALVE (Oi REPORT No.106025) -
I Section 186 of the Atomic Enegry Act c11954, as amended, requires licensees to ensure that all submissions to the NRC be complete and accurate in all material respects.
i However, the licenses submlued a Procedures Generation Package on March 18,1986, which contained a materially inaccurate statement. Speellently, the licensee stated that the Atmosphenc Dump Valve (ADV) had a 5% bypees especity, when in inct it had a 2% % cepecity. The submlasion was made to demonstrats coniormance to NUREG4737, "Clartimtion of TMI Action Plan Requirements'. Action item I.C.1,
- Guidance for the Evaluation and Developmern c1 Procedures ior Transients and Accidents'. The ineocurate statement was material to the NRC because the relici capacity relatas to the ability to adequately achieve core cooling.
TIEC-19-1997 88146 LD#tC Ql/tFC CF MEG RDr1 61033"75241 P.16."16 L
ENCLOSURE 6 APPARElfT V)oI.ATIONS A880CIATED WrrH SAFETY SYSTEM LOGIC TES REPORT No.10H43)
A.
Technioni speomosson 5.s.2 sistes, h part, met wrttien procedures be established, Implemorded, and maintelnad to control, among other things, actMues conoeming testing l
of safetyroteled equipment.
item 12 of Attachment C to Procedure No. 4163, ' Work order Process," dennes a l
Punctional Test instrudion (PTI) as instructions that denne the evolutions or opere5ons necessary to prove functionanly or operability of a component, system, or strudure.
Precaution 3.1 of Work Order 960292840, Attechment A, Yunctional Test for P-14A/S on A Train SIAS and Bus 5 Undervoltage,' and Work Order 9602929 00, Atevnment A, Tunctional Test for P.14 B/B on 5 Train SIAS and Bus 8 Undervoltage,' states that if any stop cannot be completed as specified in the FTI, then the Field Engineer must be contacted and any devletion from this FTl must be authorirod in socordance with Procedure 016 3.
Deviations to FTis are permitted through the use of Minor Technical Changes (WTC) as described in them 13 of Attachment C to Procedure No. 016 3.
However, on August 22,1996, Step 5.3.3 of WO 964292840 and WO 964292940 could not be performed as written, and the licensee 8 ailed to resolve the discrepancy by meldne a Minor Technical Change. Specifically, Step 5.3.3 provided that at Main Control Board (MCB), Section C, open circuit contimity be verffled at 46-RASA-2(YAF) using a voltehm meter (VOM) across the 5 5C contacts. The field test engineers could not vertfy the open contacts with a VOM beooues of resistance in the circuit onused by a bulb and resistor wired into the circuit. Instead of making a MTC to permit visus! vert 6 cation, the fleid engineers vertned open circuit continuity visually and signed Step 5.3.3 as satisfactorily completed.
B.
10 C.F.R. $ 50.9(a) provides in part that information required by the Commission's regulations to be maintained by the licenses to be complete and accurate in all material
, spects.
10 C.F.R. Part 50, Appendtx B, Crtherion XVil, " Qual!ty Assuranos Records,' requires, in part, est records of tests afrecting quantybe maintained.
However, on August 22,1996, the licensee created test records that were materially inaccurate. Step 5.3.3 of WO 964292840 and WO 9642929 00 provided that et MCB, Section C, open circuit continuity be vertfled at 84RASA 2(YAF) using a volt-ohm meter (VOM) scross he 5-5C contacts. The Bold test engineers could not verify the open contsets with a VOM because of resistance in the droult caused by a tmlb and resistor wired into the circuit. Instood, the field test engineers vertfled open circuit continuity visually and signed Step 5.3.3 as antisfactority completed. These inaccurseles were material because the tests concemed functionality or operablitty of safety-related components.
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