ML20210J639
| ML20210J639 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/11/1997 |
| From: | Hebert J Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-309-97-05, 50-309-97-5, JRH-97-190, MN-97-94, NUDOCS 9708180203 | |
| Download: ML20210J639 (8) | |
Text
Ee y,
g, MaineYankee REl.lABLF f LECTRICITY SINCE 1977 329 BATH ROAD e DRUNSWICK, MAINE 04011 * (207) 798 4100 August 11, l^7 MN 97-94 JRH-97-190 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk
-Washington, D.C.
20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo, dated July 11,1997, Notice of Violations for NRC Inspection Report 50-309 / 97-05
Subject:
Reply to Notice of Violations Associated with NRC Inspection Report No. 50-309/97-05 Gentlemen:
.n The attachmem to this letter provides Maine Yadkee's reply to the Notice of Violations contained in reference (b). Included in this response is the reason for each violation, corrective actions / actions to prevent recurrence and the full compliance date. After re-evaluation Maine Yankee is contesting the second example of violation "C" and violation "D" for the reasons stated in the attached i
response.
Maine Yankee would like to correct two statements made in this inspection report.
1)
On page two of the Executive Summary. " The refueling reactor coolant system (RCS) boron concentration was 1,803 ppm (Tec. Snees. Reauires minimum of 1.750 nomL" It should read as follows: The refueling reactor coolant system (RCS) boron concentration was
~
1,803 ppm (Tec. Specs. requires the refueling boron concentration be maintained to insure that it is sufficient to maintain the core 5% delta k/k suberitical)."
2)
On page eipt, the conclusions for Operations Section OS.I. The conclusions stated that Maine Yankee completed the corrective actions and then submitted a request for an exemption from 10 CFR Part 70.24, when in fact it was the opposite. Maine Yankee submitted the request for the exemption (December 19,1996) first and then started the corrective actions, which were completed by the end of February,1997.
Please contact us should you have further questions regarding this matter.
. ery truly yoursq.nt-w j
hmes R. Hebert, Manager
' Licensing & Engineering Support Department I
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I Enclosure C
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Mr. Hubert Miller Mr. J. T. Yerokun Mr. D. H. Dorman
,n, Mr. Patrick J. Dostic g{g l llgl[g
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Mr. Uldis Vanags 9708180203 970811 PDR ADOCK 05000309
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a REPLY TO NOTICE OF VIOLATIONS Violation "A" Technical specification 3.13, Refueling and Fuel Consolidation Operations, requires in part A," Prior to each refueling a complete checkout shall be conducted on fuel handling cranes that will be used to handle irradiated fuel assemblics."
Contrary to the above, from May 19,1997, through May 26,1997, there were three instances of inadequate checkouts performed on fuel handling cranes by Maine Yankee as follows:
On May 19,1997, Maine Yankee identified that a previously untested spent fuel pool crane interlock failed to function. The interlock was designed to protect fuel from inadvertent raising or lowering during trolley or bridge operation.
On May 25,1997, the mechanical stops to limit crane travel in the north direction were found mis-positioned during fuel movement. The stops were designed to prevent fuel damage due to rimning into the side of the pool.
On May 26,1997, Indicator lights for the load indicator of the fuel transfer machine were not functioning properly and had not been tested prior to use. The lights were designed to indicate the proper load indicator scale to be monitored to prevent damage to a fuel bundle during transport through the refueling canal, i
Maine Yankee Response:
Maine Yankee agrees with this violation, each of the three instances above were the result of a less than adequate checkout of refueling equipment. When checks were made they were performed in accordance with phmt procedures based on FSAR information which is referenced by Technical Specification 3.13 basis. The basis information is general in nature and thus the checks were limited m scope.
Immediate Corrective Actions:
The immediate corrective action in each of the three events was to stop fuel movement in accordance with our fuel handling procedures. Fuel handling did not resume until necessary corrective actions were put in place. Actions taken to the specific events are as follows:
(1) Untested Interlock - Leaming bank entry 97-02560 was written and an evaluation of the event was performed. The following corrective actions were in response to that issue and evaluation.
Technical Evaluation 162-97, CR-9 Interlocks was developed to identify all required interlocks on that crane. The Technical Evaluation included a walk down of the system, reviews of the Purchase orders, vendor Manuals and a review of NUREG-0554, Single-Failure Proof Cranes for Nuclear Power Plants. As a result of that Technical Evaluation hardware changes were made to restore the function of the hoist interlocks, fast function of the hoist was removed, and the breaking scheme was changed to remove the " ramping" feature of the breaks. Ops Procedure 3-1-10 was revised to include the new testing requirements and was performed prior to use of the equipment.
(2) Mis-positioned Mechanical Stop - Learning Bank entry 97-02640 was written and an evaluation of the event was performed. The stops were restored to the correct position. The correct position of the stops were marked locally and procedure 13-2, Fuel Handling In the Spent Fuel Pool, was revised to ensure correct installation of the stops.
1
(3) Indicator lights - An Operations Stand Down with a Manager of Operations hold on any fuel movement was put in effect until corrective actions could be identified and taken. Operators on the centairanent Transfer Machine were relieved of that duty pending review of their actions. Leaming Bank entry 97-02681 was written and an evaluation of the event and an aggregate review ofrefueling events was performed. Engineering performed an evaluation of the vendor recommended testing of the Refueling Machine, Upender, and the Transfer Machine. Corrective actions prior to fuel movement included: Training and assessment of Operator knowledge of the refueling procedures and processes. The principles of Stop Think Act and Review (STAR) were reinforced with the refueling personnel. Affected procedures were revised to address testing and. expected light indications. Procedures 13-2, Fuel Handling in the Spent Fuel Pool,13-3, Transfer Machine and Upender Operation,13-4 Refueling Machine Operation, were validated and functional testing was performed using a dummy fuel asambly. Procedure 3.1.10, Refueling Systern Interlock Test, was revised to include new testing and testing was completed.
Corrective Actions Taken to Avoid Further Violation:
The immediate corrective actions identified in this response are sufficient to prevent reoccurrence.
Full Comollance Date:
Ffa compliance was achieved on 05/26/1997 when all refueling efforts were halted by the Operations Stand down. Refueling activities were resumed aller corrective actions were identified and implemented.
Violation "B":
10 CFR 50, Appendix B, Criteria XVI Corrective Actions, requires in part, that in the case of significant conditions adverse to quality, measures shall assure the cause of the condition is determined and corrective action is taken to preclude repetition.
Contrary to the above, on May I 8,1997, damage to a 480 volt electrical cable during fuel movement with the spent fuel pool crane, a significant condition adverse to quality, was identified that should have been prevented by corrective actions taken for a March 4,1997, event involving running the spent fuel pool crane into a safety rail stanchion.
Maine Yankee Response:
Maine Yankee agrees with this violation. Although corrective actions resulting from the earlier event were in place, they were not adequate in preventing the less than adequate performance of the operator in the second event.
Immediate Corrective Actions:
Fuel movement in the spent fuel pool was stopped in accordance with Maine Yankee procedures.
The operator in charge was relieved of duties in moving fuel and was disciplined. Learning bank issue 97-02543 was written. Evaluations were performed to assess crane damage, operability and reportability. Procedure 13-2, Fuel Handling in the Spent Fuel Pool, and 13-4, Refueling Machine Operation, were revised to require a walkdown of the crane travel path after breaks and maintenance activities. Operations conducted standdown meetings for all fuel handling crews. Rad Protection, Maintenance, and Reactor Engineering management conducted standdown meetings for all personnel involved with support of the Spent Fuel Pool area work, including fuel moves. Power cables and hoses which could impact the rails or refueling equipment operation were taped with yellow tape to increase visibility. The Maintenance Planner guidance was revised to require final walkdowns as part ofwork closcout in the Spent Fuel Pool and Reactor Cavity areas. The March 4 event was reviewed to ensure corrective actions were adequate to prevent similar occurrences.
l a
Corrective Actions Taken to Avoid Further Violation:
The corrective action process procedure 0-16-1," Learning Process Implementation Procedure" is being revised (Rev 11) and streamlined to provide more effective and timely root causes and corrective assignment.
Eull Compliance pate:
Full compliance was achieved on May 18,1997, when svork was stopped. Work was recommenced after an evaluation identified immediate corrective actions and those corrective actions were implemented.
Violation "C":
10 CFR 50.55a(a)(3) requires, in part, that proposed alternatives to the inservice test (IST) requirements of paragraph (0 must be authorized by the Director of the Office of Nuclear Reactor Regulation. Paragraph (0(4)(ii) requires that inservice tests to verify operational readiness of pumps and valves whose function is required for safety must comply with the requirements of the latest edition of the code incorporated by reference in paragraph (b). The Maine Yankee IST program utilizes the 1986 Edition of Section XI of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code.
10 CFR 50.55a(0(4)(iv) states that inservice tests of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) subject to l
Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. On September 8,1992, the commission incorporated the 1989 Edition of the ASME Code in paragraph (b), including Part 6 (OM-6) and Part 10 (OM-10) of the ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987.
OM-6, paragraph 6.1 requires that if pump performance deviations fall within the alert range of Table 3, the frequency of testing shall be doubled until the cause of the deviation is determined and the condition corrected. Table 3a specifies that the maximum vibration alert limit for vertical line shaft pumps is greater than 0.325 inches per second.
The NRC Safety Evaluation Report for the Maine Yankee third 10-year interval IST program, dated June 30,1994, approved the use of reference values to evaluate power-operated valve stroke time measurements pursuant to OM-10 in lieu of the methods prescribed in Section XI, Article IWV-3417(a) of the code (1986 Edition), provided all related test method and corrective action requirements of paragraphs 4.2.1.3 through 4.2.1.9 of OM-10 were implemented.
Contrary to the above, alternatives to the IST requirements of 10 CFR 50.55a(0 were implemented without the authorization of the Director of the Office of Nuclear Reactor Regulation as follows:
(1)
Since December 28,1992, reference values were used to evaluate power-operated valve stroke time measurements pursuant to OM-10 in lieu of the methods prescribed in Section XI, Article IWV-3417(a) of the code (1986 Edition), and the related test method and corrective actions requirements of paragraphs 4.2.1.3 through 4.2.1.9 of OM-10 were not implemented.
(2)
In June 1996, an attemative maximum vibration alert limit in excess of the limit specified in Table 3a of OM-6 was implemented for containment spray pump P-61S, and the frequency of testing was not doubled, the cause of the deviation was not determined, and the condition was not corrected.
o Maine Yankee Response:
Maine Yankee agrees with the first example of this violation. Maine Yankee did in fact implement an approved reliefrequest, but failed to implement the additional requirements invoked by the NRC.
Maine Yankee does not concur with the second example for the reasons listed below:
NRC_ inspection Report 50-309/97-05 and Notice of Violation states that the licensee, Maine Yankee, implemented a new vibration alert limit for P-61S that exceeded the Code limit in June of 1996 without receiving prior NRC approval. The report further states that the licensee had been unaware that a relief request was required for such action. In response to this notice of violation, a review was performed of the OMa 1988 Code,1996 IST pump test results for P-61S, and the revision of Maine Yankee's IST pump test procedure in effect in June of 1996. The following facts were determined:
- 1. The OM Code requires that for vertical line shaft pumps, vibration measurements shall be taken on the upper motor bearing housing in three orthogonal directions, one of which l
is in the axial direction.
- 2. The alert limit in effect for the Code required vibration points in June 1996 was 0.325 ips which was in accordance with the OM code.
- 3. The current alert limit of 0.325 ips has been the same and in effect since June 1996.
4.- At no time in 1996 did the vibration readings for the Code required points described in I., above, exceed 0.325 ips.
- 5. In April of 1996, the vibration readings for a non-code point, PUH, exceeded the self imposed alert limit specified of the test procedure. As a result, the test frequency was subsequently increased to monthly testing as required by Maine Yankee procedures.
This was a conservative measure taken beyond any Technical Specification, Code or regulatory requirement and considered a good engineering / maintenance practice.
- 6. Step 5.8.3 of procedure 3.17.6.6, Rev. 22, which was the test procedure in effect in June 1
1996, states " Differential pressure and vibrations shall be plotted on graphs for trend analysis. These graphs shall show alert and required action limits as specified by the IST Program or appropriate relief request." This step clearly indicates the licensee's awareness of the necessity of relief requests prior to implementing new limits not specified by the Code.
In conclusion, Maine Yankee di 1 not implement a new Code required alert limit for P-61S in June 1996. The correct code required alert limit of 0.325 ips was in place in June 1996 and remains in effect today. Maine Yankee is today, as in June 1996, aware that a relief request is required for
= implementing an alternate limit outside of Code requirements.
immediate Corrective Actists Example (1): Maine Yankee reviewed valve stroke times to ensure compliance with Code requirements.
Example (2): Maine Yankee does not concur with the example, therefore, no corrective actions were taken.
7 Corrective Actions Taken to Avoid Further Violation:
Example (1):
A revision to the relief request was fonvarded to the NRC in June of 1997.
Example (2): Maine Yankee does not concur with the example, therefore, no corrective actions were taken.
Full Compilance Date:
Example (1): Maine Yankee would have been in compliance upon the NRC's approval of the revised relief request and appropriate procedure revisions completed. As the plant has been pemianently shut down, Maine Yankee is evaluating inservice testing requirements to be implemented during the decommissioning period.
Violation "D":
10 CFR 50.55a(f) requires in part that insenice testing of certain ASME Code Class 1,2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda.10 CFR 50.55a(f)(4)(iv) permits portiois of subsequent editions or addenda, incorporated by reference in 10 CFR 50.55a(b), to be used provided that all related requirements of the respective editions or addenda are met.
Part 6 (OM-6) of the ASME/ ANSI OMa 1988 Addenda to ASME/ ANSI OM-1987, paragraph 4.4, requires that when a reference value may have been affected by repair, replacement, or routine servicing of a pump, a new reference value shall be determined or the previous value reconfirmed by an inservice test run prior to declaring the pump operable. Verification that the new values represent acceptable pump operation shall be placed in the record of tests, Contrary to the above, on April 9,1992, following repair of service water pump P-29D, new vibration reference values were not determined and previous values were not reconfirmed by an inservice test run prior to declaring the pump operable, and the verification that the new values represent acceptable pump operation was not placed in the record of tests.
Maine Yankee Resnonse:
Maine Yankee does not concur with this violation based on the following facts:
- 1. The issue in question took place during the second inservice testing interval for Maine Yankee. The ASME Code m use at this time was the 1980 Edition of ASME Section XI up to and including the Winter of 1980 addenda.
- 2. The 1980 Code states that when a reference value or set of values may have been affected by repair or routine servicing of the pump, a new reference value or set of values shall be determined or the previous value reconfirmed by an inservice test run prior to, or within 96 hr after, return of the pump to normal service. Deviations between the previous and new set of reference values shall be identified, and verification that the new values represent acceptable pump operation shall be placed in the record of tests.
- 3. P-29D was disassembled and reassembled as part of routine maintenance per Work Order 91-6500-00 during the last quarter of 1991. This work order specified an inservice pump test to be performed in accordance with procedure 3.17.6.6 and the results evaluated within 96 hrs after return of the pump to service.
- 4. On 1/2/92, the functional test specified in work order 91-6500-00 was performed and the results evaluated. The results of this test were declared satisfactory with a note that this was the first test after a pump and motor rebuild and that the results of this test would be used to determine new reference values. This test data is on file at Maine Yankee, u
r
- 5. Although not required, subsequent pump tests were performed on 1/6/92 and 1/17/92 to -
reconfirm the results of the first test performed on 1/2/92. These subsequent tests were also declared satisfactory. This additional pump test data sheets for 1/6/92 and 1/17/92 -
are on file at Maine Yankee.
- 6. In compliance with Procedure 0-06-2, prior to changing the acceptance criteria of a surveillance test procedure, a Technical Evaluation must be performed per Procedure 17-226. On 4/8/92, Technical Evaluation 2%-92 was approved for changing the reference values for discharge pressure and delta pressure for P-29D. These were the only two-values that changed significantly and ifignored would have resulted in non-conservative Alert and Required Action limits Vibration values from the first test performed on 1/2/92 were only slightly higher than the existing reference values and did not warrant changing, in fact, if changed would have resulted in less conservative alert and required action limits.
7.- Procedure change TPC 92-325_was initiated to incorporate the n'ew values approved under Technical Evaluation 206-92.
In conclusion, post maintenance IST pump testing was performed on P-29D, as required, in early 1992 and as a result, those reference, alert, and required action values which warranted change, were L
revised. Those reference values which were reconfimled remained the same. The test records i;
associated with this issue are available in the Engineering Programs Department. Based on the above, Maine Yankee does not agree with this violation.
Violation "E":
10 CFR 50, Appendix B, Criterion XI, Test Control, requires that a test pmgram shall be established to assure that all testing required to demonstrate that components will perform satisfactorily in service is performed in accordance with written test procedures which incorporate acceptance limits i
contained in applicable design documents. Part 6 (OM-6) of the ASME/ ANSI OMa-1988 Addenda to ASMI/ ANSI OM-1987, Table 3a, requires pump vibration alert and required action acceptance criteria to be established at the more conservative range of greater than (>) 2.5Vr to 6Vr (where Vr is the vibration reference value) or >0.325 inches per second (ips), and >6Vr or >0.70 ips, respectively.
Contrary to the above, since December 28,1992, testing required to demonstrate that components will perform satisfactorily in service was not performed in accordance with written test procedures which incorporate acceptance limits contained in applicable design documents in that the more conservative range ofpump vibration alert and required action acceptance criteria prescribed in OM-6, Table 3a were not established.
Maine Yankee Response:
Maine Yankee concurs with this violation.
Immediate Correetive Aetions:
Immediately following the discovery of this issue, a cognizant engineer compared all recent IST pump vibration data against the correct Code required acceptance criteria and found no alert or moperable conditions. This review was not formally documented.
Corrective Actions Taken to Avoid Further Violation:
1.
Learning Bank issue 97-1433 was entered in the Corrective Action Program on March 12, 1997. Tasks initiated to resolve the issue are as follows:
- 1) root cause evaluation
- 2) review and revise the current IST values as applicable for vibration acceptance parameters and criteria for all IST pumps to ensure compliance with the Code
- 3) revise surveillance procedure to incorporate the new vibration reference, alert, and inoperable values based on technical evaluation 155-97
- 4) update the Mastertrend vibration database set-up to incorporate the new alert and inoperable limits based on technical evaluation 155-97
- 5) additional Code training and industry involvement shall be provided to all implementers of the IST Program 2.
Evaluation Report 97-01433-01 was completed on 5/11/97 and approved on 7/2/97. This evaluation concluded that an improper code interpretation was made coincident with a lack ofindustry involvement by the Maine Yankee IST Coordinator.
3.
Technical Evaluation 155-97 was completed on 5/19/97 and approved on 5/23/97 which documents the review and changes to IST pump vibration reference, alert, and required action values as required by the Code.
4.
Surveillance Procedure 3.17.6.6 is being revised. Changes to the procedure are being made other than those required to address this issue. The procedure revision is being worked as a high priority and is scheduled for completion in early August.
Full Compliance Datu Full compliance will be achieved upon PORC approval of Surveillance Procedure 3.17.6.6. As the plant has been permanently shut down, Maine Yankee is evaluating testing requirements to be implemented during the decommissioning period.