ML20211M136

Responds to NRC Re Violations Noted in Insp 50-029/86-08 on 860610-1006.Corrective Actions:Surveillance Procedure OP-4212, Main Coolant Sys RHR Availability Verification, Amended to Require Bypass Valve Closure

ML20211M136
Person / Time
Site:	Yankee Rowe
Issue date:	11/26/1986
From:	Heider L YANKEE ATOMIC ELECTRIC CO.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
FYR-86-113, NUDOCS 8612160274
Download: ML20211M136 (3)

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YANKEE ATOMIC ELECTRIC COMPANY TWX 710-380-7619

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November 26, 1986 FYR 86-113 United States Nuclear Regulatory Commission Region I I

631 Park Avenue King of Prussia, PA 19406 Attention: Dr. Thomas E. Murley Regional Administrator

References:

(a) License No. DPR-3 (Docket No. 50-29) m (b) I&E Letter to YAEC, I&E Inspection No. 50-029/86-08, dated October 24, 1986

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Subject:

Response to Inspection 50-029/86-08

Dear Sir:

Reference is made to I&E Inspection No. 50-029/86-08 conducted by your Mr. H. Eichenholz during the period June 10 through October 6, 1986, at the Yankee Atomic Electric Company, Yankee Nuclear Power Station in Rowe, Massachusetts. The report made subsequent to that inspection identified an item which .yparsntly was not conducted in full compliance with NRC requirements. In accordance with Section 2.201 of the NRC's " Rules and Practices," Part 2. Title 10, Code of Federal Regulations we hereby submit the l following information:

Apparent Violation i

Technical Specification Limiting Condition for Operation 3.4.1.1.2.b requires that in Mode 3 at least one Main Coolant Loop (McL) shall be in operation. Technical Specification Surveillance Requirement 4.4.1.1.2.3.b requires that a determination be made a least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the steam generators associated with the MCLs required to be in operation are capable of decay heat removal by verifying that the MCL cold and hot leg stop valves are fully open, with the bypass valve closed. Technical Specification 6.8.1 requires that written procedures shall be established that meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 calls for implemented procedures for 0612160274Ohh29 ADOCK O PDR PDR _

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l United States Nuclear Regulatory Commission- November 26, 1986 Attention: Dr. Thomas E. Murley Page-2 I FYR 86-113 Technical Specification Surveillance Requirements. Contrary to the above while in Mode 3 from June 1 through 3, 1986, the, Technical Specification surveillance requirement 4.4.1.1.2.3.b was not performed and no written procedure was established that prescribes the required surveillance requirement. Furthermore, on June 2, 1986, for approximately a four-hour period, all MCL bypass valves were open, resulting in no MCLs being in operation.

This is a Severity Level IV Violation (Supplement I).

Response

We concur with the Notice of Violation as described above.

1. Reason for the Violation r

The Technical Specification requirements for both main coolant flow in Modes 1 and 2, and main coolant loop operability in Modes 3 and 4, was intended to be documented by " Note 5" of No. 2 Control Room Log (implemented by OP-2007). " Note 5" of No. 2 Control Room Log was ambiguous for the Mode 3 requirement.

On June 2, 1986, while the plant was in Mode 3, the main coolant bypass valves were opened in an attempt to maintain main coolant temperature. Main coolant temperature was decreasing slowly due to steam demands required to maintain condenser vacuum. Control Room personnel did not recognize that opening the fourth bypass valve violated Technical Specification 4.4.1.1.2.3, since all four main coolant pumps were operating at the time.

2. Corrective Steps Which Have Been Taken and Results Achieved P

On June 18, 1986, Surveillance Procedure OP-4212, " Main Coolant System Residual Heat Removal Availability Verification," was amended to include the check that the bypass valve for the McL, required to be operable, is closed.

3. Corrective Steps Which Will be Taken to Avoid Further Violations 1,

I All operating personnel have been informed of the need for diligence in complying with Technical Specification requirements.

4. The Date When Full Compliance Will be Achieved Full coupliance was achieved on June 18, 1986, with the iusuance of OP-4212, ACM No. 1.

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United States Nuclear Regulatory Commission November 26, 1986 Attention: Dr. Thomas E. Murley Page 3 FYR 86-113

5. General Observation Relevant to the Inspection Report Inspection Report 50-29/86-08, although covering an approximate four-month period, was considered excessive in length, detail, and subj ectivity. This issue can be discussed further during the next Systematic Assessment of Licensee Performance (SALP) meeting.

The date for submittal of this response was modified during a discussion with Mr. Thomas Elsasser (USNRC) to November 26, 1986. Please contact us if you have any questions.

Very truly yours, uis H. Heider Vice President Manager of Operations GP/bil