A08061, Responds to NRC Re Violations Noted in Insp Rept 50-213/89-05.Corrective Actions:Valve PW-V-600 Placed in Locked Close Position & Labeled as Containment Isolation Valve & Procedures Re Containment Integrity to Be Reviewed

Responds to NRC Re Violations Noted in Insp Rept 50-213/89-05.Corrective Actions:Valve PW-V-600 Placed in Locked Close Position & Labeled as Containment Isolation Valve & Procedures Re Containment Integrity to Be Reviewed

ML20245A033
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/12/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A08061, A8061, NUDOCS 8906210045
Download: ML20245A033 (4)

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NORTHEAST UTILITIES cenere Omces . seicen street, seriin, connecticut i v c:,,c u w o .~o noma cw.-

1 *wn umac,w mece-a-P.O. BOX 170 H ARTFORD, CONNECTICUT 06141-0270 k k J SE , $$ c5~", (203) 665-5000 June 12, 1989 Docket No. 50-213 A08061 Hr. Jacque P. Durr, Acting Chief Projects Branch No. 1 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406

Reference:

(1) J. P. Durr letter to E. J. Hroczka, dated May 17, 1989, ,

Resident Inspection No. 50-213/89-05.

Gentlemen:

Haddam Neck Plant Response to Resident Inspection 50-213/89-05 Pursuant to the provisions of Section 2.201 (" Notice of Violation") and Appendix C (Enforcement Policy) of the NRC's Rules of Practice (10 CFR2),

this report is submitted in reply to Reference (1), which informed Connecticut Yankee Atomic Power Company (CYAPCO) of a violation which was identified during a routine inspection at the Haddam Neck Plant froir March 29 through May 2, 1989.

1. Description of Violation Connecticut Yankee Atomic Power Company, Haddam Neck Plant Technical Specification 3.11, Containment, requires that containment integrity be maintained whenever the RCS (Reactor Coolant System) is above 300 psig and 200 degrees P.

SUR 5.1-126, Locked Valve checklist, Revision 16, identifies PV-V-600 (a one-half inch, primary water, sample sink flushing isolation valve) as a containment isolation valve and requires the valve to be locked closed when containment integrity is required.

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USNRC-A08061/Page.2 June 12, 1989 Contrary to the above,.on March 27, 1989, with the RCS greater than 300 psig and 200 degrees F, PV-V-600 was open.

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

2. Admission or Denial of Violation i

CYAPC0 does not contest the violation as set forth in the Notice of-Violation.

3. Reason for Violation On March 27, during a valkdown inspection of Containment Penetration P-68 l in support of validation of a local leak rate surveillance procedure i being revised as part of the ongoing Procedure Upgrade Program, PV-V-600 l vas identified as mislabeled and not locked closed as required by SUR 5.1-126, " Locked Valve Checklist".

4. Corrective Action Taken and Results Achieved PV-V-600 was immediately placed in the locked closed position and correctly labeled as a containment isolation valve. Procedures associ-ated with this penetration were revised, as necessary, to correctly specify the function and position required of this valve. Based on Haddam Neck's Penetration Drawing Upgrade Program, individual _ penetration ,

drawings that illustrate all valves and components which comprise the  ;

containment boundary were used to walk down all accessible containment  !

isolation valves to verify correct valve positions. All valves reviewed were found to be in the correct position. Twelve valves associated with ,

ten penetrations were inaccessible. Eight of the twelve valves are check '

valves and obviously do not present a concern. The remaining four valves are boundary valves on the main steam piping inside containment. They.  ;

vill be inspected at the next cold shutdown.

A root cause evaluation concluded that the root cause was human error.

The following circumstances contributed to the human error which inadver-tently placed control on the wrong valve (PV-V-601):

o Inconsistent P&ID revisions interchanged valve identification numbers, o Since valves were labeled in accordance with the PEIDs, the valve identification labels for.PV-V-600 and 601 vere interchanged, o Procedural deficiencies in which valve identification numbers and/or functional descriptions varied between disciplines, o Plant design in which a portion of a containpint boundary is used as the normal lineup for supply of primary demineralized water to the chemistry sample sink, and o Technical Specifications (TSs) which do not control PV-V-600 and many other containment penetration isolation and boundary valves.

4 USNRC A08061/Page 3 June 12, 1989 The root cause of similar events of loss of containment integrity identified in Reference (1) were different from this event. Previous events involved inadequate procedural controls on the manipulation of designated, locked closed, containment isolation valves during surveillance testing and normal operational evolutions when containment ~-

integrity was required. This event involved an isolated drawing control and functional terminology discrepancy leading to misidentification of =-

the boundary valve. This was not a factor in previous events. The error appears to have been an isolated case (PV-V-600) as indicated by the =

valkdown results in which no other valves were found mispositioned.

CYAPC0 has evaluated this event and determined it to be an isolated case.

We have undertaken prompt corrective action to ensure this problem vill _

not recur.

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5. Corrective Actions to Avoid Future Violations Elements of our corrective actions to prevent recurrence of this event follow:

Program Status --

1. Revise Technical Specification 1.8 A proposed Tech Spec change was and 3.11 " Containment Integrity" submitted on June 2, 1939 to =

to control containment penetration control all containment isolation and isolation boundary valves valves. Expected completion:

prior to startup from the 1989 outage (approx. November 5, 1989)

2. Procedure Upgrade Review and revise all procedures ~

pertaining to containment integrity. Expected Completion:

September 1, 1989 (currently 90%

completed)

3. containment Isolation and Boundary Review the existing Program and Velve Identification Program revise as necessary.

Re ision Expected Completion: prior to start up from the 1989 outage (approx. Nov. 5, 1989)

4. Containment Penetration System Using the ISI penetration Drawing Upgrade drawing, update system pene-tration drawing. (Estimated Completion Date: May, 1990)

5. Update of the Containment Section Completed April 28, 1989 e of the Final Safety Analysis Report

6. Update PMMS Identification System Expected Completion:

in which all CIVs are noted September 1, 1989 4

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USNRC

,AOB061/Page 4

- June 12, 1989 In conclusion, CYAPCO's ongoing efforts per the above programs have provided the steps required to ensure that this type of problem does not recur.

6. Date When Full Compliance Vill Be Achieved CYAPC0 is currently in full compliance with applicable Technical Specifi-cations and plant procedures.

l If there are any questions, do not hesitate to contact my staff directly.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY u:v/

E. J. ' czka g' Senio Vice President cc: J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant A. B. Vang, Project Manager, Haddam Neck Plant U. S. Nuclear Regulatory Commission Attn: Document Control Desk Vashington, D.C. 20555

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