IR 05000213/1979010
| ML19208D598 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 06/28/1979 |
| From: | Conte R, Kister H, Szymanski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19208D594 | List: |
| References | |
| 50-213-79-10, NUDOCS 7909280689 | |
| Download: ML19208D598 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-213/79-10 Docket No.
50-213 License No. DPR-61 Priority Category C
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Licensee:
Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name:
Haddam Neck Plant Inspection at:
Haddam Neck, Connecticut Inspection conducted: flarch 27-30, 1979 Inspectors:
N f
f.J. Conte,leactorInspector datre signed
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e T. Szymanski, Training Specialist date signed date signed Approved by:
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[.17 W H. B. Kister, Chief, Nuclear Support Section date s4gned No. 2, RO&NS Branch Inspection Summary:
Inspection on March 27-30,1979 (Report No. 50-213/79-10)
Areas Inspected:
Routine unannounced inspection by regional ba::ed inspectors of licensee action on previous inspection findings; administrative controls for surveillance testing; surveillance test content and data; inservice testing of safety related pumps, inservice testing of safety related valves; and technician qualifications.
The inspection involved 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> onsite by two regional based NRC inspectors.
Results:
Of the six areas inspected no items of noncompliance were identified in four areas, three apparent items of noncompliance were identified in two areas (Infraction-failure to perform an inservice test run on two safety relatec' puaps following maintenance - Paragraph 5.c; Infraction - failure to periodically test fire protection system pumps in accordance with designated surveillance procedure -
Paragraph 4.c(1); Deficiency - failure to document surveillance test deficiency for a fire pump - Paragraph d.c(2).
Region I Form 12
)Q}4
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(Rev. April 77)
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eg909280M9
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DETAILS l.
Persons Contacted
- R. Blewett, Quality Assurance Supervisor
- J. Delawrence, Inservice Inspection Coordinator
- R. Gracie, Operations Assistant
- R. Graves, Station Superintendent J. Levine, Maintenance Sunervisor Other members of the operations, quality assurance and administrative staffs were also interviewed.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (213/77-25-01):
Failure to follow procedures in the completions of Maintenance Requests and Job Orders.
Program changes, which resulted from this noncompliance, we a roviewed.
However, the inspector pointed out that the implementation aspects of thesc changes will be verified on a subsequent inspection.
To reduce the impact on department heads and still accomplish the necessary review process of completed job packages, QA 1.2 - 5.1, Maintenance Requests and Work Permits, was revised (Revision 6, dated January 15, 1979).
This change includes a revised form (Job ',rder is now dasignate *?ork Permit).
Further Quality Assurance (QA) now reviews the work packagO documentation for completeness.
The QA group was expanded to provide additional capabilty for performance of review and audit functions.
A QC Technician was added from a Vendor Service Organization.
F.urther training was conducted during the past year for plant personnel on the various changes in the administrative procedures for the conduct of safety related maintenance.
During this review several inconsistencies were noted.
QA 1.2 - 8.2, Material Issue, Revision 2, October 6, 1978 still refers
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to the old Job Order system. The licensee stated that the procedure will be revised as a part of the periodic review updating of facility procedures.
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QA 1.2 - 5.1, Maintenance Requests and Work Permits, Revision 6,
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January 15, 1979 implies that the Material Issue forms for parts used during the conduct of maintenance will be attached to the Work Package as other pertinent documentation.
The licensee intends only to document these form numbers for traceability.
The licensee repre-sentative indicated that this procedure will be revised to clarify this area.
QA 1.2 - 9.1, Control of Srectal Processes, Revision 0, July 24,1974,
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still references the "QA Surveillance File" which is non-existent.
All formal records are being stored in QA Program prescribed vault.
The licensee representatives indicated that this procedure was ten-tatively revised to clarify this, but it was held up for revision for incorporation of Northeast Utilities Welding Manual requirements.
The revision to this procedure is iminent.
The inspector acknowledged the licensee's intentions to clarify the above inconsistencies and had no further coments in this area.
3.
Administrative Controls for Surveillance Testing Administrative controls were reviewed to determine the licensee's program for implementing requirements associated with the control of surveillance testing, as specified in Technical Specifications, Section 6, Regulatory Guide 1.33 - 1972, Quality Assurance Requirements; and, ANSI N18.7 - 1972, Administrative Control.for Nuclear Power Plants.
The following documents were reviewed Quality Assurance Procedure (QA) - 1.2 - 5.2, Procedure Format,
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Revision 2, May 12, 1977 QA - 1.2 - 6.5, Procedure Review and Approval, Revision 3, July 27,1976
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QA - 1.2 - 11.1, Operatinal Surveillance Tests, Revision 2, May 7, 1978 QA - 1.2 - 11.2, Review of Test Data, Revision 1, June 11,1978
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Administrative Procedure 1.1 - 5.1, Inservice Inspection Program, Revision 0, April 6, 1978 No items of noncompliance were identified.
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4.
Surveillance Test Content and Data a.
Surveillance procedures and associated data were reviewed on a sampling basis to verify the following.
Properly approved procedures are issued for tests required by
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Technical Specifications (TS) or by the Inservice Inspection Program (ISI) for Pumps and Valves; and the format for these procedures are in accordance with ANSI 18.7 - 1972, Administrative Controls for Nuclear Power Plants, including the specification of prerequisites, acceptance criteria, and restoration of systems to normal operatior.
Technical content is adequate to assure compliance with the re-
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quiremants specified in TS or the. ISI Program.
Completed test records indicate conformance with TS/ISI Program
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and Procedural Requirements at required frequencies.
Test results were reviewed in accordance with Administrative
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Requirements, and appropriate action was taken for noncomformance with test acceptance criteria, b.
The selected surveillance requirements, procedures test data (indicated by date of performance) are listed below.
SP 5.1 - 15, P.re Protection System Tests, Revision 4, October 6,1978
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(TS 4.15.A.l(a)), Data: November, December,1978; January 3,1979 and March 1, 1979.
SP 5.5 - 15, Semi-Annual Inspection of C02 Systems fcr Cable Vault,
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HEPA Filters and Halon System for Cable Vault, Revision 0, October 27,1978 (TS 4.15.B.l(a)); Data: July 1, 1976; February 2, 1977; August 9,1977; February 27, 1978 and September 20, 1978.
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SP 5.5 - 9, Semi-Annual Testing of Flood Control Alarm Systems, Revision 1, May 18, 1978 (TS 4.14); Data: July 5,1977; August 24, 1978 and December 26, 1978.
SP 5.5 - 3, Testing of Rod Step Counters, Revision 2, November 23,
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1977 (TS Table 4.2-1); Date: May 24, 1976; October 15,1977 and January 27, 1979.
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SP 5.1 - 13, Auxiliary Feed Pump Monthly Functional Test, Revision
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4, May 19,1977 and SP 5.1-14, Auxiliary Feed Pump Flow Capacity Test, Revision 0, February 1,1975 (TS 4.8); Data:
October 31, 1978; December 4,1978; January 2,1979, February,1979, March 2, 1979.
c.
During this review the following apparent items of noncompliance were 1dbntified.
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(1) Technical Specification (TS) 3.22 requires in part that the two high pressure fire pumps be operable in all modes and TS 4.15 re-quims the demonstration of operability every 30 days on a staggered tet_ oasis.
From January 3, 1979 to March 1, 1979, SP 5.1-15, which demonstrates the operability of the fire pumps, was not conducted and therefore the frequency interval of TS 4.15 (including 25% grace period) was exceeded.
Further, the Diesel Driven Fire Pump was inocerable for 12 days starting February 15, 1979.
However, SP 5.1-15 was not conducted as post maintenance testing for the pump.
A Licensee Event Report was submitted concerning the inoperability of the Diesel Driven Fire Pump.
Other evidence indicated these pumps were run on a weekly basis per an automatic sequencer.
Further, based on review of the work permit associated with the maintenance on the diesel fire pump in February 1979 the pump was given an operability check.
However, it appeared no performance evaluation was conducted in accordance with SP 5.1-15 which implements TS 4.15.
This represents apparent noncompliance (infraction level) with TS 3.22 and 4.15 (213/79-10-01).
(2)
During the review of completed data acquired January 3 and March 1,1979 for SP.S.1-15, Fire Protection System Testing, it was observed that the lube oil pressure for the Diesel Fire Pump was recorded high and outside the range of 45-55 psie s required by the surveillance procedure.
However, QA - 1.2 - 11.2, Revici of Test Data, Revision 1, June 11,1978, was not implemented in that a Plant Information Report (PIR) was not initiated on the above deficiency to identify the deficiency to plant management and document corrective action taken.
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This failure to follow QA - 1.2 - 11.2 represents apparent noncompliance (deficiency level) with TS 6.8.1; ANSI 18.7 - 1972,
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paragraph 5.1.7 and paragraph 6.1 of QA -l.2 -11.2.
(213/79-10-02)
d.
The following unresolved items were disclosed.
(1) QA - 1.2 - 11.1, Operational Surveillance Test, and QA - 1.2 - 11.2 Review of Test Data, imply that a detailed review of each completed surveillance test is to be conducted by the QA Department. Based on the findings of paragraph 4.c above and a review of other data, it appeared that a detailed review by QA was not always accomplished.
The licensee representativa stated that the intent of QA 1.2 - 11.1 and QA 1.2 - 11.2 is that QA review t he surveillance test data for completeness and that the more detailed reviews are accomplished during the periodic audits in this area.
The licensee representative stated that this area would be reviewed to clarify the established administrative controls for the review of test data while maintaining a second independent level of review of test data.
This is unresolved pending completion of action by the licensee as stated above and subsequent NRC: RI review (213/79-10-03).
(2) A review of data acquired for SP 5.1-15, Fire Protection System Tests, indicated that actual run times for the fire system pumps were not always recorded.
The procedure itself was unclear on the recording of such data; however, it did not require the pumps to be run for at least 15 minutes as required by TS 4.15.
The licensee representative stated that SP 5.1-15 would be revised to indicate actual run times for the pumps.
This is unresolved pending completion of action as stated by the licensee and subsequent NRC: RI review (213/79-10-04).
e.
Since this inspection was the initial review of the licensee's ISI Program for Pumps and valves, a more detailed progr7e.1 tic review was conducted alcag with a sampling review of associated data.
Details are discussed in subsequent paragraphs.
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5.
Inservice Ter ing of Safe' i< elated Pumps a.
The lice's: 1's progrt ror testing safecy related pumps in accordance with 10.CFR 5.55a paragraph (g) (which references appropriate edition /
addenda of the ASME Boiler aad Pressure Vessel Code for Pumps and Valves) was reviewed. This review was conducted to ensure that associated administrative ard surveillance procedures nave been esta-blished and that they address the requirements of the ASME Code,Section XI, Subsection IWP, Inservice iasting of Pumps in Nuclear Power Plants (edition / addenda as specified in the licensee's program subm; ?ted),
in addition to those procedural requirements listed in paragraph 4a above.
Further, implementation aspects of the program were obsa.rved by sampling completed procedures and associated data acquired.
b.
The following documents and data (indicatM by date of performance)
were selected for review.
ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWP,
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Inservice Testing of Pumps in Nuclear Power Plants,1974 Edition through Summer 1975 Addenda
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Letter from D. C. Switzer, CY, to A. Schwencer, NRR, dated June 29, 1977 Letter from A. Schwencer, NRR, to D. C. Switzer, CY dated
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December 14, 1977
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Letter from D. L. Ziemann, NRR, to D. C. Switzer, CY, dated March 23, 1978 Letter from D. C. Switzer, CY, to D. L. Ziemann, NRR, datei
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May 26, 1978 Letter from W. G. Counsil, CY, to D. L. Ziemann, NRR, dated
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July 14, 1978 SUR-5.3-26, Inservice Inspection Funp Analysis, (Draft)
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SUR-5.1-4, Core Cooling Systems Hot Operational Test, Revision 4
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August 25, 1978 1034
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SUR - 5.1 - 103, Inservice Inspection Pump Surveillance, Revision 2,
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August 4,1978 Data: Monthly Acquisitions from January 2,1978 to December 15, 1978 for Chargini Pumps (P-18A and B), Low Pressure Safety Injection (LPSI) Pumps iP-92-1A and B) and Auxiliar, Feed Pumps (P-32-1A and B)
c.
The 411owing apparent noncompliance was identified.Section XI of the accep.ad edition of TSME Code, paragraph IWP-3111 requires in part that when reference values for pump test acceptance criteria may be affected by repair, the previous values must be reconfirmed or new values determined by an inservice test run prior to or within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after return of the pump to normal service.
In two instances this was not accomplished.
For 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> starting July 24, 1978, the B High Pressure Safety Injectior. Pump was inoperable for the replacement of a booster pump shaft sleeve and wear ring.
Further, between September 6 and October 10, 1978 the B Service Water Pump was overhauled.
In both cases, SUR-5.1 - 103 (which implements the ISI Program for Pumps)
was not performed until its next regularly scheduled monthly test.
This resulted in the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> limit being exceeded for an inservice test run from the time the pump was returned to service.
This represents noncompliance with 10 CFR 50.55a (g) and ASME Boiler and Pressure Vessel Code 1974 edition through Suraner 1975 Addenda,Section XI Subsection IWP-3111 (213/79-10-05).
d.
The following unresolved items were identified.
The licensee repre-sentative agreed to further review these areas where resolution, if needed, will be addressed by subsequent submittals to NRR of the revised ISI Program.
These items are unresolved pending completion of action as stated below and subsequent NRC: RI review.
(1) The program submittals of May,1978 and July,1978 (referenced in paragraph 5.b above as letters) in certain instances conflict with each other. The May, 1978 letter to NRR clarified the method by which suction pressure (Pi) for the charging pumps would be calculated, and it stated monthly surveillance of the charging pumps would be accomplished.
The later submittal of July,1978 does not reflect this clarification.
Further, based on a review of data for the charging pumps, the method for conducting the test on these pumps appears questionable.
Subsection IWP-3100 requires that for constant speed driven pumps, the test be conducted at the reference flow rate or referenced differential pressure.
The licensee representative stated that it 1034 J
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has not been established yet if a constant flow rate could be maintained during the test of these pumps and that differential pressure varies depending on Volume Control Tank Pressure (on the suction header of the pumps). A review of data confimed the inconsistency of differential pressures on each test.
The licensee representative stated that by June 30, 1979, this area will be reviewed further to determine if a more controlled test of the charging pumps is achievable without adversely affecting plant operations, and if an exemption to the code may be warranted. This is unresolved (213/79-10-06).
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(2) The program submittal of Ju'y,1978 h s an exemption from a monthly test of each Service Water Pump due to physical constraints of needing at lcest two pumps at all times during operations.
However, individual testing of each pump will be conducted during cold shutdown conditions.
The licensee is further looking into testing individual pumps at shutoff head on a monthly basis.
This is unresolved pending NRC: RI review of the licensee's disposi-tion of shutoff head testing of Service Water Pumps which the licensee representative indicated should be accomplished by June 30, 1979. (213/79-10-07)
(3)
It was determined that the licensee is in the process of verifying compliance with Subsection IWP-4000, Methods of Measurement.
Specific Code requirement areas to be reviewed among others are as follows.
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Instrument Tap Locations Instrument Ranges less than four times reference values
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Identification of Instruments used in the ISI program tc insure incorporation in an effective calibration schedule /
program.
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Vibration Measurements on Service Water Pump Supports with respect to resilient mount separation of pump support structure from the pump itself.
The licensee representative indicated that this review should be accomplished by June 30, 1979. This is unresolved pending NRC: RI review of the licensee's findings iii the above areas (213/79-10-08).
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(4)
The inspector observed errors in the transfer of data from the completed surveillance test to the Sumary List of Pump Da ta.
In no instance did these errors give false indication of acceptability with original data being unacceptable.
The inspector noted that one individual is coordinating the program and compiling data.
The licensee representative indicated plans for allocating more manpower to this program with QA responsible for audit functions in this area.
The inspector stated that this is unresolved pending NRC: RI review of this area within 6 months for improvement in the re-cording of data on the pump summary lists (213/79-10-09).
(5)
It was noted that several records remain to be formalized as required by Subsection IWP-6000.
Many of these records will be incorporated into SUR 5.3-26, Inservice Inspection Pump Analysis (Draft), which has yet to be issued.
These records include the following.
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Summary Listing of all Pumps Covered by the Program versus
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current test status Pump Records with Nameplate Information
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Inservice Test Plans including Reference Values for Pump Testing Records of Tests including comparison with allowable ranges
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of test values and analysis of deviations and requirements for corrective action.
The licensee representative indicated that these records should be formalized by September 30, 1979.
This is e solved pending issuance of the above records (213/79-10-10).
6.
Inservice Testing of Safety Related Valves a.
The licensee's program for testing safety related valves in accorconee with 10 CFR 50.55a paragraph (g) (which references appropriate edition /
addenda cf the ASME Boiler and Pressure Vessel Code for Pumps and Valves) was reviewed.
This review was to ensure that associated admin-istrative and surveillance procedures Fave been established and address the requirments of the ASME Code,Section XI Subsection IWV Inservice Testing of Valves in Nuclear Power Plants (edition / addenda as specified in the licensee's program submittals), in addition to those procedural requirements listed in paragraph 4a above.
Further implementation aspects of the program were observed by sampling completed procedures and associated data acquired.
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b.
The following documents and data (indicated by data of performance)
were selected for review.
ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWV,
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Inservice Testing of Valves in Nuclear Power Plants,1974 Edition through Sumner 1975 Addenda Letters referenced in paragraph 5.b
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Engineering Procedure 5.3 - XX, Valve Summarization (Draft)
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SUR 5.1 - 4, Core Cooling System Hot Operational Test, Revision
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4, August 25,1978 Data: March 3 and January 4,1979; December 12, November 2, and October 3, 1978 SUR 5.1 - 95, Inservice Inspection of Feedwater M0V's, Revision
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0, April 14,1978; Data: February 23, 1978 SUR 5.1 - 5, Inspection of Check i'alves (RH-CV-783) Revision 0,
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February 27,1970; Data: February 27, 1979 SUR 5.1 - 7, Reactor Containment - Functional Test of Containment
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Spray Valves, Revision 1, April 6,1978; Data: February 1, 1979 SUR 5.1 - 116, Inservice Inspection of Auxiliary Steam Generator
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Feed Pump Control Valve (Fail Safe) (MS-PICV 1206 A and B),
. Revision 0, April 14,1978; Data: January 19, 1979 c.
No items of noncompliance were identified, however, the following unresolved items were disclosed.
These items are unresolved pending completion of action as stated below and subsequent NRC: RI review.
(1) The below listed observations are unresolved pending disposition of the Final Valve List which will indicate scope of valve coverage for the program.
Discussions on this list are being conducted between the licensee and NRR (213/79-10-11)
Valves under the dual scope of coverage by 10 CFR 50 Appendix
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J and by the ISI Program necd exemption from individual leak rate testing required by Subsection IWV-3420 (f) and (g).
Seve al pressure isolation valves, not under the scope of
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10 CFR 50 Appendix J, which require leak rate testing per ISI remain to be identified.
Pending the identification '
of these valves NRC: RI will review associated procedures developed for leak rate testing these valves.
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Category E Valves (valves which are normall or sealed open or closed to fulfill function) y locked
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remain to be identified on the implementation schedule. They are however, in the program submittal.
Other valves in this category are being considered and associated procedures will have to be developed.
Relief valves remain to be identified in the Implementation
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Schedule.
They are, however, in the program submittal.
Additional valves are being considered.
Fur ther, procedures remain to be issued incorporating the requirements of PTC 25.2 - 1966, the test procedure referenced in subsection
IWV-3510. The licensee indicated intentions of using a later version of this test procedure.
The inspector stated an exemption from the code would be warranted if a later version of the PTC were used.
The licensee representative acknowledged the inspector's coments in this area.
(2)
Subsection 3410 paragraph (e), on exercising fail safe valves, indicates that the test is to 50 conducted upon loss of actuator power. A review of SUR 5.1 - 116 for Auxiliary Feedwater Control Valves indicates that the loss of power is simulated by rapidly taking the control switches to the fail safe position (in this case open).
Discussions with licensee representatives indicated that they felt the test was adequate to fulfill the intent of this section of the code.
This is unresolved pending a more detailed technical review by NRC: RI of this area (213/79-10-12).
(3)
It was noted that several records remain to be formalized as required by Subsection IWV-6000.
Many of these records will be incorporated into Procedure 5.3 - XX, Valve Sumarization (Draft)
which has yet to be issued.
These records include the following.
Summary of Covered Valves versus Current Status of Test
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and Inspection Program Manufacture's preoperational test and examination results -
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An exemption from the code may be warranted if this informa-tion cannot be located Specification of acceptance criteria based on previous test
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results, eg. maximum valve stroke time and previous test results for trending.
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The licensee representative indicated that these records should be formalized by September 30, 1979.
This is unresolved pending issuance of the above records (213/79-10-13).
7.
Technician Qualifications The inspector verified that salected technicians, with responsibility for surveillance testing of safety related system and components, have sufficient experience level and training in accordance with the guidelines of AN3I 18.1 - 1971, Selection and Training of Nuclear Power Plant Fersonnel, Section 4.
No items of noncompliance were identified.
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8.
Unresolved Items Unresolved Items are findings about which more information is needed to ascertain whether it is an item of noncompliance, a deviation, or acceptable.
Unresolved items reviewed / disclosed during this inspection are discussed in paragraphs 2, 4.d, 5.d, and 6.c.
9.
Exit Interview The inspector met with the licensee representatives (denoted.n Pargraph 1)
at the conclusion of the inspection on March 30, 1979.
The purpose, scope and findings of tne inspection weie summarized.
Subsequent discussions of inspection findings occurred in telephone conversations between Mr. R.
Conte, NRC: RI, and Mr. R. Graves, CY, on April 3,1979; and betweer; Mr. Conte and le. J. Delawrence, CY~on April 25', 1979.,
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