IR 05000213/1993004

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-213/93-04
ML20024H960
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 08/16/1993
From: Durr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Opeka J
CONNECTICUT YANKEE ATOMIC POWER CO.
References
NUDOCS 9308310028
Download: ML20024H960 (2)


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l AUG 161993

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Docket No. 50-213 l

Mr. John Executive Vice President - Nuclear Connecticut Yankee Atomic Power Company

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P.O. Box 270

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Hartford, Connecticut 06141-0270 t

Dear Mr. Opeka:

SUBJECT: INSPECTION NO. 50-213/93-04 r

This letter refers to your June 9,1993, correspondence, in response to our May 4,1993,

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letter.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

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Your cooperation with us is appreciated.

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Sincerely, i

I Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety G:HN9304.JSS

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C UFFICIAL RECORD COPY f

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9308310028 930816 PDR ADOCK 05000213 G

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AUG 161993

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Mr. John :

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cc:

W. D. Romberg, Vice President, Nuclear, Operations Services

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J. P. Stetz, Vice President, Haddam Neck Station G. H. Bouchard, Director, Nuclear Quality Services D. J. Ray, Unit Director R. M. Kacich, Director, Nuclear Licensing j

Gerald Garfield, Esquire j

Nicholas Reynolds, Esquire

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K. Abraham, PAO (33) SALP, AIT & Special Reports and (2) All Inspection Reports Public Document Room (PDR)

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Iscal Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident inspector State of Connecticut SLO r

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Region I Docket Room (with concurrences)

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bec (VIA E-MAIL):

J. Stolz, NRR/PD I-4 V. McCree, OEDO A. Wang, PM, NRR g

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St.ewart/ajk Eay,sti Durr b!JW I

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G:HN9304.JSS OFFICIAL RECORD COPY

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NORTHEAST UTILITIES c,ne,.i Omc... seen sir t. serun. Conn.ct,cui l

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HARTFORD. CONNECTICUT 06141-0270 k

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June 9, 1993

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Docket No. 50-213 B14485 Re:

Response to Inspection Report No. 50-213/93-04 10CFR2.201

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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Haddam Neck Plant Inspection Report No. 50-213/93-04 Response to Notice of Violation In a letter dated May 4, 1993,"' the NRC Staff transmitted to Connecticut Yankee Atomic Power Company (CYAPC0) Inspection Report No. 50-213/93-04.

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discussed in that report, the NRC Staff cited CYAPC0 for a violation of the Commission's regulations.

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Pursuant to 10CFR2.201, and in accordance with the instructions contained in the inspection report, CYAPC0 hereby provides the attached information in response to the Notice of Violation.

We trust that you will find this information satisfactory, and we remain available to answer any questions you may have.

Very truly yours,

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CONNECTICUT YANKEE ATOMIC POWER COMPANY hI

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J. F. Opekt

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Executive Vice President

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cc:

T. T. Martin, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant H

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U.S. Nuclear Regulatory Commission letter to J. F. Opeka, "NRC Inspection of Inservice Testing of Pumps and Valves at Connecticut Yankee Atomic Power Station (Inspection Repert No. 50-213/93-04)," dated May 4, 1993.

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Docket No. 50-213 B14485 Attachment 1 Haddam Neck Plant Response to Notice of Violation

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June 1993

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i U.S. Nuclear Regulatory Commission l

B14485/ Attachment 1/Page 1

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June 9, 1993

Haddam Neck Plant Response to Notice of Violation

Description of Violation

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"Haddam Neck Technical Specification 4.0.S.a, states, in part, that inservice testing of ASME Code Class 1, 2, and 3 equivalent pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code, except where specific written relief has been granted by the Commission.

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The ASME Code,Section XI,1983, Section IW-3413, requires, in part, I

that 'the stroke time of all power operated valves shall be measured.'

Contrary to the above, as of April 15, 1993, two power-operated ASME Code Class 2, category B valves, CH-S0V-242 and CH-S0V-242B, were neither

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stroke time tested nor had specific written relief been granted by the t

Nuclear Regulatory Commission for the requirement to stroke time test the l

valves.

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This is a Severity Level IV violation."

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Reason for the Violation:

During the 1990 refueling outage, power-operated valves CH-50V-242 and CH-50V-242B were installed to upgrade the charging system to prevent single-active failures from disabling the system during event mitigation.

The subject valves are one-inch, unidirectional, fast acting solenoid valves with no installed position indication.

The valves are normally

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energized open, but deenergized to shut on receipt of a safety injection actuation signal.

The subject valves were installed under Plant Design Change Request

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(PDCR) 967, " Connecticut Yankee - Single Failure Modifications." During

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the PDCR inservice inspection program review, ISI Engineering identified measurement of valve full stroke time as one of the test requirements per

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ASME Code,Section XI.

Nevertheless, the PDCR test plan was not updated

to reflect the ISI review.

Following implementation of PDCR 967, the Special Test procedure used to perform required testing in the PDCR test

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plan was converted to a surveillance procedure and measurement of valve full stroke time was not included.

Since CH-50V-242 and CH-SOV-242B were not equipped with either control switches or position indicating lights, full stroke time testing of the valves was not possible.

Upon discovery of the aforementioned deficiency, ISI Engineering updated the inservice test (IST) program with a note to the IST Program Manual instead of

seeking a relief request.

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U.S. Nuclear Regulatory Commission

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B14485/ Attachment 1/Page 2 June 9, 1993 i

Corrective Steps That Have Been Taken and Results Achieved:

I CYAPC0 has initiated a relief request for CH-S0V-242 and CH-SOV-242B and contacted other nuclear units and utilities to determine if alternate test methods are in existence.

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CYAPC0 has been made aware of the successful use of acoustic measurement devices for solenoid valve stroke time testing. A vendor will be used to assist in obtaining valve stroke times for CH-S0V-242 and CH-50V-2428.

Acoustic diagnostic systems currently employed to assess the condition of check valves will be used and evaluated to obtain valve-stroke times.

Corrective Steps That Will Be Taken to Avoid Further Violation:

For reasons stated above, the subject violation occurred because CYAPC0 failed to submit a relief request to the NRC Staff upon discovering that the subject valves, as designed, were incapable of valve full stroke time testing as required by the ASME Code,Section XI, 1983, Section IWV-3413.

CYAPCO will ensure that if future inservice inspection program reviews indicate that an ASME Code test requirement cannot be met (safety or i

nonsafety), a relief request will be submitted to the Staff.

Date When Full Compliance Will Be Achieved:

Testing will be completed prior to plant startup from the present refueling outage.

Presently, CYAPC0 is preparing a request to the NRC Staff for relief from performing examint.tions in accordance with ASME Code,Section XI.

The submittal will provide information on the basis for requesting relief and alternative test methods to be implemented if relief is granted.

However, if the use of acoustic measurement devices proves succassful for solenoid valve stroke time testing, the relief request will be withdrawn.

Generic Implications:

Programs are in place at the Millstone Units to preclude this event.

Therefore, CYAPC0 has concluded that this violation is an isolated case.

It is a standard procedure for CYAPC0 and Northeast Nuclear Energy Company to pursue relief requests when unable to meet specific ASME code test requirements.

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