ML19208D595

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Responds to NRC Re Violations Noted in IE Insp Rept 50-213/79-10.Corrective Actions:Procedural Revisions Re Pump Repairs,Maint Testing & Recording
ML19208D595
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 07/18/1979
From: Counsil W
CONNECTICUT YANKEE ATOMIC POWER CO.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19208D594 List:
References
CYH-79-183, NUDOCS 7909280683
Download: ML19208D595 (4)


Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANt BERLIN. CO N N ECTIC U T P.O. BOX 270 H ARTFORD. CON N ECTICUT 00101 Tsk a peso = s 203 666-6911 July 18, 1979 CYH 79-183 Dut.IET No. 50-213 U. S. Nuclear Regulatory Commission Region 1 Office of Im pection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406 Attn:

Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch

Reference:

Letter, E. J. Brunner to W. G. Counsil, dated June 29, 1979 Inspection 50-213/79-10

Dear Mr. Brunner:

This correspondence is in response to the Notice of 'liolation as described in the report of Inspection 50-213/79-10 unat was conducted during March 27-30, 1979.

Infraction 10 CFR 50.44a paragraph (g)(4) states in part:

"Throughout the service life of a... nuclear power... facility, components... classified as ASME Code 1, 2 and 3 shall meet the requirements... set forth in Section XI of.titions of the ASME Boiler and Pressure Vessel Code and Addenda..."

The accepted Inservice Inspection / Test Program commits to the 1974 Edition through Summer 1975 Addenda of the ASME Code.

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The accepted edition / addenda of the ASME Code Section XI, Subsectfon IWP-3111 states in part:

"...Whenever a reference value or set of values may have been affected by repair or routine servicing of the pump a new reference value or act of values shall be determined or the previous value reconfirmed 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..."

Contrary to the ab'ove on or about July 27, 1978, maintenance, which effected pump reference values on the B High Pressure Safety Injection (HPSI) Pump, was completed with no subsequent 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 /> of pump restoration to normal service; and on or about October 10, 1978, maintenance, which affected pump reference values on the B Service Water (SW) Pump, was completed with no sub-sequent 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 /> of pump restora-tion to normal service.

The B HPSI Pump was repaired for the replace-ment of a booster pump shaft sleeve and wear ring, and the B SW Pucp received a major overhaul.

Response

The above infraction has been discussed with the Operations and Maintenance Departments to ensure that they are cognizant of the requirements of Sub-sectira IWP-3111.

In addition, procedure SUR 5.1-103, " Inservice Inspection Pump Surveillance" has been revised to ensure that pumps which have been repaired, or received routine maintenance shall be tested within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and shall he e appropriate reference values evaluated.

No further action is considered necessary at this time.

Infraction Technical Specifica:1on (TS) 3.22 states in part:

"The Fire Suppression Water System (which includes two high pressure fire pumps) shall be operable during all modes of operation..." and TS 4.15.A.1 states in part:

"The Fire Suppression Water System shall be demonstrated operable...

At least once per 31 day + 25% on a staggered test basis by starting each pump and operating it for 15 minutes with flow..." Surveillance Procedure SUR 5.1-15, Fire Protection System Tests, Revision 4, October 6,1978, implements these TS requirements for the Electric Driven and Diesel Driven Fire Pumps.

Contrary to the above from January 3 to March 1, 1973, the Diesel Driven Fire Pump was not demonstrated operable in accordance with SUR 5.1-15.

Further maintenance waa conducted on this pump from February 15-27, 1979, and associated documentation did not reflect post mainte-nance testing cf this pump in accordance with SUR 5.1-15.

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Response

The control list which dictates weekly surveillance requirements has been revised to prevent similar ovarsights.

In addition, Operar. ions personnel have been cautioned in their use of the control list when shifting from the last week of one month to the first week of the following month.

Alsc, the maintenance procedure for this pump has been revised to specify retest requirements and references SUR 5.1-15.

These measures have already been put into effect and no further action is necessary at this time.

Deficiency Technical Specification 6.8.1 states in part:

" Written procedures and administrative policies shall be... implemented...that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N13.7-1972..."

ANSI N18.7-1972 paragraph 5.1.7 states in part:

"... control p::ocedures shall be instituted to assure timely conduct of surveillance testing and approyriate documentation, reporting and evaluation of test results..."

Quality Assurance Procedurc 1A 1.2-11.2, Review of Test Data, Revision 1, June 11, 1978, paragraph 6.1 states:

" Deficiencies identified during the performance of tests such as failure to meet acceptance criteria shall be reported to the Station Superintendent with a Plant Information Report (PIR).

The report will document the corrective action taken."

Contrary to the above on January 3, and March 1, 1979, the acceptance criteria for surveillance test was not met, in part, with no subse-quent documentation on a PIR.

Specifically, lube oil pressure for the diesel driven fire pump was recorded high and outside the required range of 45-55 psig per SUR 5.1-15, Fire Protection System Testing, Revision 4, October 6, 1978.

As a result of this, documentation of corrective action taken was not accomplished.

Response

Prccedure SUR 5.1-15, Fire Protection System Teeting, has been revised to ensure that meaningful test data is recorded.

Specifically, the procedure instructs test personnel to allow readings to stabilize before recording data, which will enstre that data is recorded in a consistent manner.

The steps to be taken where test data legitimately falls outside of the acceptance criteria, including the filing of a PIR, have been reviewed with the affected personnel.

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No further action is necessary at this time.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWE COMPANY

^

W. G. Counsil, Vice-President k0bb

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