ML19254E375
| ML19254E375 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/12/1979 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19254E374 | List: |
| References | |
| CYH-79-212, NUDOCS 7911010005 | |
| Download: ML19254E375 (4) | |
Text
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e CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN. CONNECTICUT P. O. SOX 270 H ARTFORD. CONNECTICUT 06101 TELEPwe=E 203 668-6911 September 12, 1979 Docket No. 50-213 CYH 79-212 U. S. Nuclear Regulatory Commission Region 1 Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406 Attn:
Mr. E. J. Brunner, Chief Reactor Operations and Nuclear Support Branch
Reference:
Letter, E. J. Brunner to W. G. Counsil, dated August 21, 1979 Inspection 50-213/79-13
Dear Mr. Brunner:
The following explanation concerning the items of non-compliance described in the above reference is submitted to your office pursuant to the provisions of Section 2.201 of the Nuclear Regulatory Commissions " Rules of Practice", Part 20, Title 10, Code of Federal Regulations.
W 1282 C' C
7911010
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Infraction A.
Technical Specification 6.8.1 states, in part, " Written procedures and administrative policies shall be established, implemented, and maintained..."
Contrary to the above, on May 9, 1979, procedures NOP 2.12-1 and SUR 5.1-4 were not adhered to in that valve SI-V-866, which was required to be in the open position, was found in the shut position.
Recponse A.
SI-V-866 is a small manual valve that provides isolation capability for a pressure gage installed on a recirculation line used primarily during Core Cooling System Hot Operation Test.
The valve is normally throttled (just cracked off its seat) to provide dampening for tbs pressure gage.
This valve is provided with a packing gland to prevent leakage along the valve stem. Normally, once the valve is set in the proper position it is seldom operated.
Although the valve was assumed to be shut when checked it could have been in its normal throttled position with the gland follower tightened down.
The Valve Lineup Checkoff in both the above noted procedures called for the valve to be in the open position.
The natural assumption in this situation is the valve should be fully opened.
To avoid future confusion in this area procedures NOP 2.12-1 and SUR 5.1-4 were revised to reflect the actual proper valve position as " throttled".
A.
Contrary to the above, Procedure QA 1.2-6.4, Temporary Procedure Change, which states in Step 5.1, "When a deviation from a procedure is required a temporary procedure change shall be utilized," was not adhered to in that on April 26, 1979, a deviation was made to procedure NOP 2.9-1 to shut valve RH-MOV-21 and no temporary procedure change was initiated.
Response
A.
To improve the reliability of changeover to containment sump recirculation mode during a Loss of Coolant incident the normal position for RH-MOV-21 was changed from "open" to " closed". A temporary procedure change should have been initiated to reflect this change until the associated procedures could be changed.
This oversight and the importance of adhering to procedures was discussed with the personnel involved.
The applicable procedures have been revised to reflect the proper position of the valve.
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Infraction B.
Technical Specification 6.8.2 states, in part, "Each procedure and administrative policy...shall be reviewed by the PORC and approved by the Plant Superintendent prior to implementation..."
Contrary to the above, as of May 9, 1979, valve SI-V-878 (RRST-SI Recire. Stop) and valves for the Emergency Diesel Generator fuel oil supply were being positioned utilizing a Locked Valve Check List, dated July 26, 1973, which is not reviewed by the PORC nor approved by the Plant Superintendent.
Response
B.
Plant procedure SUR 5.1-126, Locked Valve List was reviewed by the PORC and approved by the Station Superintendent on May 21, 1979.
Infraction C.
10 CFR 50 Appendix B, Criterion V, stated in part:
Activities affecting quality shall be prescribed by documented...
procedures... of a type appropriate to the circumstances..."
" Procedures...shall include appropriate quanitative or qualitative acceptance criteria for determining that important activitias have been satisfactorily accomplished."
QAP 5.0, Paragraph 5.2.4 states:
" Cognizant Department Heads review and approve department procedures, instructions and drawings to ensure the inclusion of adequate quantitative and qualitative acceptance criteria, as appropriate
'or determining satisfactory work performance and quality cor 11ance.
These criteria apply to activities such as design, operations, test control, inspection and plant modifications."
Contrary to the above, on May 9, 1979, an inadequate valve lineup and inadequate valve labeling caused two valves that isolate the 40,000 gallon fuel oil tank from the 5000 gallon day tanks for Emergency Diesel generators (EDG) 2A and 2B "to be" closed, instead of locked open.
Closure of these valves would prevent refilling of t a day tanks when required during EDG operation.
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Response
C.
Procedural inadequacies relative to proper valve positions were resolved by approval of SUR 5.1-126, Locked Valve List on May 21, 1979.
Leakage through the level control valve for the 5000 gallon underground storage tank was resolved and the isolation valves locked in the open position. The situation which led to the above infraction and the importance of complying with regulatory criteria and plant procedures was discussed with the involved personnel.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER CGIPANY
/
W. G. Counsil, Vice-President
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