ML20011A074
| ML20011A074 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/18/1981 |
| From: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011A073 | List: |
| References | |
| 50-245-81-09, 50-245-81-9, 50-336-81-08, 50-336-81-8, NUDOCS 8110060525 | |
| Download: ML20011A074 (3) | |
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I APPENDIX A NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket No. 50-245 Millstone Nuclear Power Station, Unit 1 l
As a result of the inspection conducted on May 26, 1981 to May 29, 1981 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:
10 CFR 50.55a(g)(4) states, in part, that: "Throughout the service life of a... nuclear power facility, components...shall meet the requirements... set forth in Section XI of the ASME Boiler and Pressure l
Vessel Code...."
f Millstone Nuclear Fower Station, Unit 1, Technical Specification 4.13B states that:
" Inservice testing of... pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code..., with exemptions approved by the NRC...These exemptions and alternate testings are included in the Inservice Inspection Program."
Section XI of the ASME B&PV Code, Article IWP-3100, Inservice Test Procedure, and Article IWP-3200, Analysis of Results, states, in part that:
"...the resistance of the system shall be varied until either the measured differential pressure or the measured flowrate shall equal the corresponding reference value."
" Reference values are a set of values for certain operating parameters at a point of operation readily duplicated during
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subsequent inservice tests and shall be determined during a j
single test performance."
"Each measured test quantity (parameter) shall be compared to the reference value of the same quantity. Any deviations determined shall be compared to the limits given in Table IWP-3100-2..."
"When test result deviations fall within the " Alert Range" of Table IWP-3100-2, the corrective action shall include doubling the frequency of tests and when they fall within the " Required Action Range" the pump shall be declared inoperative."
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Appendix A 2
The NRC approved Inservice Inspection Program-Differential Pressure Relief Request (Note 5), specifies an alternate test method of measuring sea level for equivalent suction pressure during inservice tests of the Service Water Pumps.
Section XI of ASME B&PV Code, Article IWV-3410 and IWV-3520 requires that corrective action be initiated immediately if a valve fails to exhibit the required change of disk position during a test and be declared inoperable if the condition cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above specific requirements, as of May 29, 1981, required surveillance tests were performed using pro edures which did not conform to Section XI of the ASME Boiler and Pressure Vessel Code.
Test records reviewed indicated that the latest surveillance tests performed for the Fuel Pool Cooling Pumps, Service Water Pumps, and Reactor Feedwater Pumps were May 7,1981, May 14,1981, and September 30, 1980 respectively. Details are as follows:
Pump surveillance test procedure SP 1060, along with the individual Test Plans (Form SP 1060-15) for the Fuel Pool Cooling, Reactor Feedwater, and Service Water Pumps do not specify that the system hydraulic resistance be varied to equal an established reference value for differential pressure or flowrate.
Pump surveillance test procedure SP 1060 permits an optional method of establishing Pump Test Base Line Data (reference values) by analysis of tests over a six month or greater period.
Pump surveillance test procedure SP 1060 permits an optional use of a pump characteristic curve in lieu of established reference values for analysis of test results and acceptance criteria.
Pump surveillance test procedure SP 1060 does not invoke the specific required corrective actions when test results are un-acceptable and fall within the " Alert Range" or " Required Action Range" of Table IWP-3100-2.
Pump surveillance test procedure SP 1060, along with the Test Plan (Form 1060-15) for the Service Water Pumps does not require measurement and recording of sea level for conversion to equivalent suction pressure.
Valve surveillance test procedures SP-1061, SP 608.15, and SP-608.17 do not invoke the specific required corrective actions when test results are unacceptable by a valves' failure to exhibit the required change of disk position.
The above examples collectively constitute a Severity Level IV Violation.
(Supplement I).
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Appendix A 3
Pursuant to the provisions of 10 CFR 2.201, the Northeast Nuclear Energy Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be 51ven to extending your response time.
The responses directed by this Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
SEP 181381 Orisinal sicace 37, Dated Eldon J. Brunner, Chief, Projects Branch #1, Division of Resident and Project Inspection l
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