ML20012B119

Responds to NRC 900205 Ltr Re Violations Noted in Insp Rept 50-443/89-17.Corrective Actions:Conduit Seals Installed on Required Solenoids & Operability Completed on 900204

ML20012B119
Person / Time
Site:	Seabrook
Issue date:	03/07/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-90055, NUDOCS 9003130602
Download: ML20012B119 (4)

Text

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New Hampshire u c, , .p Senior Vice Presi tand

_ _ _ _ Chief Operating C4cer NYN- 90055 March 7, 1990 United States Nuclear Regulatory Commission '

Washington, DC 20555 Attention: Doctu3ent Control Desk

References:

(a) Facility Operating License No. NPF-67. Docket No. 50-443 (b) USNRC Letter dated February 5, 1990, ' Inspection Report 50-443/89-17', M. W. Hodges to E. A. Brown

Subject:

Reply to a Notice of Violation Gentlemen:

In accordance.with the requirements of the Notice of Violation contained in Reference (b), the New Hampshire Yankee response to the cited violation is provided as Enclosure 1.

Should you have any questions concerning our response, please contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474-9521, extension 3772.

Very truly yours,

x. 94 ALLp Ted C. Feigenbaum cci Mr. William T. Russell Regional Adntinistrator United States Nuclear Regulatory Commission Region I 475 Allendale Road (L .

King of Prumsia PA 19406 M Mr. Victor Herses Project Manager 40 Project Directorate I-3

'$8' United States Nuclear Regulatory Conunission Division of Reactor Projects

gg-So Washington, DC 20555 NM

'gg Mr. Noel Dudley

'oo NRC Senior Resident Inspector 7 P.O.. Box 1149 Qg Seabrook, NH 03874

. NG . New Hampshire Yankee Division of Public Service Company of New Hampshire sh i P.O. Box 300

• Seabrook, NH 03874 e Telephone (603) 474 9521 1 u

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New Hampshire Yankee  :

March 7. 1990 l-f

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s Enclosure 1 to NYN-90055 ,

,i Reply to a Notice of Violation i

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New Hampshire Yankee i March 7, 1990 j f

REPLY TO A NOTICE OF VIOLATION J i

During an NRC inspection conducted on November 6-10 and December 4 l 1989, a violation of NRC requirements was identified. In accordance with  ;

the instructions provided in the Notice of Violation forwarded by Reference (b),

the NHY response to the violation is provided below. ,

Violations- ,

10 CFR 50.49 (f, states, in part, 'that each item of electrical equipment important to safety must be qualified by testing or experience with identical or similar equipment under similar conditions with supporting ,

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analysis to show that the equipment to be qualified is acceptable'.

Contrary to the above, on November 10, 1989, the licensee failed to demonstrate qualification of the installed ASCO valve configuration, by l either test or analysis, for the environmental conditions in which they must function.

Response

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NHY has performed d review of ASCO solenoid valves installed without conduit seals and the following corrective action has been taken.  ;

1. Thirty (30) ASCO solenoid valves have been modified by a design t change (MHOD 89-620) that installed Namco Electrical Conductor Seal Assemblies (ECSA) to preclude any potential moisture concerns, and to improve the prior method of preventing moisture from entering -

the ASCO solenoid electrical enclosure. Operability on this decign change was complete on February 4, 1990.

2. Four valves located outside the containment were evaluated as qualified on the basis that they would not experience a harsh .

environment during a LOCA, and would not perform a safety function during a hot water line break outside the containment. Four additional valves located outside the containment were evaluated to be included in the next category of valves as having an Operability Code C.

3. Forty-three (43) valves were evaluated to have an Operability code C in that they will experience harsh steam and moisture conditions due to ,

design basis accidents but need not function for the mitigation of ,

these accidents. Their failure, in any mode, is not detrimental to plant safety or accident mitigation. Operability Code C determinations ,

were added to the applicable documentation packages by Document Revision Report (DRR)90-014.

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New Hampshire Yankee r March 7, 1990 6

4. Thirty-four (34) valves were evaluated to be qualified on the basis of their operability time during a LOCA in that they are subject to a harsh environment but deenergize on the isolation signal. These valves are also adequate for small break LOCA events.

Conduit seals have been installed on the required solenoids and Operability was complete on February 4, 1900. An analysis was completed on ,

February 7, 1990, and documented in Engineering Evaluation Number 90-04 ASCO Solenoid Valve Qualification. The results from this evaluation were added to .

the applicable documentation packages on February 16, 1990, and are available onsite for NRC staff review. The applicable Equipment Qualification files are scheduled to be updated by June 15, 1990.

Furthermore, an independent review by a technical specialist was -

conducted via Quality Assurance Audit 90-A02-05. This independent review confirmed that actions taken to resolve the concerns regarding ASCO solenoid valve seals is proper and technically sound.

To avoid further violations of this type, when ASCO solenoids which are required to be energiaed during a harsh steam environment condition are adden to the plant design, they will be installed with qualified conduit seals.

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