ML20064F379
| ML20064F379 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/08/1978 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20064F376 | List: |
| References | |
| NUDOCS 7811290332 | |
| Download: ML20064F379 (3) | |
Text
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i November 8,1978 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
NRC Inspection 50-336/78-30
Dear Mr. Brunner:
Pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, this report is submitted in reply to your letter of October 16, 1978 which infomed the Northeast Nuclear Energy Company of certain activities conducted in apparent noncompliance with NRC requirements.
A.
Apparent Item of Noncomoliance Technical Specification 6.8.1 states in part: " Written procedures shall be established, implemented and maintained covering...sur-veillance activities of safety related equipment."
Contrary to the above, on September 21, 1978, it was determined that surveillance procedure SP 2601 A and SP 2601 B which satisfy the requirements for exercising testable power operated valves and verifying the position of manually operated valves in coron injection flow paths were not revised to reflect the installation, during the last refueling outage, of a power operated valve (2-CH-192) in the flow path from the refueling water storage tank to the charging pump.
In addition, these procedures had been performed on a number of occasions with no procedure changes being initiated by the operators to document deviations from the procedure as written.
Response
NNECO has evaluated the above item as consisting of two problems.
The first involves the failure to revise the procedure while the second addresses operator performance of procedures without adequately updating them.
781129o3vt
Mr. Eldon J. Brunner Page 2 With regard to the first item the primary cause was failure to adequately close out the Plant Design Change Request (PDCR) which added air operators to the valves in question. When the PDCR was reviewed at the end of the outage. the Operating Procedure was revised but not the surveillance proceo re. Since that time the PDCR checklist has been revised to include an expanded procedure revision checkoff section. As immediate corrective action, changes were initiated to update and correct Surveil-lance Procedures 2601 A and 2601 B.
It was noted at the time that the valves had been and were being stroked periodically so that the surveil-lance was in actual fact satisfied. By January 1,1979, all PDCR's completed during and subsequent to the last refueling outage will be reviewed to ensure all appropriate procedure changes have been made.
Concerning the failure to update the procedures, the surveillance program depends on the use of data sheets for documentation of the completion of surveillance requirements. For items which are frequently perfonned and are uncomplicated the procedure might not be physically viewed for each performance, which is consistent with procedure compliance guidelines presented in ANSI N18.7.
In addition the effect of the design change on the operational characteristics of the system was discussed at a past nutage meeting and reviewed by reference to changes made to system operating procedures. Thus the combination of use of data sheets for documentation, the simplicity of the evolution and the previous knowledge of the system effects resulted in the operation being done correctly, while procedure 2601 A remained outdated.
With regards to 2601 B, the procedure requirements are completion of a valve lineup. The valve lineups were changed to show actual position of the valve although a procedure change was not initiated. The personnel reviewing the lineup ensured the altered valve positions did not affect system operability. The change would have been made when it became apparent that this was a permanent valve lineup alteration.
Based on this it is not felt that procedure changes are ignored when the need exists but rather that the need was not recognized for this particular si tuation. Corrective action consisted of incorporating the procedure changes. This action is complete. In addition Operations Department personnel will be made aware of the situation and reminded of the need to be alert to identify required procedure changes and initiate the resultant change. This will be done by December 1, 1978.
Mr. Eldon J. Brunner Page 3 B.
Apparent Item of Noncompliance Technical Specification 4.6.1.1 states in part: " Primary containment integrity shall be demonstrated at least once per 30 days by verifying that....all penetrations....are closed by valves..."
Contrary to the above, on September 21, 1978, it was determined T*y that two containment isolation valves (2-AC-46 and 2-AC-51) were not included in surveillance procedure SP 2605 A, verifying CTMT integrity, which is performed each 31 days.
.Gd
Response
The failure to include 2-AC-46 and 2-AC-51 was an oversight during the procedure preparation. Surveillance procedure 2605 A was revised to include the valves. The procedure was also reviewed to ensure all the required valves were listed. The review identified no additional requirements. All action with regard to this item is complete.
Very truly yours, Northeast Nuclear Energy Company W. wi.ounsi s Vice President WGC:ECF/jmb By:
W. F. Fee Vice President