ML20113D316
| ML20113D316 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/07/1985 |
| From: | Uderitz R Public Service Enterprise Group |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8501230056 | |
| Download: ML20113D316 (4) | |
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u s-Ja' ary 7, 1985 Regional Administrator, Pegion 1 U.
S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19400 Attention:
Mr. Richard W.
Starostecki, Director Division of Project and Resident Programs Gentlemera ITEMS OF CONCERN NRC COMBINED INSPECTION 50-272/84-36 AND 50-311/84-35 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Your letter, dated December 6, 1984, identified three items of concern resulting from the referenced inspection report.
The responses to those concerns are as follows:
Item 1 The failure of your program to identify status of this equipment to the operators.
On October 19, 1984, the operators did not know whether ICV 69 had successfully passed a leak rate test and again, on November 27, 1984, the operators were still unsure of the status.
No guidance had yet been provided to preclude inadvertent use of ICV 69 as an isolation valve af ter December 10, 1984, when the current leak test surveillance interval expires.
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Mr.
R.
W.
Starostecki 1/7/85 Response to Item 1 On October 19, 1984, the Operations Department was notified verbally that ICV 69 had not successfully passed the leak rate test required by the Technical Specifications.
Technical Specification Action Statement 3.6.3.1.b was entered at that time, and CV69 was deactivated and tagged shut in accordance with the action requirements.
The valve was considered inoperable until approximately November 20, 1984, when it was discovered that ICV 69 had, in fact, not failed a leak rate test.
Following this discovery, a thorough investigation was performed to establish the facts surrounding the occurrence.
Maintenance Procedure M16E has been revised to require an incident report to be initiated in the event that either CV68 or CV69 are not acceptable as containment isolation valves due to unacceptable leak rates.
This will ensure that the Operations Department is aware of the current status of these valves.
In eddition, on December 10, 1984, a letter was issued to the Operations Department to preclude further use of CV69 as an isolation valve, since the current leak test surveillance interval had expired.
Item 2 Although the Technical Specifications permit testing of either CV68 or CV69, we question the decision not to test CV69 following an inconclusive test en April 9, 1984.
Even though a problem was subsequently identified with the test boundary valves, a prudent course of action for resolution of a questionable unsatisfactory test for a safety-related component would include a subsequent retest of the component to identify it acceptability.
Response to Item 2 Although the Technical Specifications do permit testing of either CV68 or CV69, we also believe that an error in judgement was made in not retesting CV69 following repair of the boundary valves.
The situation was thoroughly discussed with testing personnel, and on December 4, 1984, prior to your letter of concern dated December 6, 1984, Maintenance Procedure M16E was revised to require the testing of both CV68 and CV69 every ref ueling outage.
2
o-Mr.
R.
W.
Starostecki 1/7/85 Item 3 We are concerned with the length of time it took for you to establish-the facts surrounding this event.
The acceptability of CV69 as an. operable isolation valve was not determined until after you had already erroneously documented, in Unit 1 LER 8 4-0 22, the fact that it had failed a leak rate test.
The need for better documentation is clearly evident in this case.
Response to Item 3 On October 19, 1984, at the daily morning meeting, there was no reason to question the reported leak rate test failure of CV69.
This information was immediately transmitted to the operating shift, who took the appropriate action in accordance with the Technical Specification requirements.
The incident was then documented on an incident report, and an investigation ensued for reportability determination.
The incident was subsequently determined to be reportable, r.J was documented in Unit 1 LER 84-022-00 and transmitted to tne USNRC on November 16, 1984.
During subsequent data sheet review and discussions with testing personnel, it was discovered that CV69 had not failed the leak rate test. Further investigation has revealed that the data sheet for documenting the leak rate test results did not contain provisions for documenting boundary valve leakage.
It appeared, when reviewing these data sheets, that CV69 had failed; however, the failure was actually due to boundary valve leakage, which was not apparent to the individual reporting CV69 failure or to the personnel reviewing the incident for reportability.
As a corrective action, the data sheet in Maintenance Procedure M16E has been revised to more clearly identify important test information.
This revision includes a means for more readily distinguishing between boundary valve test results and isolation valve test results.
We also are concerned with the length of time that was required to establish the facts surrounding this event, and believe that our corrective actions will precluae future 3
confusion and resultant delays.
Mr.
R.
W.
Starostecki 1/7/85 In addition, Unit 1 LER 8 4-0 22-00 will be revised by January 18, 1985, to incorporate this new information and document the facts surrounding the event.
Sincerely, t;st-ts.-
C Mr. Donald C.
Fischer Licensing Project Manager M r. James Linville Senior Project Inspector i
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