ML20197C137

Responds to NRC Re Violations Noted in Insp Rept 50-213/86-20.Corrective Actions:Maint Supervisors Instructed That quality-related Work Will Be Performed or Verified by Qualified Level 1 Personnel

ML20197C137
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/14/1986
From:	Opeka J, Sears C CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A06040, A6040, NUDOCS 8610310201
Download: ML20197C137 (5)

Text

- _ _ .

F.

~

CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N. CONNECTICUT P O Box 270 HARTFORD. CONNECTICUT 06141-0270 TELEPHONE 203-665-5000 October 14,1986 Docket No. 50-213 A06040 Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406

References:

(1) E. C. Wenzinger letter to 3. F. Opeka, dated August 29,1986, transmitting Inspection No. 50-213/86-20.

(2) 3. F. Opeka letter to C. I. Grimes, " Proposed Revision to Technical Specifications Surveillance Requirements of Man-ual Containment Isolation Valves," dated August 29,1986.

(3) C. I. Grimes letter to 3. F. Opeka, " Temporary Waiver of Compliance from Technical Specification Sections 1.8 and 3.11," dated September 11, 1986.

Gentlemen:

Haddam Neck Plant Response to I&E Inspection No. 50-213/86-20 Pursuant to. the provisions of Section 2.201 (" Notice of Violation") and Appendix C (Enforcement Policy) of the NRC's Rules of Practice (10 CFR 2),

this report is submitted in reply to Reference (1), which informed Connecticut Yankee Atomic Power Company (CYAPCO) of two violations which were identified during a routine inspection at the Haddam Neck Plant from July 8 through August 14, 1986. Per conversation between E. 3. Mroczka of CYAPCO and E. McCabe of NRC on September 23, 1986, the response due date was extended to October 14,1986.

Alleged Violation Technical Specification 6.8 requires procedures to be established and maintained for implementation of the Facility Fire Protection Program. Preventive Maintenance Procedure 9.5-120 requires that portable fire extinguishers be inspected monthly.

8610310201 861014 3 1 DR ADOCK 0500

$ % CD \

F.

t .

Contrary to the above, portable fire extinguishers in the switchgear room were not inspected in July,1986.

This is a Severity Level V violation (Supplement 1).

Response

Failure to inspect the fire extinguishers in the switchgear room was the result of poor communication between contractor personnel assigned to this duty and station personnel responsible for its completion. Since the contractor was not authorized access to the switchgear room, he was not able to perform the inspection and failed to notify anyone. Station personnel were under the erroneous impression that the inspection was completed and the work order for the inspection was closed out. Immediate corrective action was to re-perform the inspection to insure that all fire extinguishers had been checked.

To prevent recurrence, all maintenance supervisors have been instructed that all quality related work will be performed or verified by qualified Level I personnel.

A memo to the maintenance department was issued by the maintenance supervisor stressing the importance of verification and the meaning of a signature on a proceduie. Corrective actions are complete.

Alleged Violation Technical Specification 3.11, Containment, requires containment integrity to be maintained whenever the reactor coolant system (RCS) is above 300 psig and 200 degrees F.

Technical Specification 1.8, Containment Integrity, requires that all penetrations required to be closed during accident conditions are either: a) capable of being closed by OPERABLE containment automatic isolation valves, or b) closed by manual valves, blind flanges, or deactivated automatic valves secured and locked in their closed positions.

Contrary to the above, on July 8,1986, with the RCS greater than 300 psig and 200 degrees F, normally locked closed manual containment isolation valves SI-V-863A/B/C/D were opened to perform monthly surveillance tests.

This is a Severity Level IV violation (Supplement 1).

Response

These valves have been operated for monthly core cooling wrveillance testing since plant operation began in 1967. This test practice is described in the FDSA and can therefore be considered accepted by the NRC by virtue of issuance of the operating license. Short duration, infrequent opening of valves such as these to satisfy another Technical Specification requirement (in this case, 4.3, Core Cooling Systems - Periodic Testing) were not considered to be deviations from the normal containment integrity requirements (which do not explicitly forbid this operation). Therefore, although operation of these valves could be techni-cally interpreted as a violation of the letter of the Technical Specifications, continued surveillance represents correct plant operations. Further, to eliminate

any potential ambiguity, CYAPCO applied for a temporary Technical Specification waiver and subsequent license amendment (Reference 2) to author-Ize the surveillance at issue here, and provided the requisite technical justifica-tion. The Staff concurred with our request by issuing the temporary waiver (Reference 3). In sum, this confirms that we collectively have verified the correctness of surveillance practices in effect since initial plant operation as documented in the FDSA. This emphasizes the fact that there was no safety violation here, only confusion caused by ambiguities in the Technical Specifica-tions.

Although CYAPCO does not intend to contest this violation, we believe that the following factors are relevant. 10 CFR 2, Appendix C identifies several criteria, including timeliness of licensee actions as well as other mitigating factors, which if met would preclude the classifying of a deficiency as a violation. CYAPCO believes that these criteria were met in this case, as (1) the deficiency was identified, (2) immediate corrective actions, as detailed below, were imple-mented, and (3) the situation was reported to the NRC.

It is also our view that our corrective actions for previous deficiencies identified in Inspections 84-14 and 86-08 could not have been expected to preclude occurrence of this event as they were narrowly focused on clarifying the Technical Specifications and did not address the issue generically. We acknow-ledge that previous corrective actions should have been more comprehensive. As such, although the problems identified in Inspections 34-14 and 86-08 were addressed, the limited scope of corrective actions for those items was not broad enough to foresee and preclude the deficiencies identified in Inspection 86-20. In contrast, the corrective actions in this case are broader in scope and are intended to identify, correct and preclude any similar deficiencies.

The immediate corrective actions consisted of maintaining SI-V-863A/B/C/D locked closed. In addition, to preclude recurrence, CYAPCO is conducting a review of all manual containment boundary valves. This review will include identification of valves which are opened periodically during operation, and an evaluation to determine if this is necessary. If not, those valves will be maintained locked closed and marked or tagged to insure personnel understand they are containment boundary valves. If continued opening is appropriate, procedural controls will be instituted to permit the necessary operation while ensuring containment integrity can be rapidly reestablished when required. The Technical Specifications will be clarified accordingly. This review will be completed by November 3,1986. The schedule for any additional work, such as I submittal of amendment requests, will also be provided by November 3,1986.

It should also be noted that prior to discovery of the SI-V-863A/B/C/D discrepancy, CYAPCO was actively addressing the issue of containment integ-i rity. During a review of the CY Plant Design Change Task Group recommenda-I tions on 10 CFR 50, Appendix J, several procedural inconsistencies related to l containment integrity were identified. Activities to address these procedural inconsistencies were initiated and are now being performed in conjunction with the aforementioned review of all manual containment boundary valves.

I 1

i t

i

_4 Additional Items Reference (1) also requests an assessment of events described in report details 4.2 and 4.8.

Report Detail 4.2 CYAPCO maintains its original position that there was no reason to declare the "A" charging pump inoperable when it first experienced minor oscillations (all within limits) in pressure and amperage.

Operability of equipment is proven by its ability to meet corresponding surveil-lance requirements. During the period that the "A" charging pump was running, it never failed to meet its Technical Specification surveillance requirements for operability. With leakage past the metering pump relief valve occurring at the same time, operators were led to believe this was the cause of the oscillations.

In response to the issue of the "B" charging pump not exhibiting the same oscillations, it should be noted that the "B" charging pump has a lower discharge pressure than the "A" pump, so its potential for lifting the metering pump relief valve would have been less.

Report Detail 4.8 Replacement of the excore detectors following maintenance was performed by plant personnel as on previous occasions. On this occasion, due to the more restrictive axial offset curves which were implemented due to the utilization of thrice burned fuel in the core, the relative impact of the minor change in placement of the detectors was significant. However, the operators did not foresee that the minor change in detector placement would result in a significant change in nuclear instrumentation system calibration.

The plant has been operated for many years with axial offset curves that were more tolerant than the curves that were utilized af ter the last refueling startup.

Consequently, in the past, detector removal and reinstallation had no noticeable effect on axial offset indication. The more restrictive axial offset curves accentuated the small change in ion chamber current due to detector position change. We conclude that operator judgement here was acceptable since it relied on comparable previous changes which yielded no adverse effects.

To preclude recurrence, all maintenance procedures that affect excore nuclear instrumentation have been revised to require reactor engineering notification if detector position is disturbed for any reason.

CYAPCO therefore concludes that interface between operators and maintenance personnel is generally adequate and that these isolated instances do not indicate a problem in this area. In fact, first line supervisors in the Operations, Maintenance and Instrument and Controls Departments meet daily to discuss plant problems and proposed repairs as well as planned preventative mainte-nance.

My Staff remains available to discuss these and any other issues.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY ki .b

3. F. Opeka '

Senior Vice President By: C.F. Sears Vice President