ML20203N933

Responds to NRC Re Violations Noted in Insp Rept 50-029/86-02.Corrective Actions:Mod of Appropriate Plant Procedure Initiated to Incorporate Guidance for Qualitative Assessment of Channel Check for Blowdown Monitors

ML20203N933
Person / Time
Site:	Yankee Rowe
Issue date:	04/23/1986
From:	Heider L YANKEE ATOMIC ELECTRIC CO.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
FYR-86-043, FYR-86-43, NUDOCS 8605060228
Download: ML20203N933 (2)

Text

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April 23, 1986 FYR 86-043 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Dr. Thomas E. Murley Regional Administrator

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) I&E Letter to YAEC, "I&E Inspection No. 50-029/86-02 "

dated March 24, 1986

Subject:

Response to Inspection 50-029/86-02

Dear Sir:

Reference is made to I&E Inspection No. 50-029/86-02 conducted by your Mr. H. Eichenhole during the period January 7-February 14, 1986, at the Yankee Nuclear Power Station in Rowe, Massachusetts. The report made subsequent to that inspection identified an item which apparently was not conducted in full compliance with NRC regulrements. In accordance wlth Section 2.201 of the NRC's " Rules and Practices," Part 2. Title 10, Code of Federal Regulations, we hereby submit the following information:

Apparent Violation Technical Specification 6.8.1 requires that written procedures shall be established that meet or exceed the requirements and recommendations of Appendix "A" of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 requires implemented procedures for Technical Specification surveillance tests. Technical Specification 4.3.3 specifies a once per 12-hour surveillance requirement consisting of a channel check to demonstrate operability of the Steam Generator Blowdown Monitor instrumentation channels.

This surveillance is to include a qualitative assessment of channel behavior.

Contrary to the above, on January 8, 1986, it was determined that a written procedure was not established that prescribes the required qualitative assessment of channel behavior that would ascertain the once per 12-hour operability of the Steam Generator Blowdown Monitor.

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a United States Nuclear Regulatory Commission April 23, 1986 Attention: Dr. Thomas E. Murley Page 2 DCC 86-038

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Corrective Steps Taken/Results Achieved In response to Reference (b), the following information is submitted for your consideration:

Corrective action has been taken in the form of a Special Order to reinforce to the Operations Department personnel the need to be more attentive to changing parameters and to investigate reasons for changes. Subsequently, modification of the appropriate plant procedure was initiated to incorporate the necessary guidance for qualitative assessment of the channel check for the blowdown monitors. Because the nature of a channcl check is subjective, in that, it is difficult to provide an exact guidance for a qualitative assessment, the implementation of these instructions and procedure modifications will be monitored by plant management to determine the overall effectiveness.

We do feel, however, that an overall improvement in performing channel checks has been made in the last year. This is acknowledged in Reference (b),

Section 9, by the inspector's ntatement, "The licensee's actions as a result of an observed discrepancy between instrumentation channels for a plant parameter appears to indicate an increased sensitivity by plant operators to identify and correct potential of f-normal instrumentation situations."

Not withstanding, management attention will continue to reinforce the importance of proper performance of channel checks and the need to question abnormal channat behavior, compare information, and take appropriate and timely corrective action.

Corrective Steps to be Taken/ Compliance Date Plant Procedure AP-2007, " Maintenance of Operations Department Logs,"

(Revision 17) provides guidance for performing channel checks on the Steam Generator Blowdown Monitors. Most channel checks are required to be performed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, per the Technical Specifications. AP-2007 conservatively requires the subject channel check to be performed once every eight hours.

AP-2007 will be revised to provide improved instructions for performing a qualitative assessment of the Steam Generator blowdown Monitor operation. The revision to AP-2007 is expected to be reviewed, approved, and issued no later than May 16, 1986.

In addition, a review of instrumentation requiring a qualitative assessment per Technical Specifications will be made to ascert ain if further guidance in procedures is required. This review and corrective action resulting from this review will be completed by July 31, 1986.

If you have any questions or desire additional information, please contact us.

Very truly yours, ll 9hl

!!. H .' He i d e r Vice President and Manager of Operations GP/LHH/dpa