ML20210J248
| ML20210J248 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/31/1978 |
| From: | Switzer D NORTHEAST NUCLEAR ENERGY CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20210J229 | List: |
| References | |
| 50-336-77-31, NUDOCS 9708150294 | |
| Download: ML20210J248 (4) | |
Text
, _ _ _ _ _ - _. - - _ _
' 3, y.
y+:
1.
NNBCO
,,o,c m HoRTHEAST NUCLEAR E ERGY COMPANY -
-.3666691
. A NoRTMEAST UTILITIES COMPANY l
January 31, 1978.
Mr. Boyce H. Grier Director, Region I
~ Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Office of Inspection and Enforcement i
Inspection Report 50-336/77-31, License OPR-65 n.#
Dear Mr. Grier:
Pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2. Title 10, Code of Federal Regulations, this reply is submitted to the above referenced audit report, which informed Northeast Nuclear Energy Company of apparent items of non-compliance with NRC. requirements.
The response is included directly below the item of non-compliance as identified in-the Notice of Violation.
Item A:
Infraction Technical Specification 4.7.8.1.c states in part:
"At least once per 18 months during shutdown, a representative sample of at least 10 hydraulic snubbers or at least 10%
of all snubbers listed in Table 3.7-1, whichever is less, shall be selected and functionally tested to verify
. correct piston movement, lockup and bleed.... For
~
- each snubber found inoperable during these functional 4
tests, an additional minimum of.10% of all-snubbers or 10 snubbers, whichever is less, shall also be functionally tested.. until no more failures are found or all snubbers have been functionally tested."
=_
9708150294 7 m g7 gDR ADOCK 05000336 PDR J
Mr. Boyce H. 'Grier 2-January 31, 1978:
Reference:
Office of Inspection and Enforcement inspection Report 50-336/77-31.
License DPR-65 Item A:
Infraction (continued)-
Contrary to the ai>ove, during the June 1977 outage, the liceni,ee did not test an. additional 10 snubbers for each snubber found inoperable-per procedure 27338. Hydraulic Snubber Functional Test, Revision 0, June 1, 1977.
Response
Following the exit interview, plans were made to reset the remaining hydraulic snubbers not previously tested m
having a load capacity of less than or equal to 50,000 lbs. Units exceeding 50,000 lb. capacity are excluded from functional test requirements by Technical Specification
- 4. 7. 8.1. c.
It was also determined that these units having factory precalibrated lockup and bleed valves and pins would not require resetting since the precalibrated 4
parts were certified to meet specified requirements as part_of the corrective action in response to NRC IE Circular 7h05
-There were 52 hydraulic snubbers which were reset to values recomended by ITT Grinnell for field adjustment of snubbers.
In addition, to provide assurance that, those units exceeding 50,000 lb. capacity are within the acceptance criteria of the surveillance procedure, a 6",
8" and 10" unit were all. functionally tested and found to.
. meet the acceptance criteria.-
As action to prevent recurrence, the surveillance test procedure was changed following the June 1977 testing to specify expansion of the testing scope on the basis of r the testing acceptance critertaversus being inoperable,
_i.e., failing to-lockup.
f
..-n.-
L Mr. Boyce H. Grier January 31, 1978
Reference:
-Office of Inspection and Enforcement Inspection Report 50-336/77-31, License DPR-65 Item 8:
Infraction 10 CFR 50.59 states in part:
"The holder of a license
... may (1) make changes in the facility as described in the safety analysis report... without prior Commission approval, unless the proposed change...
involves
... an unreviewed safety question.
The Technical Review dated November 2, 1977, of the Safety Evaluation for the New Fuel Elevator Modification PDCR 2-219-77 conditionally approved the modification as not an unreviewed safety question; one of the provisos being, "Both the electrical and mechanical upper stops shall be tested in the spent fuel inspection position."
Contrary to the above, the modified New Fuel Elevator was used to inspect spent fuel on December 8,1977, without first verifying that the modification was not an unreviewed safety question in that the mechanical upper stop was not tested.
Response
The inspection of spent fuel was immediately halted when notified by the inspector of his findings. A Non Conformance Report (NCR) was written to prevent use of the modified new fuel elevator until the upper mechanical stop testing was dispositioned. Subsequent review of the design of the mechanical and electrical upper limit mechanisms indicated that testing of the electrical upper stop also verified the installation of the upper mechanical stop.
, Based on the above consideration and the potential for equipment damage if actual testing of the mechanical upper stop was conducted, the NCR was dispositioned to "Use-As-Is".
Spent fuel inspection was then allowed to
-proceed..
l Mr. Boyce H. Grier January-31, 1978.
f
- Refere'nce: - Office of Inspection and Enforcement inspection Report 50-336/77-31, a
License DPR-65 Item B:
Response (continued)
As action to prevent recurrence, the-failure to address all items in the Plant Design Change Request (PDCR)
Safety Evaluation was discussed with the responsible person and the necessity to disposition all items emphasized.
In addition, all staff engineering personnel were instructed to ensure their review of PDCR's emphasized a check of all items specified as a condition of approval and that these items be dispositioned prior to completion of PDCR implementation.
E Very truly yours.
NORTHEAST NUCLEAR ENERGY COMPANY
[
D. C. Switzer President DCS/EJF/jj
.,m
- -, - - ~
-