ML20212C462
| ML20212C462 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/23/1987 |
| From: | Josiger W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IP3-JAS-018B, IP3-JAS-18B, IP3-WAJ-013Z, IP3-WAJ-13Z, NUDOCS 8703030796 | |
| Download: ML20212C462 (3) | |
Text
N.
4 Indian Point 3 Nuclear Power Plant P.O. Box 215 l#
Buchanan. New ork 10511 914 739.8200
- > NewYorkPower 1sf Authority February 23, 1987 IP3-WAJ-013Z IP3-JAS-018B Docket No.
50-286 License No.
DPR-64 Mr. Robert M. Gallo Projects Branch No. 2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Ave.
King of Prussia, PA 19406
SUBJECT:
INSPECTION NO. 50-286/86-23 AND NOTICE OF VIOLATION DATED January 22, 1987
Dear Mr. Gallo:
This letter and Attachment A provide the Authority's response to your Inspection Report No. 50-286/86-23 and the associated Notice of Violation dated January 22, 1987.
Should you or your staff have any questions regarding this matter, please contact Mr. Michael P. Cass of my staff.
Sincerely, Will m A.
osi r sident Ma ag IndianPoitJnit3 Nuclear P wer Plant Attachments WAJ:JAS:lg cc:
IP3 Resident Inspector's Office fu ff f
1,b
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ATTACHMENT A VIOLATION Paragraph 6.8.1 of Technical Specifications requires that written procedures be implemented covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972. Appendix "A" of Regulatory Guide 1.33 lists procedures for the performance of maintenance.
Administrative Procedure AP-9, Work Requests, Revision 6, establishes the mechanism to request corrective maintenance and provide associated management controls. Section 11 states that each Category I corrective maintenance task must be requested via an approved work request.
Administrative Procedure AP-25-3, Material Substitutions, Revision 0, estab-lishes measures for controlling the use of materials as substituted for Category I applications. Section 5.2 states that substituted items will not be installed until the Material Substitution Evaluation is prepared and approved.
Contrary to the above, as identified on November 24, 1986, during a mainten-ance outage, from July to August 1986, the licensee replaced four pressure regulators on the Category I Weld Channel and Containment Penetration Pressur-ization system without the issuance of an approved work request and without an approved Material Substitution Evaluation.
RESPONSE
The discussion and conclusions provided in Inspection Report 86-23 are con-sidered to represent an accurate presentation of the incident.
With the plant shut down *o effect repairs to the low pressure turbines, one of the pressure regulators in the Weld Channel and Containment Penetration Pressurization (WCCPP) System failed. This system maintains an overpressure on the Containment liner welds and in the Containment penetrations during normal operation. The WCCPP is normally supplied by the instrument air system and has a backup supply of nitrogen gas.
The system provides a means of determining the leak tightness of Containment during operation and limits leakage from Containment in the event of an accident. The personnel equipment hatch is pressurized by this system and was in periodic use at the time the regulator failed.
The failed regulator was identified due to the rapid depletion of the backup nitrogen gas supply to the WCCPP. The availability of replacement regulators and the potential personnel safety hazard created if nitrogen gas were to pressurize the personnel hatch prompted the expedient replacement of all four regulators. This replacement occurred during the same shift on which the failure was identified. While the actual work was performed without processing the necessary paperwork, personnel involved in the incident are cognizant of the requirements of the station procedures.
A.
Following identification of the installation of the equipment without the proper procedural controls, the Authority promptly performed a Material Substitution Evaluation in accordance with Administrative Procedure 25.3.
This evaluation demonstrated the replacement equipment to be of equal or better quality than the original equipment. The Plant Operations Review Committee concurred in the conclusions of the material substitution eval-uation.
An engineering evaluation was initiated to determine the seismic capability of the regulators and piping without the restraints installed. Due to the length of time needed to complete the engineering evaluation, a work request was also initiated to install seismic restraints on the regulators. The work request was completed on November 26, 1986.
The engineering evaluation has been completed and demonstrates that the equipment would continue to function properly during and following a seismic event without the restraints.
The Authority has reinstructed all operators in the applicability of the Administrative Procedures which address plant maintenance and modification.
This matter will also be included as a discussion point during the licensed requalification program conducted by the Training Department. The requalif-ication program cycle is completed every six weeks.
Based on the demonstrated level of understanding of the Administrative Procedures on the part of plant personnel and the circumstances under which the equipment was installed, the Authority does not consider this incident indicative of any progammatic weakness. Rather this occurrence reflects an isolated series of events which resulted in the inadvertent procedural oversight.
Senior plant management will continue to underscore the lessons of this event in their routine oversight of plant activities.
l