ML20215J684
| ML20215J684 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/30/1987 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GDW-87-114, MN-87-57, NUDOCS 8705080201 | |
| Download: ML20215J684 (4) | |
Text
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MAIRE 5ARHEE ATOMICPOWERCOMPARUe
,voug,ay,?n"g%,
h (207) 623-3521 e
April 30, 1987 HN-87-57 GDH-87-114 Reglen I United States Nuclear Regulatory Commission Office of Inspection and Enforcement 631 Park Avenue t
King of Prussia, Pennsylvania 19406 Attention: Mr. Hilliam T. Russell, Regional Administrator
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo dated March 31, 1987 - Inspection Report No. 87-01
Subject:
Response to Notice of Violation Gentlemen:
In Reference (b), you transmitted to Maine Yankee a Notice of Violation.
Below we have restated each part of the violation and our response including necessary corrective action.
VIOLATION 10 CFR 50, Appendix B, Criterion XI, states in part:
" Test results shall be documented and evaluated to ensure that test requirements have been l
satisfied."
I The MYAPCo operational QA program,Section II.F requires implementation of ANSI N45.2 - 1977, Quality Assurance Requirements for Nuclear Power Plants. This standard requires the test report to identify the date of test and the results to be documented and evaluated by responsible authority to ensure that the test requirements have been satisfied.
Contrary to the above, as of January 30, 1987, test records did not l
identify the date of the test and the documented results were not l
evaluated adequately by a responsible authority as evidenced by:
l l
8705000201 870430 PDR ADOCK 05000309 G
PDR l
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MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear' Regulatory Commission Page Two Attention: Mr. William T. Russell, Regional Administrator NN-87-57 Item 1 The dates of routine Emergency Core Cooling System (ECCS) tests, performed per Procedure 3.1.2, were not identified.
MAINE YANKEE RESPONSE ANSI 45.2 - 1977 states, in part, that "... inspection and test records shall, as a minimum, identify the date of inspection or test, the inspector or data recorder, the type of observation, the results, the acceptability and the action taken in connection with any deficiencies noted".
t-Procedure 3.1.2, ECCS Routine Testing, Revision 37,. issued March 4, 1986 and all subsequent revisions, has sign-offs at the end of each test section that documents the date and time of supervisory review for each test section. The inspector expressed concern that since there are 9 sections and the entire procedure typically takes 2-3 days to perform, there was potential for one or more of the sections to exceed the 31-day surveillance period by more than the allowable 1.25 or 3.25 factor. He felt that there was also potential that the results might not be analyzed within the ASME XI 96-hour time limit.
A review of all completed ECCS procedures subsequent to July 1986 revealed that the completion dates for the entire procedure never exceeded a single interval ratio of 1.16 (1.25 required) or a three interval ratio of 3.19 (3.25 required).
Since all 9 sections were included, it follows that the intervals for all were conservatively short. Shift Operating Supervisor (SOS) review of individual sections occurred immediately following performance of each section and prior to commencement of the next one.
Final review of the entire completed procedure occurred within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of completion by the Plant Shift Superintendent (PSS).
Maine Yankee considers that the intent of the ANSI standard has been met.
I Iltm_2 Evaluated and approved results of a surveillance test performed per i
procedure 3.1.5, on March 12, 1986, documented the auxiliary feed pump 25B differential pressure as 1234.5 psid while the acceptance range was between 1068 and 1220 psid.
l Maine Yankee Resnonse Maine Yankee conducted a review of subsequent surveillance test results to determine whether this was an isolated occurrence. As no other instances of this have been found, Maine Yankee considers this to be an isolated occurrence and the operability of the pump was not adversely affected. He have concluded that no procedural changes are needed. To prevent recurrence, the individuals involved have been counselled.
The requirement to verify acceptance criteria during shift supervisory reviews has been reinforced by memoranda to all PSSs and SOSs.
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'I MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission Page Three Attention: Mr. Hilliam T. Russell, Regional Administrator MN 57 Item 3 Evaluated ard approved results of a surveillance test performed per Procedure 3.1.5 on August 6, 1986, documented the auxiliary feed pump 25A suction pressure as 5.2 psig while the acceptance criteria was greater than 7 psig.
Maine Yankee Restonse Procedure 3.1.5, Emergency and Auxiliary Feed Pump Test, was completed at 0955 on August 6, 1986.
Pump suction pressure is subtracted from pump discharge pressure to determine pump differential pressure. The latter two parameters were within the specified tolerances as were pump amps.
The SOS concluded, correctly, that this did not invalidate the surveillance nor did it cast doubt on operability of P-25A. The SOS noted on the Surveillance Procedure Review Sheet that the suction pressure gauge was reading ircorrectly and submitted a Hork Order (DR). Upon completion of the Work Order repair, the P-25A test was repeated satisfactorily at 2127 on the sa'ne day and the retest value (11.5 psig) inserted in the appropriate block of the earlier procedure.
Maine Yankee considers that all actions were appropriate and in accordance with approved arocedures and the cited ANSI standard.
Item 4 Evaluated and approved results of a surveillance test performed per Procedure 3.1.5 on December 10, 1986, documented the auxiliary feed pump 25B discharge pressure originally as 1239 psig while the acceptance range was between 1075 and 1229.
This result was subsequently changed to 1229 psig without explanation.
Malae Yankee Response Contrary to the above, we believe, based on our review of the records, that the operator initially recorded the pump discharge pressure as 1230 psig, and then changed it to 1229 psig to fall within the acceptance range. As a result of this incident the individual responsible, a newly qualified watchstander, was cautioned about changing log entries without explanation. Subsequent pump test results were reviewed to confirm that l
pump discharge pressure was acceptable.
These actions were completed on January 30, 1987 when full compliance was achieved.
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MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission Page Four Attention: Mr. Hilliam T. Russell, Regional Administrator NN-87-57 In summary, the additional information provided above, and the corrective actions which we have taken, should be sufficient to resolve your concerns in this matter.
If you have any questions on this information, please contact me.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY
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JMM G. D. Whittier, Manager Nuclear Engineering and Licensing GDH/bjp cc: Mr. V. Nerses, Acting Project Directorate I-3 Mr. Pat Sears Mr. Cornelius F. Holden m
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