ML20246N625: Difference between revisions

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#REDIRECT [[B13351, Provides Clarifications of Util & NRC 890525 Insp Rept 50-213/89-200.Util Proposes to Extend Schedule for Completion of Sampling and Evaluation Program to 900930 & Valves That Fail Systematic Testing Will Be Replaced]]
| number = ML20246N625
| issue date = 08/28/1989
| title = Provides Clarifications of Util & NRC 890525 Insp Rept 50-213/89-200.Util Proposes to Extend Schedule for Completion of Sampling and Evaluation Program to 900930 & Valves That Fail Systematic Testing Will Be Replaced
| author name = Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO.
| addressee name = Bettenhausen L
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| docket = 05000213
| license number =
| contact person =
| document report number = B13351, NUDOCS 8909080169
| title reference date = 03-30-1989
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}
 
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August 28, 1989 Docket No. 50-213 E13351 Re: Region-Based Inspection U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Attention:      L. H. Bettenhausen Gentlemen:
Haddam Neck Plant Additional Information for inspection No. 50-213/89-200 During the week of February 6-10, 1989, the NRC Staff conducted a site inspec-tion at the Haddam Neck Plant (Inspection No. 50-213/89-200) to review vendor interface and                                                            In a {{letter dated|date=March 30, 1989|text=letter dated March 30,1989}},grgcurement-related programs at the site. Connecticut Yankee Atomic the NRC Staff with additional informaggn as a follow-up to the site inspec-tion. In a {{letter dated|date=May 25, 1989|text=letter dated May 25, 1989}},          the NRC Staff documented the results of the February inspection. The purpose of this letter is to provide the NRC Staff with some clarifications of CYAPC0's {{letter dated|date=March 30, 1989|text=March 30, 1989, letter}} and the NRC Staff's May 25, 1989, inspection report.
Dedication of Commercial Grade Items In the {{letter dated|date=March 30, 1989|text=March 30, 1989, letter}}, CYAPC0 committed to performing a random sam-pling evaluation of purchase orders for commercial grade items installed in safety-related systems between January 1, 1985 and May 31, 1988. As described in the {{letter dated|date=March 30, 1989|text=March 30, 1989, letter}}, the sample size would be approximately 125 pur-chase orders. CYAPC0 committed to complete the sampling program approximately 60 days after the 1989 refueling outage.
(1)  E. J. Mroczka letter to the U.S. Nuclear Regulatory Commission, "Haddam Neck Plant, Additional Information," dated March 30, 1989.
(2)  S. A. Varga letter to E. J. Mroczka, " Inspection of the Vendor Interface and Procurement Programs at the Haddam Neck Plant (Inspection Report No. 50-213/89-200)," dated May 25, 1989.
8909080169 890828 PDR ADOCK 05000213 Q                        FDC h
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L L              U.S. Nuclear Regulatory Commission B13351/Page 2 August 28, 1989 When the sampling program began, the first items ' that were evaluated under Administrative Control Procedure (ACP) 1.2-4.2, " Commercial Grade Evaluation /
Upgrade and Dedication," were purchase orders identified as concerns during the NRC Staff's February 1989 inspection. An average of 20-25 man-hours per commercial grade evaluation were required to perform the technical review.
When the actual random sampling of 125 commercial grade items began, CYAPC0' found that the -research time required to accurately identify a commercial grade item that qualifies for the sampling plan plus the time for the subse-quent technical evaluation per ACP 1.2-4.2 was a total on .the average of 30 hours 'per evaluation. - CYAPC0 has now projected, based on work already performed, that the total sampling and evaluation program will require approx-imately 3000 man-hours. ' This is substantially more time than CYAPC0 antici-pated when this was discussed during the inspection or when the schedule commitment was made in the {{letter dated|date=March 30, 1989|text=March 30, 1989, letter}}. The increase in the amount of time can be attributed to the fact that a large portion of the documenta-tion necessary to perform the initial evaluations had already been assembled to support the inspection.
Accordingly, CYAPC0 hereby proposes to extend the schedule for completion of the sampling and evaluation program to September 30, 1990. This represents an approximate 9-month extension on the schedule as proposed in the {{letter dated|date=March 30, 1989|text=March 30, 1989, letter}} (based on the current schedule for completion of the refueling outage by early November 1989). CYAPC0 has concluded that this revised schedule is prudent to ensure a thorough review based on the total effort that is now recognized to be required.
Westinghouse Technical Bulletin NSP-TB-83-02 In the March 30,  1989, letter, CYAPC0 committed to revising procedures PMP 9.5-23, " Preventive Maintenance of Reactor Trip and Isolation Breakers,"
and PMP 9.5-40, " Functional Test of Reactor Trip Breakers," by July 1,1989, to incorporate a recommendation made by Westinghouse to functionally verify the UVTA four tines prior to returning a reactor trip breaker to service.
CYAPC0 subsequently determined that it was only necessary to revise one of the procedures, PMP 9.5-40, in order to implement this recommendation. This procedure was revised by July 1,1989; therefore, CYAPCO regards this commit-ment as resolved.
NRC Staff Inspection Report On page 29 of the Staff's May 25, 1989, inspection report, with reference to the reactor vessel head vent valves, the Staff stated:        "The licensee has since replaced the most susceptible valves and will replace other valves during the next outage."
CYAPC0 wishes to provide a clarification on this statement.          Replacement
            - valves have been purchased and received on-site that have springs of a new material (i.e., elgiloy).      However, contrary to the statement in the
 
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U.S. Nuclear Regulatory Commission B13351/Page 3
                  ' August 28, 1989 l
inspection. report, CYAPC0 is not necessarily going to perform a complete
          ,          replacement during this outage. An engineering evaluation has demonstrated
,                    that an acceptable valve test during the refueling outage provides sufficient l                    assurcnce.for another operating cycle. Therefore, CYAPC0 will only be replac-l                    ing those valves that fail the systematic testing. CYAPC0 is taking this approach due to concerns over personnel radiation exposure (ALARA) and other resource limitations (i.e., manpower, etc.). Replacement valves are available to replace all valves that will be tested.      However, CYAPC0 does not uant to perform unnecessary replacements, and we have concluded that if the valve test is acceptable during the outage, no replacement is necessary.
We remain . available . to discuss any of the above matters with you.                Please contact us if you have any questions.
Very truly yours.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
                                                                                    -N E. 3rftp6czka      v Senior Nice President cc:  W. T. Russell, Region 1 Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident' Inspector, Haddam Neck Plant
                                                                                                                      ;}}

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