ML20151U285

Responds to NRC 880321 Ltr Re Violations Noted in Insp Rept 50-213/88-01.Corrective Actions:New Format to Clarify Data Recording Has Been Developed & Will Be Implemented Generically on All Inservice Tests

ML20151U285
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/18/1988
From:	Mroczka E, Sears C CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A07129, A7129, NUDOCS 8805020018
Download: ML20151U285 (5)

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NORTHEA'If IFFILITIES o.n.,.i ome.. . s.io.n sir i. somn. connecticui 9 '.7,NsENEs7dE'(55~

P.o. box 270

• HARTFoAD. CONNECTICUT 061410270 k k J .U.[.,D,2.".c.'. 'cC, (203) 665 5000 April 18, 1988 Docket No. 50-213 A07129 Re: 10CFR2, Appendix C Mr. Jacque P. Durr Chief, Engineering Branch Division of Reactor Safety U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Reference:

(1) J. P. Durr letter to E. J. Mroczka, transmitting Inspection No. 50-213/88-01, dated March 21, 1986.

Gentlemen:

Haddam Neck Plant Response to Inspection Report No. 88-01 Reference (1) transmitted the tesults of Inspection No. 50-213/

88-01 which was conducted on January 11-21, 1988 of the Haddam Neck Plant Inservice Test (IST) program. During that inspection, one violation of NRC regulations was identified related to a f ailure to properly record a valve opening time as required by the test procedure. Connecticut Yankee Atomic Power Company (CYAPCO) hereby provides its response to the identified violation.

Requirement ,

l Connecticut Yankee Atomic Power Company, Haddam Neck Plant, i Technical Specificatn 6.8, "Procedures", requires that written ,

procedures and admin..cracive policies shall be established, I implemented and maintained that meet the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1976 and Appendix A of USNRC Regulatory Guide 1.33.

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l Mr. Jacque P. Durr 1 i A07129/Pcgs 2 l i April 18, 1988 l l

Section 6.1.1 of Surveillance Procedure No. SUR 5.7-67, l "Inservice Inspection of Service Water Isolation Valves SW-AOV-130, SW-AOV-8 and SW-AOV-9, Revision 8", required i recording of the opening time for Service Water valve SW-AOV-129. l Violation Contrary to the above, on January 12, 1988, the opening time for i Service Water Valve SW-AOV-129 was not recorded during the-above  !

surveillance test.

I This is a Severity Level V Violation.

Root Cause

! We have determined that this violation was the result of the procedure being unclear regarding the format in which the data '

were to be recorded. The proceuure provided a box containing the acceptance criteria followed by another box in which the actual stroke time measurement was to be recorded (see Attachment 1).

Below this was another larger box in which the operator acknowl- ,

edged observation of the valve actuating to the proper position ay circling the word SAT or UNSAT. In other casen, valve stroke  ;

times (e.g., closing times) were required to be recorded as a i separate line item, thus making it very unlikely that the recording of the data would be overlooked. The small size of stroke time data box as well as a misunderstanding on the part the operator that the SAT /UNSAT box also applied to the stroke time measurement both contributed to the cause of this violation.

Corrective Action 1

CYAPCO acknowledges that during the performance of surveillance procedure SUR 5.7-67, the non-licensed plant operators responsi-ble for the conduct of the procedure failed to record the measured opening time for valve SW-AOV-129. The conduct of this <

surveillance was at the time being observed by the NRC Staff and l 3

a member of the plant engineering staff. After it was pointed l out by the NRC Staff that the required data had not been recorded, the plant operators were advised that all valve stroke time measurements were to be recorded on the procedure. The opening time for valve SW-AOV-129 as well as all subsequent stroke time measurements wera recorded as required. It should be noted that the procedure is r.ot complete until all data have been evaluated by the cognizant IST Engineer and reviewed by the Engineering Supervisor. If this error had not been identified during the performance of the procedure, it would have been '

discovered during the engineering evaluation. Missing data would have been obtained in a retest.

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Mr. Jccquo P. Dur-A07129/Paga 3 April 18, 1988 Actions to Pre _ vent Recurrence As a corrective measure to prevent future violations, 3 new format to clarify data recording has been developed and will be implemented generically on all IST and other surveillance procedures as part of the current station procedure improvement program which is scheduled to be completed by the end of 1989.

If you have any questions related to the above, please feel free to contact my staff directly.

very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY

_, i E. J. Mroczka N Senior Vice President C. F. Sears Vice President Attachment cc U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant

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Docket'No. 50-213 A0717 ,

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, s Attachment 1 Haddam Neck Plant i

Procedure SUR 5.7-67, Rev. 8 ,

u l Section 6.1.1 1

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i i i j April 1988  :

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r SUR 5.7-67

,- Rev. 8 SUR57J APR 2 21987-4.0 _ PREREQUISITES INITIALS 4.1 Check whether the test is surveillance or retest on Page 1. Include the AWO number if applicable.

4.2 EG2A not operating when testing SW-A0V-129, 4.3 EG2B not operating when testing SW-A0V-130 4.4 Baron Recovery System shutdown when testing SW-A0V-8.

4.5 Spent Fuel. Pit Heat Exchanger can be inservice or isolated when testing SW-A0V-9.

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4.6 A calibrated stopwatch is available to measure stroke time.

Stopwatch Number Calibration Due Date

• 4.7 SW-A0V-129, 130, 8 & 9 valves may be tested in accordance with this procedure.*3 4.8 Two (2) operators used to perfom test.

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5.0 PRECAUTIONS I E.

'5.1 Do not leave SW-A0V-129 and- SW-A0V-130 open any longer than necessary to perfom test. l 5.2 Notify control room personnel prior to perfoming test. '

6.0 PROCEDURE 6.1 Complete test for SW-A0Y-129 as follows:

6.1.1 Open SW-A0V-129. Measure opening tinie from placing raw water control switch on EG2A control panel in the manual position until valve is locally observed to be fully open. l Acceptance Criteria Test Results t

30 sec, to open, or less see Valve exercised to open Sat /Unsat position as indicated by local observation Page 2 of 9

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