ML070220503
| ML070220503 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/22/2007 |
| From: | Howell A NRC/RGN-IV/DRP |
| To: | Parrish J Energy Northwest |
| References | |
| EA-04-101, IR-03-007 | |
| Download: ML070220503 (5) | |
See also: IR 05000397/2003007
Text
January 22, 2007
J. V. Parrish (Mail Drop 1023)
Chief Executive Officer
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
SUBJECT:
RESPONSE TO NONCITED VIOLATION IN NRC INSPECTION
REPORT 05000397/2003007
Dear Mr. Parrish:
In your letter of April 16, 2004, Energy Northwest (ENW) contested a Green NRC-identified
noncited violation (NCV) concerning the conduct of local leak rate testing (LLRT) of the main
steam isolation valves (MSIVs) at Columbia Generating Station (CGS). This NCV (50-397/03-
07-01) was documented in NRC Inspection Report 0500397/2003007. You requested that this
NCV be withdrawn and provided a summary of the actions that ENW was pursuing concerning
this issue. On August 16, 2004, the NRC responded to your letter by acknowledging your basis
for disputing the noncited violation, and informing you that the NRC was evaluating the basis for
your request for withdrawal of this NCV, including reviewing the generic aspects of this issue.
This NCV pertained to a violation of Technical Specification Surveillance Requirement 3.6.1.11.
Specifically, ENW had performed inadequate MSIV local leak rate testing by utilizing nonsafety-
related instrument air to assist in closing and seating the valves during testing. In your
response, ENW disagreed with the NCV. Your letter noted that: 10 CFR Part 50, Appendix J,
Section III.C.1, states that each valve to be tested shall be closed by normal operation and
without any preliminary exercising or adjustments. Also, ANSI/ANS 56.8 - 1994, Section 3.3.3,
states that closure of primary containment isolation valves for Type C testing shall be
accomplished by normal or equivalent means and without adjustment. ENW considered
closure of the MSIVs with the nonsafety-related air sources to be the normal means of closing
The NRC has evaluated your position. This evaluation included a review of the rule language,
the applicable statements of consideration, the CGS Final Safety Analysis Report (FSAR), the
technical and safety basis of the test methodology in question, as well as, the generic
implications of this issue. On the basis of this review, the NRC staff has concluded that the
normal method for closing the MSIVs during normal operations is with springs only (slow
closure, no instrument air or accumulator air). The FSAR states in Section 5.4.5.4, Inspection
Energy Northwest
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and Testing, that all MSIVs are closed utilizing both spring force and air pressure on the
operating cylinder. The term normal or equivalent means can reasonably be interpreted to
include the non-safety air supply. Accordingly, we are withdrawing this violation.
While this contested NCV was being reviewed by the NRC staff, we understand that CGS has
been testing the MSIVs in a manner that ensured the valves would fully close using spring force
and safety related air pressure for the purposes of local leak rate testing. This has provided
satisfactory leak rate test results and an added measure of assurance that the valves would
operate correctly under conditions where non-safety related air was not available. Given the
efficacy of this testing methodology, we are interested in understanding your future plans for
testing the MSIVs.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be
made available electronically for public inspection in the NRC Public Document Room or from
the Publicly Available Records (PARS) component of NRC's document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
Should you have any questions concerning this matter, please contact Mr. Claude Johnson at
817-860-8148.
Sincerely,
/RA/
Arthur T. Howell III, Director
Division of Reactor Projects
Docket: 50-397
License: NPF-21
cc:
W. Scott Oxenford (Mail Drop PE04)
Vice President, Technical Services
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
Albert E. Mouncer (Mail Drop PE01)
Vice President, Corporate Services/
General Counsel/CFO
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
Energy Northwest
- 3 -
Chairman
Energy Facility Site Evaluation Council
P.O. Box 43172
Olympia, WA 98504-3172
Douglas W. Coleman (Mail Drop PE20)
Manager, Regulatory Programs
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
Gregory V. Cullen (Mail Drop PE20)
Supervisor, Licensing
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
Chairman
Benton County Board of Commissioners
P.O. Box 190
Prosser, WA 99350-0190
Dale K. Atkinson (Mail Drop PE08)
Vice President, Nuclear Generation
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
Cheryl M. Whitcomb (Mail Drop PE03)
Vice President, Organizational
Performance & Staffing/CKO
Energy Northwest
P.O. Box 968
Richland, WA 99352-0968
William A. Horin, Esq.
Winston & Strawn
1700 K Street, NW
Washington, DC 20006-3817
Matt Steuerwalt
Executive Policy Division
Office of the Governor
P.O. Box 43113
Olympia, WA 98504-3113
Energy Northwest
- 4 -
Lynn Albin, Radiation Physicist
Washington State Department of Health
P.O. Box 7827
Olympia, WA 98504-7827
Assistant Director
Nuclear Safety and Energy Siting Division
Oregon Department of Energy
625 Marion Street NE
Salem, OR 97301-3742
Energy Northwest
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Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
DRS Deputy Director (RJC1)
Senior Resident Inspector (ZKD)
Branch Chief, DRP/A (CEJ1)
Senior Project Engineer, DRP/E (TRF)
Team Leader, DRP/TSS (MAS3)
RITS Coordinator (MSH3)
R. REPLOGLE (GDR)
D. Cullison, OEDO RIV Coordinator (DGC)
ROPreports
Columbia Site Secretary (LEF1)
K. S. Fuller, RC/ACES (KSF)
C. A. Carpenter, D:OE (CAC)
OE:EA File (RidsOeMailCenter)
SUNSI Review Completed: _CEJ___
ADAMS: / Yes
G No Initials: __CEJ__
/ Publicly Available G Non-Publicly Available G Sensitive
/ Non-Sensitive
R:\\_REACTORS\\_COL\\2006\\COL2003-07RP Response to NCV.wpd
RIV:SPE:DRP/A
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EF:ACES
D:DRS
TRFarnholtz
ZKDunham
CEJohnson
MSHaire
DDChamberlain
/RA/
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RJCaniano for
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OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax