ML20045A992
| ML20045A992 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/10/1993 |
| From: | Stratman R CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| PY-CEI-NRR-1665, NUDOCS 9306160043 | |
| Download: ML20045A992 (6) | |
Text
,...
B centreson ENERGY
. w PERRY NUCLEAR POWER PLANT t
Address:
Robert A. Stratman -
0 PERRY, OHIO 44081 VICE PRESIDENT. NUCLEAR E
, ohio 4 cai (216) 259-3737 l
June 10, 1993 PY-CEI/NRR-1665 L l
U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Perry Nuclear Power Plant Docket No. 50 440 Reply to Notice of Violation 1.
Gentlemen:
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/93002 dated May 10, 1993. The referenced report l
identifies areas examined by a Region III-inspector from January 13 through April 29, 1993. A response to each of the-items addressed in the subject
=i Notice of Violation is provided in the-attachment which-follows.
L Additionally, with regard to your request concerning instrumentation required I
for the Containment Integrated Leak Rate Test (CILRT); Perry vill purchase or lease the necessary hardware and softvare to rectify equipment problems which occurred during the 1993 Maintenance Outage test..This equipment vill be I
obtained prior to the performance of the CILRT scheduled for Refueling Outage 4.
If you have any questions,.please feel free to call.
Sincerely I
$7x s
Robert A. Stratman RAS RVG:ss i
Attachment cc:.NRC Project Manager NRC Resident Inspector Office NRC Region III.
Opetemg Compon.es Cleveiond Electnc inumme.ng
. f g
Toiedo la; son
.930616004
/
l WD 0 '2 M
?" ^*"3 930610BM*
6 B
V
__.-___A..-
PY-CEI/NRR-1665 L Page 1 of 5
' I REPLY TO NOTICE OF VIOLATION 50-440/93-002-01A (NOV-A.1)
Restatement of the Violation 10 CFR Part 50, Appendix B Criterion V requires, in part, that activities affecting quality be prescribed by and accomplished in accordance with, documented instructions, procedures, or drawings of a type appropriate to the i
circumstances. These instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, Work Order Nos. 910001178, 910001181, 910001193, 910001230, 910001231, and 910001233 used to modify the A, B and D main steam line containment isolation valves during the 1992 refueling outage failed to include the appropriate acceptance criteria to ensure a)
The even compression of the gasket during bolt tensioning by requiring l
the periodic recording of bonnet to valve flange gap dimensions.
b)
The proper gasket compression by requiring metal to metal contact between the bonnet and the valve body after completion of bolt tensioning.
c)
That the gaskets used met the required manufacturer's outside and inside diameter groove clearance prior to valve reassembly.
Reason for the Violation The examples listed above for failure to include appropriate acceptance criteria were also' identified in an investigation' conducted by a Perry Incident Response Team (IRT). The IRT was formed to investigate the cause of identified MSIV leakage and to determine corrective steps to prevent recurrence.
During-the IRT investigation, it was determined that the requirement for periodic body to bonnet. flange gap measurements included in Generic Mechanical Instruction (GMI)-0096,."MSIV Disassembly, Repair, and Reassembly Instructions" had-not been incorporated into alternate instructions used during Refueling Outage.(RFO) 3 for performing torquing / tensioning of the MSIV body to bonnet flange studs.
Specifically, Section 5.3.9 of GMI-0096 provides specific instructions for valve reassembly-using torque vrenches, including the requirement to periodically record gap measurements. However, the vork orders referenced in the Restatement of the Violation above utilized a hydraulic tensioner for performing this task. The importance of the flange gap measurements was not recognized at the time the alternate reassembly method was developed and'vas ultimately not included in the work orders.
The requirement for metal-to-metal contact referenced in Example b) of this violation is not included in the vendor manual for Atwood and Morrill valve-assembly and was therefore not incorporated into GMI-0096. Although not properly implemented, the 1992 vork orders relied solely on proper tensioning 4
e
.La l
k PY-CEI/NRR-1665 L-
'l Page 2 of 5
_of'the bonnet to flange bolts to ensure adequate gasket compression. The need for metal-to-metal contact on the body to bonnet flange vas not identified until recognized by a vendor representative during the 1993 Maintenance ~
Outage.
As part of the IRT investigation, inspections were performed on gaskets in the varehouse inventory. The gaskets were determined to be within the l
manufacturers tolerances for outside diameter (0.D.), inside diameter (I.D.)
)
and thickness. A review of the gasket manufacturer's dimensional tolerances indicated that Flexitallic's standard manufacturing tolerance allows fur a 3/64 inch tolerance on the I.D. and 1/16 inch tolerance on the 0.D..
Atwood and Morrill tolerance on the gasket groove width is 1/16 inch on both I.D.
i and 0.D..
The standard Flexitallic gasket practice is to allow a 1/16 inch nominal
)
diametric clearance between both the I.D. of the groove and the I.D. of the gasket, and between the 0.D. of the groove and the 0.D. of the gasket to allov for gasket grovth during compression. With the noted manufacturing tolerance
]
of both the gasket and gasket groove on the body flange face, it was
-determined that the additive effects of the tolerance margins could create a condition that would prevent proper diametric clearance between the gasket and groove on either, or both, the I.D. and 0.D..
This vould prevent uninhibited gasket growth during compression.
Gaske's which had been previously utilized vere nominally sized for their application and predominantly supplied by the valve manufacturer. Because the additive effects of gasket and groove tolerance vere not previously identified, the associated vork orders for MSIVs specified the required replacement gasket but did not require verification of-groove to gasket clearance.
Corrective Action Taken and Results Achieved As previously addressed in the Corrective' Actions for LER 93-003, which reported the MSIV Local Leak Rate Test (LLRT) failures, additional guidance for valve reassembly was developed to address the requirement for metal-to-metal contact.and proper tensioning of the flanges. This guidance was incorporated into the work instructions utilized during reassembly of valves during the 1993 Maintenance Outage. This guidance vill also be incorporated into GMI-0096.
The purchase specification for-replacement gaskets was revised to ensure that I
proper dimensions and material properties of the gaskets are maintained.
Additionally, the work instructions have been revised to require verification of groove dimensions to ensure proper gasket fit.
Actions to Avoid Further Violations No further actions are required.
l-l..
1
PY-CEI/NRR-1665 L o
Page 3 of 5 P
~
.i Date Vhen Full Compliance Vill Be Achieved l
Full compliance for,the violation was achieved on January 27, 1993, with the incorporation of the referenced guidance into the associated work instructions.
(
50-440/93002-01B (NOV A.2)
Restatement of the Violation 10 CFR Part 50, Appendix B Criterion V requires, in part, that activities affecting quality be prescribed by and accomplished in accordance with, documented instructions, procedures, or drawings of a type appropriate to the-circumstances. These instructions, procedures,'or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, the tensioning of the bonnet bolts _for the "B" inboard and outboard main steam isolation valves, performed during May 1992, was not
_per ormed in accordance with the Vork Order instructions as modified by Field f
Clarification Request No. 16335, in that less than two full tensioning passes were performed.
Reason for the Violation A review of the Vork Orders (Vos) for MSIV reassembly during May of 1992L determined that on at'least two occasions the' required tensioning requirements were not sufficiently documented to indicate compliance with the VO instructions. In one instance,'the Torque Data Sheet for the final tensioning of the body to bonnet flange was not included in the Work Order package at the time of closecut. This vas-determined to result-from a' lack of attention to-detail on the part of the craft personnel when performing the prescribed task.
These errors were not identified by the work supervisors or VO reviewers. prior to closeout. The VO instructions are considered to be clear and concise with regard to the intended actions to be performed.
Corrective Actions Taken and Results Achieved During the 1993 Maintenance Outage, increased management attention vas. focused on all aspects of the MSIV' troubleshooting, disassembly, repair, and reassembly activities. No problems involving adherence to work instructions or procedures were identified relative to MSIV activities, with the exception of_an event involving the misapplication of measuring and test equipment during troubleshooting prior to valve disassembly. This event did not significantly impact the troubleshooting efforts.
Action to Avoid Further Violations I
A' training package is being developed to include lessons learned from previous.
MSIV repair activities.
Formal training vill be conducted for craft, l
supervisory, and engineering personnel involved with maintenance activities associated with the MSIVs prior to commencement of MSIV testing in RF04.
I' PY-CEI/RRR-1665 L Page 4 of 5
+
Date Vhen Full Compliance Vill Be Achieved Full compliance with the stated violation was achieved during the 1993 i
Maintenance Outage following successful completion of repairs and testing associated with the MSIVs.
50-440/93-002-02 (NOV-B)
Restatement of the Violation 10 CFR Part 50, Appendix B, Criterion XIV requires, in part, that measures be established to indicate by the use of markings such as stamps, tags, labels, or other suitable means, the status of inspections and tests performed upon individual items of the nuclear power plant to preclude inadvertent bypassing-of such inspections and tests.
Contrary to the above, during the maintenance outage of January through February 1993, measures vere not taken to ensure that as-found local leak rate tests vere performed on containment isolation valves for the main steam line drain, and for the dryvell and containment floor drain sump pump discharge to -
radvaste penetrations prior to the performance of maintenance. As a result, the improvements in leakage rate could not be determined causing the failure uf the containment integrated leak rate test as-found condition.
Reason for the Violation The failure to include appropriate retest requirements associated with the-Main Steam Line (MSL) drain valve was reported in Licensee Event. Report 93-004. This event was attributed to failure to follow procedures on the part of a Responsible System Engineer (RSE) who-failed to contact the-Component-Performance Group for. appropriate retest requirements, as required by Plant Administrative Procedure (PAP)-1116, " Motor Operated Valve Testing and Surveillance Program."
Additional valves / penetrations referenced in the v'iolation'did not have as-found LLRTs performed due to an earlier interpretation of retest requirements.
For valve.1B21-F016, stem lubrication was performed as'part of a preventive maintenance activity. Generic Letter (GL) 89-10 differential pressure testing was subsequently performed on the valve. GL 89-10 testing provides data which illustrates the effect on valve thrust capabilities resulting from stem lubrication;-therefore, any change in thrust must be assumed to affect the seating characteristic of containment isolation valves.
Stem lubrications had.not previously been considered to be repairs or adjustments with regard to the need to perform as-found LLRTs, and the work packages did not include requirements for obtaining as-found LLRT data.
Corrective Actions Taken and Results Achieved
{
The RSE vho failed to follow the programmatic requirements'of PAP-1116 to obtain as-found LLRT data for the Main Steam Line drain valve is no longer employed at the Perry site. Additionally, RSEs and Shift Technical Advisors (STAS) vere re-trained regarding vork order retest and. review requirements as part of the corrective action for LER 93-004. Engineering. personnel involved
~in specifying or reviewing retest requirements for containment isolation-b i
m.
~
t PY-CEX/NRR-1665-L
^
Page 5 of SL A
valves have received training to address the revised' interpretation of the retest philosophy with regard to maintenance activities which would affect l
valve seating characteristics. ' Procedure changes are in progress to incorporate additional guidance for as-found LLRT' requirements.
Actions to Avoid Further Violations As an enhancement to the corrective actions described above, an independent; l
evaluation of the Perry LLRT/ILRT program vill be performed by an outside organization to review the various facets of the programs and make appropriate recommendations for improvements._ Included in this activity vill'be a review of LLRT program requirements regarding the specification of retests, and the-need'for obtaining as-found LLRT data. The recommendations will be evaluated for incorporation into the Perry programs and procedures.
Date When Full Compliance Vill Be Achieved Full compliance with the Appendix B criteria cited vill be achieved by August 15, 1993 upon incorporation of the additional guidance regarding as-found LLRTs into the applicable plant procedures.
l I
l t
I
,