ML20045E462

Responds to NRC 930510 Ltr Re Violations Noted in Insp Rept 50-440/93-02 on 930113-0429.C/As:engineer Who Failed to Follow Programmatic Requirements of PAP-1116 Is No Longer Employed at Plant

ML20045E462
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 9307020135
Download: ML20045E462 (6)

Text

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'. CENTE3OR '

3) ENERGY

- PERRY NUCLEAR POWER PLANT Mail Addressi PO. BOX 97 Robert A. Stratmsn '

CE" "^ PERRY, OHIO 44081 VICE PRESIDENT NUCLEAR kgRY OHIO 081 (216) 259-3737 June 10, 1993 PY-CEI/NRR-1665 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 Gentlemen:

This letter acknowledges receipt of.the Notice of Violation contained within.'

Inspection Report 50-440/93002 dated May 10, 1993. The referenced-report identifies areas' examined by a Region III inspector'from' January.13 through '

April 29, 1993. A response to each of the items addressed .in f.he subject Notice of Violation is provided'in the attachment which follows.

Additionally, with regard to your request'concerning instrumentation required for the Containment. Integrated Leak Rate Test (CILRT); Perry vill purchase or lease the necessary hardware and software'to rectify equipment' problems which .;

occurred during the 1993 Maintenance Outage test. ..This equipment will be obtained prior to the' performance of.the CILRT scheduled for Refueling Outage 4. >

If you have any questions, please feel free to call'.- .

Sincerely h ,  ;

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/k<l7x Robert A. Stratman RAS:RVG:ss ,

Attachment ec: . NRC' Project Manager -

NRC Resident' Inspector. Office ,

NRC Region'III

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PY-CEI/NRR-1665 L

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. e Page 1 of 5 REPLY TO NOTICE OF VIOLATION 50-440/93-002-01A (NOV-A.1)

Restatement of the Violation 10 CFR Part 30, Appendix B Criterion V requires, in part, that activities H affecting quali:y 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, Vork 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 ensures a) The even comprecsion of the gasket during bolt tensioning by requiring-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 andtinside diameter groove clearance prior to valve reassembly.

Reason for the Violation The examples listed above for failure to include appropriate acceptance criteria were also identificd in an. investigation conducted'by a Perry Incident Respor,se 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.vas determined that the requirement for periodic body to bonnet flange' gap measurements included 'in Generic Mechanical Instruction (GHI)-0096, "HSIV Disassembly, Repair, and

-Reassembly Instructions" had not been incorporated into alternate instructions used during Refueling Outage (RF0) 3 for-performing torquing / tensioning of the MSIV body to bonnet flange studs. Specifically, Section 5.3.9.of GHI-0096 provides specific instructions for valve reassembly using-torque wrenches, including the requirement to periodically record gap measurements. However, the.vork orders referenced in the Restatementlof the Violationiabove utilized' a hydraulle tensioner for performing this task.- The importance of the flange

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gap measurements was not recognized at the timeithe alternate reassembly method was developed and was 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 work orders relied solely on-proper tensioning k

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PY-CEI/NRR-1665 L

, . Attachment 1 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 was 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 +

manufacturers tolorances for outside diameter (0.D.),-inside diameter (I.D.)

and thickness. A teview of the gasket manufacturer's dimensional tolerances indicated that Flexitallic's standard manut'acturing tolerance allows for 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 i 1/16 inch on both I.D. .;

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 allow; for gasket growth during compression. With tue noted manufacturing tolerance e of both the gasket and gasket. groove on the body flange face, it vas-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. ,

Gaskets.vhich had been previously utilized were nominally sized for their application and predominantly supplied by the valve manufacturer. Because the ,

additive effects of. gasket and groove tolerance were not previously identified, the associated work orders for MSIVs specified the required replacement gasket but diu not require verification of groove to gasket i clearance.

Corrective Action Taken and Results Achieved As previously addressed in the Corrective Actions for LER 93-003, which reported the HSIV 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.

i The purchase-specification for replacement gaskets was revised to ensure that  :

proper dimensions and material propettles of the gaskets are maintained. l 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.

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PY-CEI/NRR-1665 L-

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.Page 3 of 5 Date When Full Compliance Vill Be Achieved

-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-OlB (NOV A.2)

Restatemeat of the Violation 10 CFR Fart 50, Appendix B Criterion V requires, in part, that activities affecting quality be prescribed by and accomplished in accordance with, documented instructions, procedures, or dravirgs 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 Hay 1992,'vas not performed in accordance with the Work Order instructions as modified by Field Clarification Request No. 16335, in that less than two full . tensioning passes.

vere performed.

Reason for the Violation A review of the Work Orders (Vos) for MSIV reassembly during May of 1992 determined that on at least two occasions the required tensioning requirements vere 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 infthe Work Order package at the time of' closeout. 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 vere not identified by the work' supervisors or VO reviewers prior-to closecut. 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 was focused on all aspects of the.HSIV 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-

-A training package is being developed to include lessons learned from previous; MSIV repair. activities. Formal training vill be conducted for' craft, supervisory, and engineering personnel involved vith maintenance activitfes associated with the HSIVs prior'to commencement of MSIV testing in RF04.

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-Attachment 1.

Page-4 of 5-Date When Full Compliance Vill Be Achieved

= Full. compliance with the stated violation was achieved during the 1993 Maintenance Outage following successful completion of, repairs and testing associated with the HSIVs.

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 were not taken to ensure that as-found local-leak rate tests were 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 l causing the failure- ;i of 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 vas 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, asfrequired by Plant

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Administrative Procedure (PAP)-1116, "Hotor-Operated Valve Testing and.

Surveillance Program."

Additional valves / penetrations referenced in the violation did not have.

as-found LLRTs performed due'to an earlier interpretation of retest requirements. For valve 1B21-F016,'st'em lubrication was performed as'part of a preventive maintenance. activity. Generic Letter (GL):89-10 differential pressure testing was subsequent 1y' 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. '

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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 ior-obtaining as-found-LLRT data.

Corrective Actions Taken and Results Achieved

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'The RSE who failed t'o 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) were re-trained regarding work order' retest.and'reviev. requirements as'  :

.part of the-corrective action for LER 93-004. Engineering personnel involved in specifying or revieving retest requirements for containment isolation I'

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Attachment 1

.Page 5 of.5 valves have received training to address the revised interpretation of'the retest philosophy with regard to maintenance activities which would affect

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. 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 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 vill be~ evaluated-for incorporation into the Perry programs and procedures.

Date When Full Compliance Will 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.

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