ML20091K708
| ML20091K708 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/13/1992 |
| From: | Odell W GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RBG-36-236, NUDOCS 9201270037 | |
| Download: ML20091K708 (4) | |
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- GULF STATES UTILITIES M5tEi< BEND FTAlidN POST OrrKE BOW 2N ST FR ANMv44 f. LOUfbiA*eA 707 ?F Aftf A CODE VA fiM (O34 3M fM6L January la 1992 RBG-36,236 File Nos. G9.5, G15.4.1 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Docket No. 50-458/91-21 In response to the Nuclear Regulatory Commission's letter from Mr. A.B. Beach to Mr. J.C. Deddens dated December 24, 1991 concerning the Notice of Violation (NOV) for NRC Inspection Report 50-458/91-21, Gulf States Utilities provides additional information as discussed in a conference call on December 16, 1991. The information in the attachment to this letter is intended to supplement information provided in our original response to the NOV dated November 15,
- 1991. ' Based on the original response and this supplemental information, GSU continues to request that the notice of violation be withdrawn.
Sincerely f
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el Manager - Oversight River Bend Nuclear Station E/D kvm Attachment cc:
U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051
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St. Francisville, LA 70775 9201270037 920113 y
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'..i-l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE 07 LOUISIANA
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PARISH OF WEST FELICIANA
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Docket No. 50-458 In the Matter of
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GULF STATES UTILITIES COMPANY
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-(River Bend Station
- Unit 1)
AFFIDAVIT W. H.-Odell, bein; duly sworn, states that he is a Manager-Oversight for Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
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W. HT Ddell Subscribed and sworn to before me, a Notary Public in and for the State and Parish above
- named, this
/ 3 /C day of nM14uut tt4 1931 My Commission expires with Life.
CLLLb L :, lNitrah ClaudTa F.
Hurst Notary Public in and for West Feliciana Parish, Louisiana l
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ATTACllMENT SuppkmtDtalInformation for Notice of Violation 50-458/91-21 Reference Notice of Violation Letter from A. Bill Beach to James C. Deddens dated October 16,1991 Response to NOV Letter from J.C. Deddens to the U.S. NRC dated November 15, 1991 Request for Information Letter from A. Bill Beach to James C. Deddens dated December 24,1991 Supplemental Information GSU's initial response to the Notice of Violation (NOV) describes the events that occurred on and following August 23,1991, concerning maintenance performed on the standby gas treatment system and fuel building ventilation filter train beater control circuit. The response included a description of the operability evaluation that was performed on the fuel building ventilation system which resulted in a determination that the ventilation system was operable with the heater
- in the filter -train being' out of service.
This operability evaluation was performed and documented prior to work on the heater. A control switch was removed from the circuit during maintenance and was returned to its original configuration under the procedural control of maintenance procedures ADM-0028 " Maintenance Work Order" and GMP-0042
- Circuit Testing Lifted Leads, and Jumpers." At no time while the control switch was removed was the heater required to be operable. The heater was deemed inopetable and was not operated during this time GSU did not modify (cf. ENG-3-006) the heater control circuit during the maintenance activity. The replacement switch possessed the same fit, form and function.
l During the conference call on December 16,1991, the NRC representatives pointed out that the USAR describes the filtration ecit including the-filter heater and questioned the basis for defeating-the heater function Mthbut an approved modification request and 10CFR50.59 evaluation. The fuel building. ventilation system is described in USAR Section 9.4.2. This section gives the design bases, system description, safety evaluation, i.tspection and testing requirements, and instrumentation requirements. Section 9.4.2.2.4, charcoal filtration system, states that " Electric heating coils in the filter unit raise the temperature of air to limit the relative humidity to a maximum of 70 percent."
One purpose of the USAR is to give a description of the plant, including most systems and l
- components. When a component or system is taken out of service for maintenance the plant no longer completely' meets the USAR as the component or system cannot perform its function.
In general, the Technical Specifications give the requirements for system operability including allowable octage times. When maintenance has an effect on the safety function of a Technical Specification required system, an action statement must be entered.
However, when a I
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function, the maintenance can be performed without declaring the tt cSnical specification system inoperable. NRC Inspection Manual Part 9900: Technical Guidt.nca on Operability gives an example concerning heat tracing used for freeze protection of a safety related system. The freeze protection support function may be described in the USAR and may be needed for operability when freezing temperatures exist; however, enen not required it may be removed from service for maintenance without impact on system operability. Even though support functions may be described in the USAR, they may not always be required to fulfill the safety 1
function of the system. This is the case with the fuel building ventilation system charcoal filter heater. The support function of the heater was determined to not be required during normal operation with no fuel movement; that is, the ventilation system could perform its safety function without the heater in service. When the switch was removed from the heater contrd circuit there was no intent to change the design. The circuit was returned to its original conGguration as part of the maintenance activity. If, for example, the switch had failed, it is clear that it could have been removed and replaced with a spare part as a maintenance activity.
In this example, operability of the system would not be effected, i.e. the system would remain operable throughout the maintenance as the system safety function would not be effected. The maintenance that was performed in August,1991, wa essentially the same as the replacement of a failed switch with a spare part.
In summary, the USAR describes plant systems and components.
These systems and components are required to function when neded to meet the requirements of the Technical Specifications and. the safety analysis.
A component can be removed from service for maintenance if the component is not required to support a safety function. If the component is returned to service in its original configuration, no modification request or 10CFR50.59 is required. GSU believes that the maintenance performed in August,1991 on the fuel building filtration heater control circuit was properly controlled as a maintenance activity and that no modification request was required. The heater switch was removed from th: circuit and replaced with a spare without any impact on the safety function of the system as dercribed in the USAR.
GSU has reviewed this position with the guidance given in NRC Inspection Manual Part 9900:
Technical Guidance on Operability (specifically Section 6.12, Support System Operability) and has found them to be consistent, i
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