ML20126H290
| ML20126H290 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/29/1992 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Graham P GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 9301050134 | |
| Download: ML20126H290 (4) | |
See also: IR 05000458/1992026
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NUCLEAR REGULATORY COMMISSION
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REQloN IV
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611 RYAN PLAZA DRIVE.SulTE 400
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AR LINGTON. T E XAS 76011-8364
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L)tf 2 91992
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' Docket No. 50-458
License No. NPF-47
Gulf States Utilities
ATTN:
P. D. Graham
Vice President (RBNG)
P.O. Box 220
St. Francisville, Louisian) 70775
Gentlemen:
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SUBJECT:
NRC INSPECTION PEPORT 50-458/92-26 (NOTICE OF VIOLATION)
Thank you for your letter of October 12, 1992, in response to our letter and
the attached Notice of Violntion dated September 10, 1992.
As a result of our
review, we find that additional information, as discussed with your.Mr. David-
Lorfing (during-a telephone call on December 15, 1992) is needed.
Specifically, please supplement your response to the first violation in the
Notice of Violation to include the results of your review and the corrective
actions taken, or planned, to address how' vendor nanuals are updated after
design changes.
Also, the wording-in your response to the second violation
regaroing acceptance of the violation, and then asserting compliance, was
apparently conflicting.
Please clarify this response.
Please provide the supplemental information within-30 days of the date of this
letter.
Sincerely,
M. Bill Paach, Director
Division of Reactor' Projects
cc:
Gul f States- Utilities
ATTN:
J. E. Booker, Manager-
Nuclear Industry Relations
P.O. Box 2951
Beaumont, Texas 77704-
Winston & Strawn
ATTN: Mark J Wetterhahn, Esq.
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1401 L Street', N.W.
Washington, D.C.
20005-3502
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9301050134 921229
ADOCK 05000458
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idulf States Utilitie's
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- Gulf States Utilities .
ATTN:
Les England, Director
Nuclear Licensing-
P.O. Box 220:
St.-Francisville, Louisiana 7077,
Mr. J. David McNeill, III.
William G. Davis, Esq.
Departinent of; Justice
Attorney General's Office
P.O. Box 94095
Baton Rouge, Louisiana 70804-9095
H. Anne Plettinger .
,
3456 Villa Rose Drive
Baton Rouge,-Louisiana 70806
President of West Feliciana
Police Jury
P.O. Box 1921
-St.-
Francisville, Louisiana 70775
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Cajun Electric Power Coop. Inc.
ATTN:
Philip G. Harris
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10719 Airline Highway
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P.O. Box 15540
Baton. Rouge, Louisiana 70895
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Hall Bohlinger, Administrator
Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana- 70884-2135
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Gulf States Utilities
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DEC 2 91992 -
bec_tolDMB(IE01)-
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bec distrib. by RIV:
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Hilhoan
Resident inspector
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Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503
MIS System
DRSS-FIPS
RSTS Operator
RIV File
Section Chief (DRP/TSS)
Senior Resident Inspector, Cooper
PRS
Senior Resident Inspector, Fort Calhoun
J. Lieberman, 0E, MS: 7-H-5
G. F. Sanborn, EO
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Gulf States Utilitias
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DEC 2 91992
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bcc to DMB (IE01)
bec distrib by RIV:
J. L, Milhoan
Resident inspector
Section Chief (DRP/C)
Lisa Shea, RM.'ALF, MS: MNBB 4503
MIS System
DRSS-FIPS
RSTS Optrator
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RIV File
Section Chief (DRP/TSS)
Senior Resident Inspector, Cooper
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Senior Resident Inspector, Fort Calhoun
J. Lieberman. OE. MS: 7-H-5
G. F. Sanborn, EO
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GULF STA TES
UTILITIES
COMPANY
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October 12, 1992
RBG-_37573
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File Nos. G9.5, G15.4.1
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555
Gentlemen:
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River Bend Station - Unit 1
Docket No. 50-458/92-26
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Pursuant to -10CFR2.201, this letter provides Gulf States Utilities Company's (GSU)
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reply to the Notice of Violation for NRC Inspection Report No. 50-458/92 26. The
inspection was conducted by Messrs. E. J. Ford and D. P. Loveless on July 5 through
August 15,1992, of activities authorized by NRC Operating License NPF-47 for River
Bend Station (RBS) - Unit 1.
Should you have any que:tions, please contact Mr. L.A.- England of my staff at (504)
381-4145.
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Sincerely,
,
. H. Odell
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Manager Oversight
River Bend Nuclear Group
LAE/PDG/FRC/
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U.S. Nuclear Regulatory Commission
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611 Ryan Picza Drive, Suite 400
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Arlington, TX 76011.
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NRC Resident inspector
P.O. Box 1051 -
St. Francisville, LA 70775
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A'ITACIIMENT 1
REPLY TO NOTICE OF VIOLATION 50458/9226-02
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LEVEL IV
REEERFECE
Notice of Violation - Letter from A. B. Beach to J. .. Deddens, dated September 10, 1992.
VIOLATION
Technical Specification 6.8.1 requires that " Written procedures shah t>e established, implemented, and
maintained covering... the applicable procedures recommended in Appendix A of Regulatory Guide 1,33,
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Revision 2, February 1978."
Regulatory Guide L33, Appendix A, states that " maintenance that can affect the performance of safety-
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related equipment should be properly preplanned and performed in accordance with written procedures,
documented instructions, or drawings appropriate to the circumstances."
Contrary to the above, on July 29, 1992, maintenance was performed that affected safety-related
equipment, without documented instructions, in that mechanics replaced the soft seat rings on the safety
relief valve accumulator check valves without a procedure governing the torquing of the seat rings'
retaining nut. The failure to properly install the seat rings could affect valve operability.
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REASON FOR TIIE VIOLNrlON
The valve manufacturer (Velan Valve Corporation) provided inadequate instructions governing soft seat
protrusion or holding nut torque. The instructions provided were adequate for the original hard seat type
valves. However, modification request (MR) 35 1072 was implemented in the first refueling outage RF-1
in 1987 replacing the hard seat valves for ones with soft seats. Additional instructions were not provided
by the vendor with the replacement valves.
Even without adequate assembly instructions for the maintenance work in progress, proper valve
operability would have been demonstrated by post-maintenance operability testing re-quired by the job
plan. Based on required post-maintenance testing, operability would have been demonstrated prior to
return to service.
CORREC_TlYE STEPS WIIICIIIIAVE REEN TAKEN AND TIIE RESULTS ACIIIEVED
Velan Valve Corporation was contacted August 5,1992, for specific instructions governing soft seat
installation. This information was immediately supplied via telecon and incorporated into the maintenance
work orders and the 5 year equipment qualification (EQ) preventative maintenance tasks. The valves
were then reworked to the updated information and each pr<ed its leak rate test.
CORRECTIVE STEPS WIIICII WILL BE TAKEN TO AVOID FURTIIER FINDINGS
On September 1,1992 addended instructions to Velan manual VEL-SFVM-92 were received to be
incorporated into GSU's vendor traud 3228.217-060-004. The previously received telecopy and the
supplement are expected to be incoip. ated via a manual revision prior to January 1,1993.
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Also as stated on page 10 of the inspectors report, procedure CMP 9173 " Check Valve Rework" did not
supply adequate detail for soft seat check valves. The procedure will be revised to incorporate a section
for soft seated check valves reworked under the above listed manual.
- DATE %TIEN FULL COMPLIANCE WILL BE ACl[lEVED
A)
The vendor manual will be addended prior to January 1,1993.
B)
Procedure CMP-9173 will be revised prior to May 1,1993.
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A'ITACI! MENT 2
REPLY TO NOTICE OF VIDIATION 50-458/9226-03
LEVEL IV
REFERENCE
Notice of Violation - Letter from A. B. Beach to J. C. Deddens, dated September 10,1992.
YIOLATION
Technical Specification 4.0.5.a requires, in part, that inservice testing of ash 1E valves be performed in
accordance with section XI of the AShiC Boiler and Pressure Vessel Code.
Paragraph IWV-3522(a) of Section XI of the ash 1E Code states that " Valves that are normally open
during plant operation and whose function is to prevent reversed flow shall be tested in a manner that
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proves that the disk travels to the seat promptly on cessation or reversal of flow."
Contrary to the above, the licensee's testing of the safety relief valve accumulator check valves did not
verify that the disk traveled to the seat promptly in that the licensee tested for seat leakage after
disassembly and reassembly of the check valves, but prior to cycling the valve open; therefore,
verification of disk travel to the seat was not performed.
BEASON FOR TIIE VIOLATION
GSU has evaluated and accepts this violation. However, we disagree with NRC Region IV interpretation
of ash 1E XI, IWV-3522(a). Further corresp andence to the NRC on this issue will be pursued at a later
date. The following is the basis for this disagreement of interpretation and should be considered the root
cause.
in April, _1989, the NRC issued Generic Letter 89-04, titled " Guidance on Developing Acceptable
Inservice Testing Propams." This document states that, " AShtE Code Class 1,2, and 3 pumps and
valves should be viewed as one part of a broad effon to ensure operational readiness of equipment rather
than viewed in a narrow sense as compliance with 10CFR50.55a(g)." This document goes on to direct
specific action to be taken by utilities to positions on in-service testing requirements that the NRC staff
considers acceptable.
Attachment I of the Generic Letter addresses three positions on check valve testing: full flow testin;;
alternatives to full flow testing; and back flow testing of check valves. These positions describe the
required parameters, acceptable alternatives, and information necessary for generating relief requests for
check valve teving.
GSU's valve Relief Request No. 9 was written specifically for the safety relief valve / automatic
depressuization system air (SRV/ ADS) accumulator check valve testing at RBS which specified the
alternate testing as performance of a leak test every refueling outage. This relief request was approved
by the NRC in a safety evaluatica report dated July 16, 1992. The Generic Letter and the approved
Relief Request both indicate that the leak test is acceptable for the verification of the closed position.
The key difference is with the NRC's interpretation of the method of demonstrating that the valve disk
travels promptly to its seat upon cessation or reversal of flow. GSU has maintained that cessation of flow
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is "a.f flow and that manual manipulation of valve disk prior to Dowing air through the valve is adequate
exercise of the disk after maintenance. Also, performance of a leak test after reassembly would detect
disk misplacement.
CORRECTIVE STElfS.E]ILCJI IIAVE IIEEN TAKEN AND TIIE RESULTS ACIIIF,VED
As a result of the NRC inspection, Surveillance Test Procedure, STP-202-3603 " ADS /SRV
Accumulator / Check Valve Leak Rate Valve Operability Test", was revised to add steps to perform check
valve cycling prior to the leak test being performed after maintenance. This is a procedural enhancement
to ensure the valve is leak tight and will perform when it is called upon to supply and maintain air in the
accumulator tanks. Previous versions of the procedure did not speci0cally address post-maintenance
testing with the NRC viewpoint. Subsequent testing prior to unit startup retested all 16 ADS /SRV check
valves to the enhanced test procedure.
GSU will schedule the "as-found" testing prior to any work being performed on the boundary being tested
for the ADS /SRV check valves.
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CORRECTIVE STEPS WII1CII WILI,11E TAKEN TO AVOID FURTIIER 11NDINGS
Although GSU is con 0 dent that we have been in compliance with Tech. Spec. 4.0.5, ASME Section XI
1980 W 81, Generic Letter 89-04, and approved Relief Request No. 9 for this specific check valve
testing, subsequent changes to STP-202-3603 further enhance Rivw Bend's conservative approach. Now,
post-maintenance testing as well as "as-found" testbg h providcd to ensure testing of these valves in a
conservative manner, regardless of maintenance performed.
DATE WilEN FULL COMPLIANCE WILL llE ACIIIEVED
All corrective action items have been completed,
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UNTTEL STATES OF AMERICA
NUCLELR REGULATORY COMMISSION
STATE OF LOUIBIANA
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PARISH OF WEST FELICIANA
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Docket No. 50-458
In ths Matter of
)
GULF STATES UTILITIES COMPANY
)
(River Dend Station
- Unit 1)
.
W.
H.
Odell, being 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 flie 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.
Le
t.
W.
H.
Odell
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Subscribed and sworn to before me, a Notary Publ gi in and for
this
/2
day
of
the
S ate
and
Paris
above
named,
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My Commission expires with Life.
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11/J MUL
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Claudia F. Hufst
Notary Public in and for
West Feliciana Parish, Louisiana
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