ML20135C356
| ML20135C356 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/24/1997 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-97043, NUDOCS 9703030517 | |
| Download: ML20135C356 (3) | |
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Log # TXX 97043 L
Z File # 10130 r
IR 96 12 Ref. # 10CFR2.201 filELECTRIC' February 24, 1997 C. lance Terry
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Gnep Mce Prendent U. S. Nuclear Regulatory Commission i
Attn:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 and 50 446 i
NRC INSPECTION REPORT NOS. 50 445/96 12 and 50 446/96 12 REPLY TO NOTICE OF VIOLATION REF:
- 2) NRC letter from Samuel J. Collins to C. L. Terry, received January 24, 1997 TU Electric has reviewed the NRC's letter dated November 27, 1996, concerning the inspections conducted by A. Gody, Jr., V. L. Ordaz.
H. A. Freeman, and W. J. Wagner on September 29 through November 9, 1996. Attached to the report was a Notice of Violation.
The Notice of Violation described a procedure inadequacy which resulted in a failure to meet ASME/ ANSI Code requirements for relief valve testing."
TU Electric's initial reply to the Notice of Violation was provided by Reference 1.
The NRC responded to TU Electric's reply via Reference 2.
TU Electric's response to Reference 2 is attached.
Should you have any comments or require additional information, please do not hesitate to contact Carl Corbin at (817) 897 0121.
Sincerely, 9703030517 970224 PDR ADOCK 05000445 8
G PDR C. L. T rr CBC:cic 030078 k
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Attachment J. I. Tapia, Region IV
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c-J. E. Dyer, Region IV T. J. Polich, NRR G. Bynog TDLR
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J. C. Hair ANII Resident Inspector, CPSES P. O. Box 1002 Glen Rose Texas 76043
"i Attachment to TXX-97043 Page 1 of 2 RESTATEMENT OF THE VIOLATION (445/9612-03)
Technical Specification 4.0.5 requires that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a.
Section XI, Subsection IWV, " Inservice Testing of Valves in Nuclear Power Plants," requires that valve testing be performed in accordance with the requirements stated in ASME/ ANSI OM, Part 1
10, Paragraph 4.3.1 of Part 10 states, in part, that safety and relief valves shall meet the inservice test requirements of Part 1.
ASME/ ANSI OM, Part 1 Paragraph 7,3, " Periodic Testing," states, in part, that no maintenance, adjustment, disassembly, or other activity which cco:d affect "as found" set pressure or seat tightness data is permitted prior to testing.
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Contrary to the above, a procedure change dated September 30, 1996, to Procedure MSM-G0-0204, Revision 4, required that valves be cycled to remove entrapped air, an activity that could affect the "as found" set pressure.
Four Unit I relief valves were cycled to remove entrapped air, prior to "as found" testing, using licensee Procedure MSM-G0-0204 during the Unit I refueling outage as follows:
(1) the containment sump to Containment Spray Pump 1-02/1-04 suction j
isolation valve bonnet relief valve on October 9,1996 j
(2) the containment ventilation chilled water return header outside containment relief valve on October 16, 1996 (3) the demineralized water / reactor makeup water outside containment building relief valve on October 17, 1996
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(4) the reactor makeup water to Pressurizer Relief Tank 1-01 outside i
containment building relief valve on October 18, 1996 l
This is a Severity Level IV violation (Supplement I) (50-445/9612-03).
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Attachment to TXX 97043 j
Page 2 of 2 l
REPLY TO THE VIOLATIDH (445/9612 03)
TU. Electric accepts the violation. The information requested is provided as follows:
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Reason for the Violation To meet the Code requirements for testing sequence and testing on system operating fluid, TV Electric believes that it is necessary to remove entrapped air from the area under the relief valve disc.
Since the valve test bench did not have the capability to vent entrapped air, TU Electric determined that an appropriate method of performing this venting operation was to slowly and evenly lift the l
valve disc. TV Electric's initial reply to this Notice of Violatic7 l
(TXX-96520 dated December 20, 1996) discusses this in further j
detail..
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2.
Corrective Steps Taken and Results Achieved I
The ASME Code safety and relief valves which used the " valve disc lift method" (as allowed by the change to procedure MSM-G0-0204, l-dated September 30, 1996) to remove the entrapped air prior to testing the "as-found" set pressure were verified to be at the correct set pressure prior to placing the valves back in service.
4 The as-left set pressure was within the required tolerance, f
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Corrective' Steps Taken to Avoid Further Violation l
TV Electric is in the process of modifying the equipment used to test the ASME Code safety and relief valves to allow the removal of entrapped air by a method which does not require lifting the valve j
disc prior to performing the as-found set pressure test. This will l
1 eliminate the need to remove the entrapped air by the valve disc lift
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method.
The test procedure will be revised to delete the valve disc lift
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method of removing entrapped air for ASME Code safety and relief i
j valves.
a To prevent recurrence. TU Electric will complete the test bench modification and the test procedure change prior to testing of ASME Code safety and relief valves in accordance with the Inservice i
Testing (IST) Plan.
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Date of Full Compliance TU Electric's method of testing ASME Code safety and relief valves will be in full compliance prior to reinstating testing of the ASME Code safety and relief valves in accordance with the IST Plan, no later than the start of the third refueling outage for Unit 2.
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