NLS8500328, Responds to NRC Re Violations Noted in Insp Rept 50-298/85-27.Corrective Actions:Drain Valve to RHR-V-181 Loop a Injection Line Will Be Replaced When Plant Conditions Permit
| ML20136D306 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/30/1985 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Martin L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20136D241 | List: |
| References | |
| NLS8500328, NUDOCS 8601060120 | |
| Download: ML20136D306 (3) | |
Text
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GENERAL OFFICE Nebraska Public Power District
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l NLS8500328 November 30, 1985
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Mr. L. E. Martin, Acting Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission am
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611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
NPPD Response to IE Inspection Report 50-298/85-27
Dear Mr. Martin:
This letter is written in response to your letter dated November 1, 1985, which forwarded Inspection Report 50-298/85-27.
Therein you indicated that one of our activities was in violation of NRC requirements.
Following is a statement of the violation and our response in accordance with 10CFR2.201:
Statement of Violation Criterion X VI, " Corrective Action", of Appendix B to 10 CFR Part 50 requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
It further requires that in the case ' of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
This requirement is also part of the licensee's approved operations quality assurance program.
The " Policy Document" (Revision 2, ' August 23, 1985) for this QA program, Section 2.16, states that the objective of the corrective action, for conditions adverse to quality, will not only be to correct the existing defect or deficiency, but also to include measures to determine cause and prevent repetition of similar failures elsewhere in the station.
Contrary to the above, the licensee failed to take adequate corrective action for deficiencies involving safety-related equipment as shown by the following examples:
(1) Failure to initiate action to replace a leaking drain shut off valve on RHR Loop A injection line.
Failure to correct an incomplete valve line up procedure for the RIIR system.
(MWR 85-1887,1985)
(2) Failure to determine why the drywell spray outboard throttle valve limit switch actuating pin fell out (which resulted in the burnup of the valve motor when shutting) al.d whether similar plant valves had this problem also.
Failure to evaluate the valve for possible damage to its seat.
(MWR 85-1461,1985)
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Mr..L. E. Martin
- Page 2 November 30, 1985 This is a Severity Level IV violation (Supplement I. D.) (50-298/8527-01)
Reason for the Violation -
The reason for the examples of the violation are as follows:
(1) The example cited in MWR 85-1887 was caused by premature closure of the MWR before the corrective maintenance activity specified for the valve was completed.
Since the valve in question is a normally closed drain valve, the personnel involved determined that replacing the drain line cap downstream of the valve corrected the valve leak.
Proceeding on that basis, the line was capped and the MWR was erroneously closed.
With regard to the valve alignment procedure, it correctly states the normal position of the valve for RIIR system operation.
No requirement exists to specify in the procedure whether the line is capped or uncapped. Burns & Roe Drawing 2040 does however show the drain line in question. as a capped line.
(2) The example cited in MWR 85-1461 was due to an inadequate procedure regarding limitorque limit switch grease removal and replacement which did not require verifying that the pin was in place following maintenance.
Corrective Action Taken and Results Achieved (1) RHR-V-181 Loop A Injection Line Leak A Design Chan ge Request (DCR 85-94) has been submitted (9-16-85) and approved (10-09-85).
When the subsequent Design Change is approved, the drain valve will be replaced when plant conditions permit.
(2) Motor burnup on the operator to the RIIR system Drywell Spray Outboard Throttle Valve due to the limit switch actuating pin having fallen out.
( R HR-MOV-MO26 A )
i The limit switch pin dropped out during reassembly of the switch after Preventive Maintenance and was not noticed by the technician.
All limit switches previously inspected by P.M. 04357 (E.Q.
Limitorque Inspection) were inspected again for proper placement of the pin in question.
As to the possible damage to the valve seat, this valve did not require any excessive torquing to manually open.
It has been determined that no seat damage occurred.
Corrective Steps Which Will be Taken to Avoid Further Violations (1) RIIR-V-181 Loop A Injection Line Leak The personnel involved in the premature closcout of MWR 85-1887 will be instructed by January 1, 1986, to ensure that specified work is complete prior to closing out MWR's.
In addition, a Design Chan ge will be written and approved to address this valve deficiency.
Physical replacement of the valve will follow the design approval progress.
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.4 Mr..L. E. Martin
'Page 3 November 30, 1985 (2) Motor burnup on the operator to the RIIR system Drywell Spray Outboard Throttle. Valve due to the limit switch actuating pin having fallen out.
( R H R-MOV-MO26A )
Maintenance procedure 7.3.21, "Limitorque Limit Switch Grease Removal and Replacement" will be revised to add a step cautioning personnel to observe pin placement during gear installation.
There will also be a step added to verify the pin is in place and functioning prior to installing the limit switch.
Date When Full Compliance Will be Achieved (1) RHR-V-181 Loop A Infection Line Leak Full compliance will be achieved by the replacement of this valve.
Installation will be performed prior to start-up from the next scheduled outage.
(2) Motor burnup on the operator to the RIIR system Drywell Spray Outboard Throttle Valve due to the limit switch actuating pin having fallen out.
( RilR-MOV-MO26 A )
Maintenance procedure 7.3.21, "Limitorque Limit Switch Grease Removal and Replacement" will be revised by February 1,1986.
If you have any question regarding this response, please contact me.
Sincerely, A
. Pilant Technical Staff Manager Nuclear Power Group JMP/DMN/WEC:chl2/1(2)