U-602843, Provides Revised Response to Violations Noted in Insp Rept 50-461/97-06.Corrective Actions:Replaced Deformed Piping on B RR Loop Drain Line,Performed Review of Similar Freeze Seal Incidents & Contracted Freeze Seal Activity to Vendor

Provides Revised Response to Violations Noted in Insp Rept 50-461/97-06.Corrective Actions:Replaced Deformed Piping on B RR Loop Drain Line,Performed Review of Similar Freeze Seal Incidents & Contracted Freeze Seal Activity to Vendor

ML20211H364
Person / Time
Site:	Clinton
Issue date:	09/30/1997
From:	Romberg W ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-461-97-06, 50-461-97-6, U-602843, NUDOCS 9710060348
Download: ML20211H364 (5)

Text

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libros Power Company Cl t i er Ltatain l

chnton il 01727 Tet 217 935,6220 Fax 217 935 4632 GWER a "' " "~~' a r

Ass stant VKe President Nuclear m

c.,.n, l

U 602843 j

4P.t90 September 30,1997 l

J Docket No. 50-461 l

l Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Revision to Reply to a Notice of Violation Csntal.ntd in insp1ction Reoort 50-461/97006 (DEP)

Dear Madam or Si :

This letter is being submitted to revise Illinois Power's (IP) response to Notice of Violation contained (provided)in IP letter U-602760, dated June 16,1997. A commitment in responw to violation 97006-05 is being revised to more accurately describe IP's corrective action. Specifically, all freeze seals at Clinton Power Station (CPS) will be performed by freeze seal specialty companies until site personnel are properly trained.

Attachment A of this letter contains the revised response to violation 97006-05 i

concerning the use of an inadequate procedure for freeze seals. Revision to this l

response is indicated by either bracketed wording or revision bars in the right-hand margin of this letter.

This letter contains the following commitments:

Training on freeze seals will be revised to include practical and classroom training.

The training will include information on industry events, including the event at CPS discussed in this response. Site personnel performing freeze seal activities will be required to receive this training prior to beginning such work.

9710060348 970930 ADOCK 050004 1 gDstuw i

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l U 602843 Page 2 Until a revised freeze seal training plan la developed and site personnel are qualified to e

th,e revised lesson plan, IP will rely on freeze seal specialty companies to pe form freeze seals at CPS in accordance with approved CPS procedures.

Sincerely yours,

{

h /t'r #

Wayne D. Romberg Assistant Vice President JRlWik Attachments cc:

NRC Clinton Project Manager Branch Chler, Region Ill, USNRC i

NRC Resident Office, V.690 Regional Administrator, Region III, USNRC lilinois Department ofNuclear Safety I

l Anachment A.

t)U402843 Page1o(3 Revised Response to Notice of Violation 50-461/97006-05 l

The Notice of Violation states in part:

"10 CFR Part 50, Appendix B, Criterion V, ' Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Contrary to the above, on November 11,1996 freeze seals were instalt 4 on a portion of the reactor coolant system boundary, an activity affecting quality, using CPS Procedure 8208.01, " Freeze Seals," revision 9, a procedure which was not appropriate to the circumstances."

Badnound and ben for the Violation i

Maintenance Work Request (MWR) D60031 was initiated on April 20,1995, to resolve seat leakage on valves IB33F051 A and IB33F052A on the B Reactor Recirculativn (RR) loop drain line. The resolution for the leaking valves was replacement. A freeze seal was required to isolate these valves on the drain line in order to remove them The process for the Reeze seal task was provided in the MWR and maintenance procedure CPS 8208.01,

" Freeze Seals." Prior to installation of the Recze seal, an engineering analysis and a 10CFR50.59 safety evaluation' screening was completed as required by the MWR, and a

_ pre-job briefwas held with the Radiation Protection Shift Supervisor, ShlR Resource Manager, Operations ShiR Supervisor, repairmen and the drywell coordinator to discuss the specifics of thejob and a contingency plan if the seal failed.

The Initial freeze plus did not completely form in the pipe due to the elevated temperature of the RR drain line and did not stop flow through the line. After discussion with the Group Leader, Mechanical Maintenance repairmen decided to install a second freeze seal Jacket next to the first jacket to help achieve the eeni. The MWR identified only one freeze seal to be installed. The second freeze seal completely froze the water in the line allowing the valves to be replaced.

When the decision was made to apply a second freeze sealjacket, engineering was not contacted to evaluate the use of a second freeze scal; the engineering analysis and safety evaluation screening had evaluated installatter of a single freeze plug.L Mechanical

.-Maintenance did initiate a second checklist.WS 8208.010001," Freeze Seal Checklist,"

for the second freeze sealjacket. The first troeze sed checklist was referenced on the second freeze seal checklist. Maintenance procedure CPS 8208.01 (does) did not address the use of a second freeze sealjacket in this situation, but does identify the minimum distance from a closed valve or blinded pipe section and does identify that multiple freeze seals may be applied at different areas to isolate the component.-

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Attachment A O U 602 43 Page 2 of 3 On February 24,1997, a copy of a Licensee Event Report (LER) was received on the

• Nuclear Network describing an event of pipe deformation that occurred during a freeze seal application at the Diablo Canyon Power Plant. The LER identiiled that bulging of the pipe resulted kom three freeze sealJackets being appiled next to each other on the pipe.

The bulging occurred at the spaces between the heeze sealJackets due to water being trapped there as the ice plugs formed. Thl Information prompted Mechanical Maintenance to initiate a condition report and an inspection of the piping on the "B" RR loop drain line where the two f eeze seals had been located.

The inspection identified that applying the two heeze sealjackets resulted in piping deformation (bulging) of approximately 0.040 inch where the heeze seal was applied. The deformation was not noticed at the time of the freeze seal work.

The cause of this violation is attributed to a lack ofprocedure guidance and inadequate training on heeze seal application. Maintenance procedure CPS 8208.01 (does] did not address the use ofmultiple freeze seals in a series.

Petsonnel applying the freeze seal felt that the application of two freeze sealjackets constituted one seal. They felt that this application would create a single ice plug.

Mainknance procedure CPS 8208.01 (does) did not restrict the application of more than one freeze sealJacket.-

Corrective Steos Takan and Remits Achieved The deformed piping on the "B" RR loop drain line was replaced.

A review was performed to determine if similar freeze seal incidents had taken place in the past. The review did not identify any other instances where two freeze seal Jackets were attached adjacent to each other to form a heeze seal, u

Since this incident, all personnel predously qualilled to perform freeze seals at Clinton Power Station have been removed from the Task Certification Matrix. The freeze seal activity is currently contracted to a freeze seal vendor with Mechanical Maintenance aislating the activity, Corrective Steos to Avoid Further Violations Maintenance procedure CPS 8208.01 was reviewed against industry guidelines for freeze seals and revised to include guldance and limitations on use ofmore than one freeze seal plug in a line.

Training on Reeze seals will be revised to include practical and classroom training. The training will include information on industry events, including the event at CPS discussed above. Site personnel performing freeze seal activities will be required to receive this training prior to beginning such work.

.i.*,

Attachment A O U402843 Page 3 of 3

" freeze}he fireen seal training plan is revised an6 site personnel are qualified to perform Until seals, IP will rely on freeze seal specialt;# companies to perfonn seals at CPS in accordance with the vendor controls specified hi CPS procedures.

Qatt_When Full Comollance Will Be Achieved _

CPS is in comp.'iance with 10CFR50, Appendix B, Criterion V with legard to this issue.

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