ML11273A002

NRR E-mail Capture - Columbia LO Analysis Program Discussed in the Inspection Report

ML11273A002
Person / Time
Site:	Columbia
Issue date:	09/27/2011
From:	Mostala A Energy Northwest
To:	Cunanan A Division of License Renewal
References
Download: ML11273A002 (3)

Text

NRR-PMDAPEm Resource From: Mostala, Abbas A. [AAMOSTALA@energy-northwest.com]

Sent: Tuesday, September 27, 2011 2:42 AM To: Cunanan, Arthur Cc: Pick, Greg; Obodoako, Aloysius; Gardner, William; Mostala, Abbas A.

Subject:

RE: Columbia LO analysis program discussed in the inspection report

Arthur, Yes. This Action Request 228715 has been resolved. Please see below.

Thanks, Abbas Actions: The following are the corrective actions taken as a result of this CR.

1) CGS will require that every EDG engine oil sample taken undergo the Low Silver Test methodology. This test is conclusive and has the needed accuracy and precision for low silver detection. This information has been updated on the Oil Analysis Program test matrix. Record viewable under the EDMS button.

2) Revise laboratory test procedures to include immediate (as soon as results are known /no later than same day) notification to program engineer for any EDG oil sample that contains silver levels above 0.2 ppm. (This requirement is also being applied to other oil samples showing a step change/abnormal results for any oil analysis parameter). Copy of the laboratory test procedure as modified is under the EDMS button.

3) Revise laboratory test procedures to perform a confirmatory re-test on an expedited basis if an EDG oil sample contains more than 0.2 ppm silver using the low silver test methodology. (This requirement is also being applied to other oil samples showing a step change/abnormal results for any oil analysis parameter).

Copy of the laboratory test procedure as modified is under the EDMS button.

4) Brief laboratory staff on PER 202-3374 which specifies and explains the reasoning for low silver limits on EDG oil samples. Require this PER review for new laboratory staff employed. New lab employees are required to review the laboratory procedures (SALLY). The PER has been attached to the SALLY. Copy of the revised SALLY is under the EDMS button.

5) The alert limits within the oil analysis database software for silver in the EDG oils have been modified to reflect the alerts and thresholds given by the EDG owners group recommendations. A copy of the modified database applicable page is attached to the EDMS button.

All actions above have been completed. The environmental laboratory director has completed and implemented the actions involving the laboratory procedures, training, and test evaluations.

Additionally, the following is not an action but is an improvement to the program. This improvement is relevant since it will improve the labs ability to detect silver and other wear metals. The laboratory used for oil sample analysis has invested in new testing equipment that will improve the accuracy and reliability of ICP test results.

Regardless, Columbia will still require the Low Silver Test methodology be employed; however, this new ICP instrument should reduce our data variability and data error significantly on silver and on other wear metals/elements.

1

From: Cunanan, Arthur [1]

Sent: Monday, September 26, 2011 7:59 AM To: Mostala, Abbas A.

Cc: Pick, Greg; Obodoako, Aloysius; Gardner, William

Subject:

Columbia LO analysis program discussed in the inspection report

Abbas, The Columbia inspection report stated the following:

The team identified that the applicant had not effectively implemented actions in response to industry operating experience related to silver content in the diesel generator lubricating oil. Specifically, NRC Information Notice 2002-22, Degraded Bearing Surfaces in GM/EMD Emergency Diesel Generators, dated June 22, 2002, and Report 10CFR21-83, Pistons Used in EMD 645 Engines, dated July 31, 2002, addressed potential diesel engine bearing problems, which would result in indications of high silver content in lubricating oil samples. In response, the applicant instituted an action level of 0.8 ppm silver that required initiating work orders to evaluate the condition of the bearings. The team identified that recent oil samples on Diesel Generator 1 had exceeded this limit (up to 2.0 ppm) three times within 6 months without the applicant initiating any evaluations.

Action Request 228715 documented this deficiency and indicated that limitations in the initial test, which used an Induction Coupled Plasma method, may have resulted in false high positive values. The applicant believed the reading might be false since the October 2010 readings exceeded 1 ppm for all five diesel generators. The applicant initiated the additional test using the low silver test method as prescribed by Problem Evaluation Request 202-3374 in response to the above operating experience. Action Request 228715 documented that changing the confirmation test frequency from monthly to annually combined with inexperienced personnel removed two administrative barriers that might have identified the out-of-specification values earlier. The applicant had not identified actions to correct the lack of awareness for the out-of-specification measurement by the end of the inspection. The team concluded the applicant had not been effective in applying external operating experience even though they had properly processed and incorporated the information into this program.

Was this Action Request 228715 resolved? If so, what was the resolution?

If it is not resolved, then we may have to discuss this in a conference call.

Sincerely, Arthur Cunanan Project Manager Division of License Renewal U.S. Nuclear Regulatory Commission 301-415-3897 arthur.cunanan@nrc.gov 2

Hearing Identifier: NRR_PMDA Email Number: 160 Mail Envelope Properties (11F5592341C9044B8FD83A755C2DA9F708A9C217)

Subject:

RE: Columbia LO analysis program discussed in the inspection report Sent Date: 9/27/2011 2:42:07 AM Received Date: 9/27/2011 2:42:13 AM From: Mostala, Abbas A.

Created By: AAMOSTALA@energy-northwest.com Recipients:

"Pick, Greg" <Greg.Pick@nrc.gov>

Tracking Status: None "Obodoako, Aloysius" <Aloysius.Obodoako@nrc.gov>

Tracking Status: None "Gardner, William" <William.Gardner@nrc.gov>

Tracking Status: None "Mostala, Abbas A." <AAMOSTALA@energy-northwest.com>

Tracking Status: None "Cunanan, Arthur" <Arthur.Cunanan@nrc.gov>

Tracking Status: None Post Office: SERVER153.domain1.energy-northwest.com Files Size Date & Time MESSAGE 5483 9/27/2011 2:42:13 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: