ML18030A070

Responds to NRC 900105 Ltr Re Violations Noted in Insp Repts 50-387/89-33 & 50-388/89-31.Corrective Actions:Rhr Svc Water Pump 2P506B Remains in Inoperable Status Until Cause of Deviation Determined & Condition Corrected

ML18030A070
Person / Time
Site:	Susquehanna
Issue date:	02/05/1990
From:	Keiser H PENNSYLVANIA POWER & LIGHT CO.
To:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
PLA-3336, NUDOCS 9002160137
Download: ML18030A070 (5)

Text

ACCELERATED DL'MUBUTION DEMONSTIRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)

ACCESSION NBR:9002160137 ~ DOC.DATE: 90/02/05 NOTARIZED: NO DOCKET FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388'usquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH. NAME AUTHOR AFFILIATION KEISER,H.W. Pennsylvania Power & Light Co.

RECIP. NAME RECIPIENT AFFILIATION GALLO,R.M. Region 1, Ofc of the Director

SUBJECT:

Responds to NRC 900105 50-387/89-01 & 50-388/89-01.

ltr re violations noted in Znsp Repts DISTRIBUTION CODE: ZE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General,(50 Dkt)-Insp Rept/Notice of VioTation Response NOTES:LPDR 1 cy Transcripts. 05000387, LPDR 1 cy Transcripts. 05000388 A

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 PD 1, 1 THADANI,M 1 1

'INTERNAL: ACRS .2 -2 AEOD 1 1 AEOD/DEIZB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DZR 11 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 .2 NRR/DRIS/DIR 1 . 1 NRR/DST/DIR 8E2 1 1' NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 0 IEBEt; 02 J 1 1

1 1

OGC/HDS2 RES MORISSEAU,D 1

1 1

1 RGN1 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSZC 1 1 R

NOTES 2 2 S

NOIR TO ALL "RIDS" RECIPIEWIS S

PLEASE HELP US TO REDUCE WASIEI CONTACT 'IHE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXl; 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMEjhGS YOU DON'T NEED1 TAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 28

Pennsylvania Power &. Light Company Two North Ninth Street ~ Allentown, PA 18101 ~ 215 i 770.5151 Harold W. Keiser Senior Vice President. Nuclear 215i770.4194 FEH0 ~ 'n"~

Mr. Robert M. Gallo, Chief Operations Branch Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO NOTICE OF VIOLATION (387/89-33; 388/89-31) Docket Nos. 50-387 PLA-3336 FILES R41-1C R41-2 and 50-388 t

Dear Mr. Gallo:

This letter provides Pennsylvania Power & Light Company's response to the Notice of Violation for NRC Combined Inspection Report 50-387/89-33 and 50-388/89-31 dated January 5, 1990.

The days notice recpxired submittal of of the date of the letter.

find the attached response acceptable.

a We written reply within thirty (30) trust that the commission will Very truly yours, H. W. Keiser Attachment cc: NRC Document Control- Desk.(original) =.

NRC Region I Mr. G. S. Barber, NRC Sr. Resident Inspector Mr. M. C. Thadani, NRC Project Manager p00205 9002i+0 ADClCK 050003~7 pop pDC 9

4.

RESPONSE TO NOTICE OP VIOLATION VIOLATION (388/89-3 1-0 1)

Technical Specification 4.0.5, specifies that inservice testing of pumps shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.

Section XI of the ASME Boiler and Pressure Vessel Code, Article IWP-3000, Inservice Test Program paragraph IWP-3230(b) specifies that if test quantities fall within the required action range, the pump shall be declared inoperative and not returned to service until the cause of the deviation has been determined and the condition corrected.

Contrary to the above, during the performance of surveillance testing, conducted on March 28, 1989, of residual heat removal service water pump 2P506B, when the differential pressure test quantity of 77.6 PSID fell within the required action range (above the acceptance range of 65 71 PSID) the pump was declared operable and returned to service without the cause of the deviation being determined.

RESPONSE

1. Reason for the Violation If Admitted:

PP&L does not contest that during the performance of surveillance testing, conducted on March 28, 1989, of residual heat, removal service water pump 2P506B, when the differential pressure test quantity of 77.6 PSID fell within the required action range (above the acceptance range of 65 71 PSID) the pump was declared operable and returned to service without a final cause of the deviation being formally determined and dispositioned. As the deviation involved a differential pressure being higher than the capability of the pump as defined in the pump's head curve, evaluations performed immediately following the Residual Heat Removal Service Water (RHRSW) system flow verification deviation determined that the pump was operable. These evaluations were consistent with the intent of the ASME Code.

The purpose of the quarterly flow verification surveillance High values of'he i is to -determine pump .degradation.

performance test quantities are not indicative of pump degradation. Rather, they are indicative of instrumentation or system changes. Such anomalies warrant prompt investigation and resolution; but in no way justify any declaration of pump inoperability. PP&L will therefore submit a relief request which will allow for the cause of the deviation to be determined expeditiously as possible and either the causative condition will be corrected prior to successful completion of the affected test or else corrective action taken per IWP-3230(c).

2. Corrective Ste s 'Which Have Been Taken and the Results Achieved The flow deviation on March 28, 1989, was immediately recognized as one requiring corrective action, in accordance with ASME Code Section XI, IWP-3230(b) and (c) requirements, and the following actions were taken.

a) The subject pump remained in an inoperable status until the cause of the deviation had been determined per IWP-3230 and until the condition had been corrected by the method of analysis demonstrating that the condition did not impair pump operability and that the pump would still perform its design function.

b) The observed deviation indicated an improvement in pump e performance of 400 gpm. It was to confirmed that no pump since its significant work had been done the previous test, and no physical mechanism exists for performance of the pump to improve by itself. Comparison of pump head data to the design pump curve and vibration measurements to those of previous tests confirmed the continuing good performance of the pump. PP&L therefore concluded that the pump was not the source of the deviation.

c) Test instrument calibration checks performed shortly following the test showed the instruments to be indicating accurately.

d) PP&L considers the cause of the indicated flow deviation to be attributable to possible fouling of the flow element installed inside the 26" RHRSW system piping. Our determination, however, could not be conclusively established due to the inability to drain and inspect the RHRSW system which may require the shutdown of both Unit 1 and Unit 2.

3. Corrective Ste s Which Will Be Taken to Avoid Purther Violations No further action is required.

4. Date of Pull Com liance Based on the above, PP&L is in full compliance.