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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L7681999-10-19019 October 1999 Forwards Insp Rept 50-458/99-12 on 990822-1002.Four Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy RBG-45125, Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams1999-10-18018 October 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams ML20217J3751999-10-15015 October 1999 Informs That Applicable Portions of NEDC-32778P, Safety Analysis Rept for River Bend 5% Power Uprate, Marked as Proprietary Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) IR 05000458/19990071999-10-0505 October 1999 Refers to Util Ltr Re Apparent Violations Described in Insp Rept 50-458/99-07 Issued on 990804 & Forwards Nov.Insp Described Two Apparent Violations Related to River Bend Station Division I EDG RBG-45123, Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required1999-09-30030 September 1999 Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required RBG-45124, Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl1999-09-24024 September 1999 Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl RBG-45122, Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-471999-09-23023 September 1999 Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-47 RBG-45113, Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp1999-09-21021 September 1999 Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp ML20212D8901999-09-16016 September 1999 Discusses 6 Month Review of Plant Midcycle Ppr.Advises of Plans for Future Insp Activities.Forwards Historical Listing of Plant Issues,Referred to as PIM ML20216F7881999-09-15015 September 1999 Forwards Insp Rept 50-458/99-10 on 990830-990903.No Violations Noted.Insp Covered Licensed Operators Requalification Training Program & Observation of Requalification Activities 05000458/LER-1998-003, Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents1999-09-0909 September 1999 Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents ML20211Q7721999-09-0909 September 1999 Expresses Appreciation for ,In Response to NRC 990702 Re Denial of Notice of Violation Cited in Concerning Insp Rept 50-458/98-16.Reply Found to Be Responsive to Concerns Raised in NOV RBG-45109, Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted1999-09-0808 September 1999 Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted ML20211Q3921999-09-0808 September 1999 Forwards Insp Rept 50-458/99-08 on 990711-0821.One Violation Being Treated as Noncited Violation ML20211Q5541999-09-0808 September 1999 Discusses Meeting Conducted on 990830 in St Francisville,La Re Overall Performance Issues During 990403-0703 Refueling/ Maintenance Outage.Due to Proprietary Nature of Some Subject Matters,Meeting Closed to Public.Attendance List Encl ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) RBG-45095, Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status1999-09-0707 September 1999 Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status RBG-45097, Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves1999-08-31031 August 1999 Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves RBG-45094, Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation1999-08-25025 August 1999 Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation ML20211E2071999-08-23023 August 1999 Discusses Insp Rept 50-458/99-07 in Which 2 Violations Were Identified & Being Considered for Escalated Enforcement Action.Response Should Be Submitted Under Oath or Affirmation ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 RBG-45093, Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept1999-08-17017 August 1999 Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept ML20211A9291999-08-17017 August 1999 Forwards Insp Rept 50-458/99-11 on 990719-23.Areas Examined Included Portions of Licensee Physical Security Program. No Violations Noted ML20210T8881999-08-16016 August 1999 Forwards Replacement Pages 9-18 for Insp Rept 50-458/99-09, Issued on 990730 IR 05000458/19980101999-08-13013 August 1999 Forwards Summary of 990805 Mgt Meeting with Licensee in Arlington,Tx Re Radiological Control Problems Noted in Insp Repts 50-458/98-10 & 50-458/99-04.With Attendance List & Licensee Presentation ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210U3751999-08-12012 August 1999 Informs That Info Contained in Presentation, River Bend Station Fuel Recovery Project,Dtd 990622, Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act of 1954,as Amended ML20210Q7691999-08-11011 August 1999 Forwards Request for Addl Info Re Licensee River Bend Individual Plant Exam External Events,Under GL 88-20,suppl 4,dtd 910628 ML20210R4591999-08-10010 August 1999 Ack Receipt of Which Transmitted Plant Emergency Plan,Rev 20 Under Provisions of 10CFR50,App E,Section V.Nrc Approval Not Required,Based on Determination That Changes Does Not Decrease Effectiveness of EP ML20210N1641999-08-0404 August 1999 Forwards Insp Rept 50-458/99-07 on 990530-0710.One Violation of NRC Requirements Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy ML20210K4641999-08-0303 August 1999 Forwards SE Accepting Licensee 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Power-Operated Gate Valves, Issued on 950817 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K1351999-07-30030 July 1999 Forwards Insp Rept 50-458/99-09 on 990510-28 with in-office Insp Until 990701.Three Violations Being Treated as Noncited Violations ML20210J9691999-07-30030 July 1999 Discusses 990719 Meeting with Util in Arlington,Tx Re Region IV Staff Findings of Root Cause Investigation Into Fuel Cladding Failures That Occurred During Recent Cycle 8 Operation.List of Attendees & Organization Chart Encl RBG-45072, Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL1999-07-23023 July 1999 Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL ML20210E9001999-07-23023 July 1999 Informs That as Result of Staff Review of Licensee Responses to GL 92-01,rev 1,Suppl 1 & Suppl 1 Rai,Staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2 RBG-45073, Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl1999-07-20020 July 1999 Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl RBG-45071, Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl1999-07-19019 July 1999 Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl 05000458/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 11999-07-15015 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 1 ML20196L0501999-07-0606 July 1999 Informs That NRC Insp Rept 50-458/99-03 Issued on 990519 with Errors in Tracking Numbers Assigned to Seven Noncited Violations & Error Re Actual Location of SRO During Refueling Activities.Revised Pages 2 & 4 Encl ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196K6851999-06-30030 June 1999 Ack Receipt of & Denial of NOV in Response to Transmitting NOV & Insp Rept 50-458/98-16.Listed Info Documents Results of Review of Response to Violation Re fire-induced Circuit Faults ML20196K0671999-06-30030 June 1999 Forwards Insp Rept 50-458/99-04 on 990412-16 & 28-29.Five Violations of NRC Requirements Occurred & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy.Meeting Scheduled for 990726 RBG-45048, Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept1999-06-29029 June 1999 Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept RBG-45047, Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output1999-06-29029 June 1999 Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output ML20196H5171999-06-21021 June 1999 Requests Withholding of Info Being Presented in Meeting of Entergy,General Electric & NRC Staff.Licensee Requested Meeting with NRC to Present Info on Recent Anomalous Conditions Found During Insp of Fuel Bundles.W/Affidavit 05000458/LER-1999-012, Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form1999-06-21021 June 1999 Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form RBG-45035, Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld1999-06-21021 June 1999 Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld ML20196E0601999-06-18018 June 1999 Forwards Insp Rept 50-458/99-05 on 990418-29.Four Violations Identified & Being Treated as Noncited Violations 05000458/LER-1999-011, Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl1999-06-0909 June 1999 Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARRBG-45125, Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams1999-10-18018 October 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams RBG-45123, Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required1999-09-30030 September 1999 Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required RBG-45124, Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl1999-09-24024 September 1999 Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl RBG-45122, Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-471999-09-23023 September 1999 Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-47 RBG-45113, Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp1999-09-21021 September 1999 Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp 05000458/LER-1998-003, Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents1999-09-0909 September 1999 Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents RBG-45109, Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted1999-09-0808 September 1999 Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted RBG-45095, Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status1999-09-0707 September 1999 Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) RBG-45097, Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves1999-08-31031 August 1999 Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves RBG-45094, Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation1999-08-25025 August 1999 Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 RBG-45093, Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept1999-08-17017 August 1999 Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept RBG-45072, Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL1999-07-23023 July 1999 Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL RBG-45073, Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl1999-07-20020 July 1999 Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl RBG-45071, Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl1999-07-19019 July 1999 Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl 05000458/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 11999-07-15015 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 1 ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl RBG-45047, Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output1999-06-29029 June 1999 Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output RBG-45048, Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept1999-06-29029 June 1999 Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept ML20196H5171999-06-21021 June 1999 Requests Withholding of Info Being Presented in Meeting of Entergy,General Electric & NRC Staff.Licensee Requested Meeting with NRC to Present Info on Recent Anomalous Conditions Found During Insp of Fuel Bundles.W/Affidavit RBG-45035, Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld1999-06-21021 June 1999 Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld 05000458/LER-1999-012, Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form1999-06-21021 June 1999 Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form 05000458/LER-1999-011, Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl1999-06-0909 June 1999 Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl 05000458/LER-1999-010, Forwards LER 99-010-00 for River Bend Station,Unit 1 IAW 10CFR50.73.Commitments Identified in Rept,Encl1999-05-28028 May 1999 Forwards LER 99-010-00 for River Bend Station,Unit 1 IAW 10CFR50.73.Commitments Identified in Rept,Encl RBG-45021, Informs That Cycle 9 Operation Will Remain within MCPR Safety Limits Approved in Amend 105 to TS Issued by NRC in1999-05-26026 May 1999 Informs That Cycle 9 Operation Will Remain within MCPR Safety Limits Approved in Amend 105 to TS Issued by NRC in 05000458/LER-1999-009, Forwards LER 99-009-00 IAW 10CFR50.73.Commitments Contained in Ltr Are Identified on Commitment Identification Form1999-05-24024 May 1999 Forwards LER 99-009-00 IAW 10CFR50.73.Commitments Contained in Ltr Are Identified on Commitment Identification Form RBG-45017, Informs NRC of Addition of ASME Boiler & Pressure Vessel Code,Section Xi,Code Case N-496-1 to RBS Inservice Insp Program.Commitment Made by Util,Encl1999-05-14014 May 1999 Informs NRC of Addition of ASME Boiler & Pressure Vessel Code,Section Xi,Code Case N-496-1 to RBS Inservice Insp Program.Commitment Made by Util,Encl ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 05000458/LER-1999-007, Forwards LER 99-007-00 IAW 10CFR50.73.Commitments Identified in LER Are Noted in Attachment 11999-05-10010 May 1999 Forwards LER 99-007-00 IAW 10CFR50.73.Commitments Identified in LER Are Noted in Attachment 1 05000458/LER-1999-006, Forwards LER 99-006-00 Re Unplanned Automatic Standby Svc Water Initiation,Due to Procedure Inadequacy.Commitments Identified in Rept Noted in Attachment 11999-05-0606 May 1999 Forwards LER 99-006-00 Re Unplanned Automatic Standby Svc Water Initiation,Due to Procedure Inadequacy.Commitments Identified in Rept Noted in Attachment 1 05000458/LER-1999-005, Forwards LER 99-005-00 IAW 10CFR50.73(a)(2)(i).Commitments Identified in LER Are Noted in Attachment 11999-05-0303 May 1999 Forwards LER 99-005-00 IAW 10CFR50.73(a)(2)(i).Commitments Identified in LER Are Noted in Attachment 1 RBG-44993, Forwards RBS Annual Individual Monitoring Rept for Jan-Dec 1998,per Requirements of 10CFR20.2206(b).File Info Listed. Without Encl1999-04-30030 April 1999 Forwards RBS Annual Individual Monitoring Rept for Jan-Dec 1998,per Requirements of 10CFR20.2206(b).File Info Listed. Without Encl RBG-44998, Informs of Missing Documentation Re Examination Results Reported in RBS Owners Activity Report Forms Submitted to NRC on 9802241999-04-30030 April 1999 Informs of Missing Documentation Re Examination Results Reported in RBS Owners Activity Report Forms Submitted to NRC on 980224 ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested 05000458/LER-1999-003, Forwards LER 99-003-00,per 10CFR50.73.Commitments Identified in Rept Are Noted in Attachment 11999-04-23023 April 1999 Forwards LER 99-003-00,per 10CFR50.73.Commitments Identified in Rept Are Noted in Attachment 1 RBG-44968, Submits Addl Info Re 981008 LAR 1998-02 Re Implementation of Bwrog/Ge Enhanced Option I-A (EI-A) Reactor Stability long- Term Solution.Clarifies Certain Aspects of Proposed Ts,Per 990406 Telcon with NRC1999-04-15015 April 1999 Submits Addl Info Re 981008 LAR 1998-02 Re Implementation of Bwrog/Ge Enhanced Option I-A (EI-A) Reactor Stability long- Term Solution.Clarifies Certain Aspects of Proposed Ts,Per 990406 Telcon with NRC RBG-44965, Responds to 990324 Telcon RAI Re SLMCPR Calculation Method for RBS Cycle 9 Slmcpr,Per LAR 1998-15 Re Change to TS 2.1.1.2, Reactor Core Safety Limits. Proposed TS Pages, Encl1999-04-0808 April 1999 Responds to 990324 Telcon RAI Re SLMCPR Calculation Method for RBS Cycle 9 Slmcpr,Per LAR 1998-15 Re Change to TS 2.1.1.2, Reactor Core Safety Limits. Proposed TS Pages, Encl RBG-44959, Withdraws 981120 LAR 1998-20,allowing Adjusting Control Pattern for Plant Startup If Outage Had Occurred Before Planned Refueling Outage.No Plant Outage Was Conducted & Plant Is Now in Eighth Refueling Outage1999-04-0808 April 1999 Withdraws 981120 LAR 1998-20,allowing Adjusting Control Pattern for Plant Startup If Outage Had Occurred Before Planned Refueling Outage.No Plant Outage Was Conducted & Plant Is Now in Eighth Refueling Outage ML20205F1781999-03-31031 March 1999 Forwards Consolidated Entergy Submittal to Document Primary & Excess Property Damage Insurance Coverage for Nuclear Sites of Entergy Operations,Inc,Per 10CFR50.54(w)(3) RBG-44939, Forwards Rbs,Unit 1 Annual Occupational Radiation Exposure Rept for 1998, Per TS 5.6.1.Rept Consists of Tabulation of Exposure for Personnel Receiving Exposures Greater than 100 Mrem Per Yr1999-03-31031 March 1999 Forwards Rbs,Unit 1 Annual Occupational Radiation Exposure Rept for 1998, Per TS 5.6.1.Rept Consists of Tabulation of Exposure for Personnel Receiving Exposures Greater than 100 Mrem Per Yr ML20196K7101999-03-26026 March 1999 Submits Reporting & Recordkeeping for Decommissioning Planning,Per 10CFR50.75(f)(1) RBG-44899, Provides Notification of Termination of Licensed Operator, AA Rouchon,License OP-42416-1,due to Resignation.Reactor Operator License Data,Listed1999-03-25025 March 1999 Provides Notification of Termination of Licensed Operator, AA Rouchon,License OP-42416-1,due to Resignation.Reactor Operator License Data,Listed ML20204G8701999-03-15015 March 1999 Responds to NOV Described in NRC Correspondance to Util ,expressing Disappointment in NRC Determination That AD Wells Deliberately Provided Incomplete & Inaccurate Info to NRC During Meeting on 971015 RBG-44925, Responds to NRC Re Violations Noted in Investigation Rept 4-97-059.Corrective Actions: Mgt Expectations for Communicating with NRC Issued to Site Personnel on 980212,by RBS Vice President,Operations1999-03-15015 March 1999 Responds to NRC Re Violations Noted in Investigation Rept 4-97-059.Corrective Actions: Mgt Expectations for Communicating with NRC Issued to Site Personnel on 980212,by RBS Vice President,Operations RBG-44924, Informs That Util Response to NOV Re Investigation Rept 4-97-059,will Be Issued by 990315,as Extended by NRC Ltr .Encl Check for $55,000 Is for Payment of Civil Penalty IAW Instructions in .Without Check1999-03-0505 March 1999 Informs That Util Response to NOV Re Investigation Rept 4-97-059,will Be Issued by 990315,as Extended by NRC Ltr .Encl Check for $55,000 Is for Payment of Civil Penalty IAW Instructions in .Without Check RBG-44912, Responds to Violations Noted in Insp Rept 50-458/98-13. Corrective Actions:Matls & Training Were Provided to Expedite Implementation of Existing Procedural Guidance to Supply Compressed Air1999-03-0303 March 1999 Responds to Violations Noted in Insp Rept 50-458/98-13. Corrective Actions:Matls & Training Were Provided to Expedite Implementation of Existing Procedural Guidance to Supply Compressed Air RBG-44904, Informs NRC of Date Change Re Commitment Made in Response to NOV 50-458/98-05-01.New Commitment Date 9912161999-02-25025 February 1999 Informs NRC of Date Change Re Commitment Made in Response to NOV 50-458/98-05-01.New Commitment Date 991216 RBG-44384, Submits Response to Fuel Cladding Defect Issues Raised in 10CFR2.206 Petition.Clear Technical Basis Exists in Info Provided by River Bend Station to Deny Petition1999-02-11011 February 1999 Submits Response to Fuel Cladding Defect Issues Raised in 10CFR2.206 Petition.Clear Technical Basis Exists in Info Provided by River Bend Station to Deny Petition ML20203C4201999-01-25025 January 1999 Submits Denial of NRC Request for Advance Info Re Concerns Raised by Ucs in 10CFR2.206 Petitions on River Bend & Perry Plants.Petitioners Were Not Required to Provide NRC with Info in Advance of Informal Public Hearings 1999-09-09
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l t, l GWTLF' STATES UTILITIES COMPANY } ,
i re.T N e t L.D 3
- a %N Gest ;;o n t tCn :: a st f we%cAnit s o.ns,A%A 73775 l m s a va . w as ase ses, ?
June 16, 1993 RBG- 38636 -
File Nos. G9.5, G15.4.1 f
'U.S. Nuclear Regulatory Commission
,- Region IV -' Regional Administrator l l 611 Ryan Plaza Drive, Suite 400. !
L - Arlington, TX 76011 i
Gentlemen: ;
River Bend Station - Unit I j l Docket No. 50-458/93-05 i
- l. Pursuant - 10CFR2.201, Gulf States Utilities Company's (GSU) response to j Notices. of Violation for NRC Inspection Report Item No. 50-458/93-05 is I
submitted at this time as discussed with Mr. Jim Gagliardo of NRC Region IV.
The inspection was conducted by Messrs. .W.F. Smith and D.P. Loveless on i January 31 through March 13,1993, of activities authorized by NRC Operating i
, License NPF-47 for River Bend Station - Unit 1 (RBS). GSU's reply to the l l violation is provided in the attachment. !
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Should you have any questions, please contact Mr. D.N. Lorfmg at (504) 381-4157.
Sincerely, i
Y hs-th)7 9309070038 9 3.E. Booker l g DR ADOCK O g- Manager - Safety Assessment
- l. PDRL and Quality Verification River Bend Nuclear Group
- p 4(h ,J 4 JPS/FRC/JHM/JBB/kym 4
.. Attachment i
cc: .U.S. Nuclear Regulatory Commission Document Control Desk
- Washington, D.C. 20555 i NRC Resident Inspector L_ P.O. Box- 1051
- St. Francisville, LA 70775'
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I ATTACIIMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/9305-01 LEVEL IV REFERENCE ,
Notice of Violation - Letter from A.B. Beach to P.D. Graham dated April 30, 1993.
VIOLATION 10 CFR Pan 50, Appendix B, Criterion XI, " Test Control," states, in pan, that a test pmgram shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contray to the above, on Febmag 24, 1993, all testing required to demonstrate that Control Building Instrument Air Solenoid Operated Valve lIAS*SOV36A would perform satisfactorily
- was not identified and performed, in that maintenance that could have affected seat and bonnet leakage integrity was performed, and the pos' .aaintenance test did not verify that the leakage integrity of the valve was adequate. In addition, the maintenance performed included disassembly and adjustment of the valve position indicating reed switches, but the post- j maintenance test did not verify the appropriate position indication which caused the stroke time test to be invalid.
l REASON FOR THE VIOLATION When a maintenance work order (MWO) is generated for a condition / problem, the maintenance planner incorporates all the applicable documents and procedures into the work package as addressed by his program. Involved in this process is the post maintenance test (Ph1T) requirements which are the specific test procedures performed as required by Operations, Maintenance, System Engineering, motor operated valve (MOV), in-service test (IST), and local leak rate test (LLRT) groups. When the planner is completed with the package, he routes the MWO to the applicable depanments for their review. The depanment's review involves review of their specific sections of the MWO for accuracy, review of the entire package for completeness, and determination of pmper retest requirements.
In this case, the specific package for valve IAS*SOV36A was generated due to the solenoid valve (SOV) failing its stroke time test. The package detailed the removal and disassembly of the valve to troubleshoot and repair. In the package, the directions provided a clear order of steps to accomplish the repair. It also indicated that the reed switch assembly was to be matched prior to removal, and returned to its original position upon reassembly. Based on this information, the engineer reviewed the package and determined that the stroke time surveillance test (STP-122-6301) was a sufficient test to fulfill the PMT requirements.
Local position indication verification was determined to no be necessary because the specified steps regarding disassembly of the valve per the MWO, vendor manual, and work practices were deemed adequate by System Engineering. A leak test was not specified by the System
- . Engineering IST Coordinator because IAS*SOV36A is a Category "B" valve per ASME XI and j as such does not require testing for seat leakage. Other leakage test requirements were not i
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l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Condition Report #93-0093 was generated to address the concems on the post maintenance test requirements. Due to the concern with position indication, the QC department was requested i
to perfonn a radiograph to_ verify that the position indication was indeed correct. This was found satisfactory.
I Leakage thmugh IIAS*SOV36A has been measured as part of the to*.al accumulator leak test in TSP-0029 " Control Building Air Accumulator Test." Because performance of this test requires rendering both divisions of Control Room HVAC inoperable, TSP-0029 is scheduled during
[ refuelings only. Per the disposition of CR 93-0093, the local position verification section of
- STP-122-6301 was performed as an equivalent retest to determine if there was gross leakage through IIAS*SOV36A. The valve exhibited no leakage in this test.
1 liAK*MV%A is backed up by a check valve so that there is redundant protection against excessive !cakage. The calculation for the control building air accumulators includes leakage
. for ilm SOV and the check. valve. This calculation provides enough margin to conclude that if j no gross leakage exists through the SOV, then the system will perform its safety function should the need arise.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER FINDINGS
! All technical section procedures (TSPs) will be reviewed to determine if they should be added i to the Maintenance Planning Guidelines as required post maintenance tests for applicable l components. The Maintenance Planning Guidelines will be revised as required. In addition, i the test method used to determine leakage through IIAS*SOV36A per the local position verification section of STP-122-6301 will be used in the future following maintenance on both i IIAS*SOV36A and IIAS*SOV36B. The section will be identified in the STP as being a post maintenance test requirement.
$ DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of the TSPs and any necessary revision to the Maintenance Planning Guidelines will
- be completed by September 1,1993.
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ATTACIIAIENT 2 REPLY TO NOTICE OF VIOLATION 50-458/9305-02 ,
LEVEL IV i
REFERENCE ;
Notice of Violation - Letter from A.B. Beach to P.D. Graham dated April 30,1993.
, VIOLATION l l i l l l . Technical Specification 6.8.1.d states that written procedures shall be established, implemented, i and maintained covering surveillance and test activities of safety-related equipment.
Contrary to the above, two inservice testing program surveillance procedures were not properly established or maintained in that they contained instructions that were in conflict with the ASME Code, but = specific relief reonest had been subn'itted by the license and approved by NRC:
- 1. On February 10,1993, Surveillance Test Procedure STP-410-6312, Revision 0, ,
" Control Building Chilled Water System Quarterly Pump and Valve Operability !
Test Division II," (including Change Notice 93-0027) was technically inadequate j in that, for Pump IHVK'PID, it allowed establishing pump differential pressure :
over a range of 93 to 102 percent of the reference value instead of equal to the ;
reference value as required by Procedure IWP-3100 in Section XI of the ASME l Code. For Pump IHVK*PIB, the procedure had a note which allowed the l
operator to vary the pump differential pressure without regard to the reference ,
value as long as the flow was satisfactory, thus defeating the purpose ofinservice I taring for early detection er pump &gmtfon.
- 2. On March 10, 1993, Surveillance Test Procedures STP-309-6301, -2, and -3, Revisions 4,- 5, and 4A, respectively, " Division I, II, and III Diesel Generator ISI Pump Operability Test," were technically inadequa* in that they directed the operators to measure pump flow rate using the day tank level indicator and a stop watch, when paragraph IWP-4600 of the ASME Code requires flow rate to be measured 'using a rate or quantity meter installed in the test circuit.
RESPONSE TO VIOLATION 9305-02 ITEM #I The following deficiencies were noted by NRC in section 5.2 of IR 93-05 concerning Violation 930542 Item #1:
9 Data Sheet' # 2 Line 7.4.21, provided an acceptance range for differential pressure. Because this was the reference value, providing a range of values was in violation of the ASME Code, Section IWP-3100. This deficiency was exacerbated by the fact that there was an asterisk referencing a note that stated, "This range is not_ test acceptance criteria, it is included only to assure repeatability of test data. If the range cannot be met, that test is still valid if )
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other data are within acceptance range." This could have been one of the contributing causes of inconsistent data each time the pumps were tested. A similar note existed in other pump operability inservice procedures, i.e., for the ;
three emergency diesel generator fuel oil transfer pumps.
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O Data Sheet # 3 was changed to eliminate the above asterisk refemnced note for
. Pump PID. However, an acceptance range, alert range and unacceptable range ,
as shown in the ASME Code IWP-3100-2 was added to the reference value for pump differential. This is in violation of the ASME Code, Section IWP-3100. j It was not appropriate to apply these ranges to the test input reference value.
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REASON FOR VIOLATION Data Sheet #2 Line 7.4.21 pmvided in the acceptance range a +% % tolerance for differential pressure reference values. Because this reference value was used to establish system resistance, I an asterisk and a note was provided to state that: "This range is not acceptance criteria, it is included only to assure repeatability of test data. If the range cannot be met, that the test is still .
valid if other data are within acceptance range." The second sentence was added in error to i clarify the first sentence but failed and only confused the original concept that the. % % range l was there for instmment fluctuation. This asterisk and note were in the process of being removed from all pump STP's when this procedure was last performed. Data Sheet #3 for pump iHVK"P1D had been changed to reflect the removal, and placed acceptance criteria, alert ranges
! and unacceptable ranges in its place.' This action was determined appropriate due to the ASME .
Code Section .XI IWP-3100 " Inservice Test Procedure" requiring that the resistance of the ,
system shall be varied until either.the measured differential pressure or measured flow rate ;
equals the corresponding reference value. The test qualities shown in IWP-3100-1 shall then be ;
measured or observed and recorded as directed in this subsection. Each measured test quantity l shall then be compared with the reference value of the same quantity. Any deviations j determined shall be compared with the limits given in Table IWP-3100-2 and specified corrective action taken.
In the case of both data sheets. the differential pressure refercnce value was used to establish the i system resistance. A tolerance of % % was assigned for instmment fluctuation of the gauges, i but if the test parameter was placed within the band it 'vould be equal to the reference value.
At no time during the revision process did we not specify a reference value. The assignment of acceptance, alert and unacceptable criteria is per the direction of the ASME Code IWP-3100 i final sentence that allows the review of deviations from the acceptance criteria. l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Due to the recent events in relation to IST testing, the pump data sheets have been revised to clarify that the reference value is to be used for system resistance only, and a statement was added to state: "The Acceptance criteria is met if the reference value is set within the specified tolerance." The placement of this statement will eliminate the mis-interpretation of the reference value in the future.
i CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER. VIOLATIONS The corrective actions described above will prevent further violations.
DATE WHEN FULL COMPLIANCE IS ACHIEVED All corrective steps have been completed.
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l RESPONSE TO VIOLATION 9305-02 ITENI #2 REASON FOR TIIE VIOLATION ASME Code Section XI IWP-4600 Flow Measurement states: Flow rate shall be measured l using a rate or quantity meter installed in the pump test circuit. The meter may be in any class i that provides an overall readout repeatability within the accuracy limits ofIWP-4110-1. Where i the meter does not indicate the flow rate directly, the record shall include the method used to j reduce the data."
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GSU believed that a relief request was not needed to use a level instmment and time period for ;
flow measurement due to the second sentence ofIWP-4600 which allows for the use of a meter ,
that does not indicate the flow mte directly as long as it is included in the record of test and the ]
method to produce the data is recorded. Because of this, no request for relief was generated in I this regard.
CORRFI'TTVE STEPS TAKEN ttND RESULTS ACIIIEVED Tine existing IST surveillance procedures will be maintained until the interim pump request for relief, described below, is approved.
CORRECTIVE STEPS WIHCH WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS l
The following actions were taken to prevent further violations. A code case was generated and forwarded to the ASME Codes and Standards committee inquiring about alternative requirements to IWP-4600. In addition to the code case, an Interim Pump Request for Relief.No #15 was l generated for the use of the level instrument and time period in lieu of the direct flow rate measurement.
l DATE WHEN FULL CONIPLLLNCE IS ACHIEVED l- The present IST diesel fuel oil testing progmm requirements have been reviewed and approved I by the NRC. The existing IST surveillance procedures will be maintained and the Interim i Request for Relief will be sent for NRC approval. Full compliance will be achieved upon 1 approval of the interim request for relief. !
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ARTICLE IWP - 3000 INSERVICE TEST PROCEDURES (EXCERPTS)
! IWP-3100 INSERVICE TEST PROCEDURE An inservice test shall be conducted with the pump operating at nominal motor name plate speed +
for constant speed drives, and at a speed adjusted to the reference speed for variable speed l drives. The resistance of the system shall be varied until either the measumd differential i pressure or the measured flow rate equals the cormsponding mfemnce value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as direct in this Subsection. Each measured test quantity shall then be compamd with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-1100-) and the specified corrective action taken.
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TABLE IWP-3100-1 INSERVICE TEST OUANTITIES l
MEASURE OBSERVE r
Speed N X ;
Iniet Pres 3nre Pi X Differential Pressure AP X !
Flow Rate Q X Vibration V X Proper Lubricant X ;
Bearing Temperature Tb X TABLE IWP-3100-2 ALLOWABLE RANGES OF TEST QUANTITIFS ALERT RANGE REQUIRED ACTION TEST ACCEITABLE LOW 'ALUE HIGil VALUE LOW llIGli QUANTITY RANGE VALUES VALUES P, See Note 2 See Note 2 See Note 2 See Note 2 See Note 2 AP .93 - 1.02AP .90 .93AP 1.02 - 1.03 AP <.90 AP > 1.03AP Q .94 - 1.02 Q .90 .94 Q 1.02 - 1.03 Q <.90 Q >1.03 Q Note #2 P, shall be within specified by the Owner in the record of tests (IWP-6000)
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. .. 1 e ATTACHMENT 2 INTERIM NO. I-02 PUMP REQUEST POR RELIEF NO. 15 SYSTEM:
Diesel Generator - Fuel Oil CCMPONENT: 1EGF*P1A, B, &C CLASS: 3 FUNCTION:
To transfer fuel oil from fuel oil storage tank to the emergency diesel generator fuel oil day tank.
TEST REOUIREMENT: IWP-4600 flow rate shall be measured using a rate or quantity meter installed in the pump test circuit. The meter may be in any class that provides an overall readout repeatability within the accuracy limits of. Table 'IWP-4110-1. Where the
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meter does not indicate the flow rate directly, the record data. shall include the method used to reduce the '
BASIS FOR RELIEF:
The purpose of the Emergency Diesel Generator Fuel Oil Transfer Pump is to pump fuel from the storage tank to the Emergency Diesel Generator Fuel Oil day tank.
the There fuel oil aresystem.
no flow instruments installed in The inservice requirement is to obtain a flow rate whichtest is achieved by a measurement of level of the storage tank and a volume change versus time to indicate a flow rate.
ALTERNATE TESTING:
To obtain the required flow rate, the use of a level instrument and time period will be used to calculate the flow rate. This calculation will be documented in the record of test.
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Code Case N-XXX Alternative . Rules for Determining Pump Flowrote Section XI, Division 1 5
Inquiry: i What attemative requirements to IWP 4600, Flow Measurement. '
may be used to determine flowrate?
o Reply?
it is the opinion of the Committee that a change in level over time i may be used provided that:
a) the level indicating instrument accuracy shall be within +2% of tuli scale and the instrument shall meet the requirements of IWP-4100.
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.calculate b) Theflowrate recordbased of test (IWP-6240) shall include the method u on changes in level over time.
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