View source for RBG-38636, Responds to NRC Re Violations Noted in Insp Rept 50-458/93-05.Corrective Actions:Test Method Used to Determine Leakage Through 1IAS*SOV36A Will Be Used in Future Following Maint

{{Adams
| number = ML20056G672
| issue date = 06/16/1993
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/93-05.Corrective Actions:Test Method Used to Determine Leakage Through 1IAS*SOV36A Will Be Used in Future Following Maint
| author name = Booker J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-38636, NUDOCS 9309070038
| title reference date = 04-30-1993
| package number = ML20056G667
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 9
}}

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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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i, considered.
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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                                           )
                                                                                                                                                        ^
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.
                                                                                                                                                               ]
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."
                                                                                                                                       )
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
                                                                                  ~
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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