ML20064A583

Responds to Violations Noted in Insp Repts 50-352/90-17 & 50-353/90-16 Re Differential Pressure for Pumps.Corrective Actions:Licensee Will No Longer Use Expanded Ranges as Acceptance Criteria for Inservice Testing Program Tests

ML20064A583
Person / Time
Site:	Limerick
Issue date:	09/07/1990
From:	Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9009140143
Download: ML20064A583 (4)

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[ . m a PHILADELPHIA ELECTRIC COMPANY-l LIMERICK GENER ATING ST ATION' P. O. 90X A <

' S AN ATOG A, PENN5YLV ANI A 15444 ,

(215) 3271200, EXT. 3000 September 7,1990\

mu u. unem m . ........, Docket No.- 50-352 - - '

m...........n..'a"*" License No -NPF-39; 1

.U.S. Nuclear'Rery < tory Commission  :

~ Attn: Document C # ol Desk  ?

Washington,'DC .20 SS  ;

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Limerick Generating Station, Unit 1:

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SUBJECT:

' Reply to a Notice of Violation j

HRC Inspection Report.No. 50-352/90-17 and'50-353/90-16' i

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Dear Sirs:

Attachsd,is Philadelphia Electric Company's reply to a Notice of' Violation _ for'. .l

-Limerick = Generating Station (LGS) Unit 1, which was contained in NRC Inspection Report I

No. 50-352/90-17 and 50-353/90-16 for LGS, Units 1 and 2, dated August 3, 1990. J 1

, . . This Notice of Violation pertains to generically ~ using expanded ranges- for - q differential pressure or flow for safety-related pumps which extended beyond thoca .

1 y i,~ Especified in Table IWP-3100-2 of,Section XI of the.ASME Boiler and Pressure Vess6 Code without appropriate technical: justification. Attachment 1 to this letter provides a restatement of the violation followed by our response. The response includes the. reason ,

. for the violation, tM corrective steps which have been taken and the results' achieved, s E theicorrective steps which willibe taken toLavoid further violations, and the date when iull compliance will be achieved. We received the inspection report'on August 7. 1990, 3 and are submitting this response within 31 days of receipt. This was discussed _with Mr. l

T. Kenny of,the NRC Region'I on August 30, 1990 and on September 6, 1990.

Additionally, the. inspection report noted continued problems with procedure I

, o compliance and technical adequacy and implementation of procedures. Also, a recurring .

problem concerning the approval of an inadequate technical' justification prepared _by the ,

li NuclearEngineeringDivision:(NED)wasnoted. We will provide our evaluation and plans I y for resolution of these weaknesses separately from this written response.

M'O If you have any questions or require additional _information, please contact us.

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q y, Very rul .ours,- l S

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p cc: T. T. Martin, Administrator, Region I, USHRC f l L T'. J. Kenny, USNRC Senior Resident inspector, LGS q

q 9009140143 900907 ADOCK 05000352

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~<' 7- Attachment ? l'--

.Page 1 of 3 Inspection No.- 50-352/90-17 i

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, , _ ; Reply to a Notice of Violation- ,

Restatement of'the Violation As'airesult of an inspection conducted on May 22 through July'1, 1990, and-in" i

'accordance with NRC' Enforcement Policy-(10CFR2,_ Appendix C) _the-following-violation was-identified:

. Technical Specification 4.0.5.a requires that inservice testing of ASME Code ~

4 Class 1, 2 and 3 pumps shall be performed in accordance with_Section.X1 of D the ASME Boiler and Pressure Vessel Code and-applicable Addenda as required .

-by10CFRPart50,-Sectica50.55a(g),exceptwherespecificwritten-relief- .;

has been granted by the Commission pursuant to 10 CFR Part 50, Section ,

50.55a(g)(6)(i). Section XI, Article IWP-3210 states that the allowable-ranges of inservice test quantities in relation to the reference values are tabulated in Table IWP-3100-2. If these ranges cannot be met, the Owner shall specify in the record of tests the reduced range limits to allow the pump-to. fulfill its function, and those limits shall be used in lieu.of.the ranges given in Table.IWP-3100-2.

Contrary to the above, since February 8, 1985, *he licensee has been..

generically using expanded differential pressure ranges for safety related-  :

pumps which extend beyond those specified in Table IWP-3100-2 of Section XI ,

of the ASME Boiler and Pressure Vessel Code without appropriate technical justification. in'several cases the pump differential pressure ranges'were expanded even though_the actual pump data had not fallen outsidesof the Code i range. In addition, the ranges were extended so broadly that the Inservice  ;

Testing Program was not assured of satisfactorily performing its intended function, to assess the operational readiness of safety'related pumps.

This is a Severity Level IV violation (Supplement 1).

Response 5 Admission of Alleged Violation Philadelphia Electric Company (PECo) acknowledges the violation.  ;

Reason For The Violation:

This violation is the result of generically using expanded ranges for differential pressure or flow in the LGS Inservice Testing (IST) program even though the allowable ranges specified in ASME Boiler and Pressure Vessel Code-iSection XI Subsection IWP Table IWP-3100-2 could be met.

'In 1985, PECo's interpretation of the ASME Section XI Subsection IWP-3210

' allowed for expanding pump performance acceptance criteria ranges (i.e. ,

differential pressure or flow ranges) for pumps that could not meet the '

. allowable ranges specified in Table IWP-3100-2. Expanded ranges were developed

'because1)notallofthepumpstestedundertheISTprogramwereexpectedto fall within the IWP Table 310f-2 range requirements (based on limite'. startup test data that showed pumps 8.nown to be operating within the design basis requirements had test results in the " Alert" and " Action Required" ranges of l>

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Page 2-of'3 '

Inspection No. 50-352/90-17 zi m- ,

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iTable.IWP-3100-2),and.2)thelimitid-testdataavailablewas' insufficient'to"

' establish representative pump performance reference values..  ;

L0ur use of.these expanded rangcs' continued because PECo did.not implement an-  !

adequate mechanism that-required-the re-evaluation of pumpireference values or -)

the application of expanded' ranges as additional pump data was.obtained.- '!

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! Corrective ctions Taken'and Results Achieved:

On-June 22, 1990,'. Plant Staff personnel completed a review of the most recent-IST pump performance data for all pumps in the IST program. This-data review

, verified that all of the safety-related pumps, including the Residual Heat Removal (RilR)pumpnotedintheinspectionreport,.mettheminimumoperability design basis requirements. Additionally, test data indicated no signs of-degraded pump performance.

We will no longer use expanded ranges as the acceptance criteria for-lST pump performance tests unless there is a-pump-specific technical justification.

. Corrective Actions to Prevent Recurrence To ensure' continued-compliance with ASME Section XI Subsection IWP code-  :

requirements, several corrective-actions will be implemented. These corrective actions are as follows:- .

Use of a recently. developed pump performance trending program to o-l-  : identify:as-needed changes to the pump reference values. This trending h program will also be used.to determine the need for the application of expanded. ranges, o- For pumps that we determine to require expanded ranges, provide on a 4

case-by-case' basis, an expanded range and the appropriate analysis to justify the expanded range.

o . Convert the existing IST program administrative guideline to an administrative procedure. This procedure will strengthen the-control and implementation of the IST program. Also, the procedure will provideiclearer direction regarding control of pump reference values, the method by which' test acceptance criteria ranges are expanded, and a feedback mechanism to confirm applicability of the selected reference values and ranges. This procedure is expected to be implemented by ,

' December 31, 1990.

Surveillance test procedures are currently being reviewed to determine if other ,

- changes are warranted to ensure that the test results produced are comparable i for the purpose of pump performance trending. The Surveillance Test procedure review and necessary testing.for trending is expected to be completed by '

September 30, 1991.

.A detailed' analysis of past pump performance test data was completed on July 30, d, 1990. This analysis consisted of compiling IST program test data for each pump

.. ,, and developing a graph by plotting the pump performance data as a function of m

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. . . , Inspection No. 50-352/90-17 s .

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time.. Evaluation of these graphs facilitated the development of the above- 1 A .

- described corrective actions. Also, these graphs pi9 vide 11 method to -

Jgraphically trend = pump performance. This.information will be' utilized to-jre-establish pump; reference values and to determine the need for the' application U

of expanded ranges; cThe review and analysis of test results completed to datb have revealed that the Core Spray system pumps and the Control Enclosure Chilled Water system pumps do?

not require expanded ranges. The appropriate IST surveiliance test procedures-have been revised to include the IWP code range requirements.

An explanation clarifying the intent'of the ASME Section XI Sebsection-IWP-??!0- '

i with respect'to the use of expanded ranges, will be added to the'IST prJgram.

, document by December. 31,,1990.

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-l Date When Full Compliance Will Be-Achieved -

Full compliance was achieved on September 7, 1990. In the-future. pump-specific-

= technical justifications will.be provided, whenever expanded ranges.are used asi the acceptance criteria for lST pump performance tests.

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