IR 05000346/1993009

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/93-09. Corrective Actions Re Auxiliary Feedwater Pumps Reviewed
ML20045H385
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 07/15/1993
From: Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Storz L
CENTERIOR ENERGY
References
NUDOCS 9307200155
Download: ML20045H385 (1)


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JUL 151993 Docket No. 50-346 Centerior Energy ATTN:

Mr. L. Vice President-Nuclear Davis-Besse c/o Toledo Edison Company 300 Madison Avenue Toledo, OH 43652-0001

Dear Mr. Storz:

SUBJECT: UNRESOLVED ITEM (NRC INSPECTION REPORT NO. 50-346/93009(DRS))

This will acknowledge receipt nf your letter dated June 15, 1993, in response to our letter dated May 17, 1993, transmitting an unresolved item associated with Inspection Report No. 50-346/93009(.DRS).

This report summarized the results of the inservice testing inspection at your Davis-Besse Nuclear Power Station. We have reviewed your corrective actions for the auxiliary feedwater pumps and have no further questions at this time.

Sincerely, l

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5.C. Wright,Chieff Engineering Branch cc:

J. Wood, General Manager cc w/ltr dtd 06/15/93:

OC/LFDCB LPM, NRR Resident Inspector, RIII James R. Williams, State of Ohio Robert E. Owen, Ohio Department of Health A. Grandjean, State of Ohio, Public utilities Commission i

9307200155 930715 PDR ADOCK 05000346-O PDR mye-1 o i i

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f 200 00k Tree Boutward Mod Address megendence OH PO Box 94061 216 441 3100 Cleveland. OH 44101-46G1 Docket Number 50-346 License Number NPF-3 Serial Number 1-1014

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June 15, 1993 United States Nuclear Regulatory Ce:amission Document Control Desk Uashington, D. C.

20555 Subj ec t : Response to NRC Inspection Report Number 50-346/93009 Gentlemen:

Toledo Edison (TE) received NRC Inspection Report 50-346/93009 (Log Number 1-2851) on May 24, 1993.

During this inspection, an unresolved item was identified by the inspectors regarding surveillance test acceptance criteria fer the Auxiliary Feedvater (AFU) pumps (Unresolved Item 93009-03). The NRC requested that TE provide a response to the identified concern addressing corrective measures taken by TE to resolve this issue and the impact of the identified concern on previous AFV pump surveillance tests. This letter provides the requested response.

Each AFV pump at the Davis-Besse Nuclear Power Station (DBNPS) is presently required to deliver a minimum of 600 gallons per minute (gpm)

of water to a Once Through Steam Generator (OSTG) at a pressure of 1050 psig. Accounting for the effects of system flow resistances, elevation differences and recirculation flov, the minimum pump performance criteria for AFV Pump 1-1 are 600 gpm flow at 1236 psig pump discharge pressure. The minimum performance requirements for AFV Pump 1-2 are 600 gpm flow at 1227 psig pump discharge pressure.

Performance of the current quarterly surveillance tests for the AFU pumps (DB-SP-03151 and DB-SP-03160) involve measuring the flow rate, the pump suction pressure, the pump discharge pressure, and the pump speed for each pump. This data is then " normalized" to a reference

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License Number NPF-3 Serial Number 1-1014 Page 2

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pump speed (nominally 3600 rpm) using pump affinity laws and compared

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to.the acceptance criteria. This practice also facilitates comparison i

between pump tests for detection of' pump degradation.

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During the recent NRC inspection of the DBNPS Inservice Testing Program it was noted by the inspectort, that the pump performance parameters for AFV Pump 1-1 vere approaching the minimum criteria mentioned above.

a The inspectors contended that if instrument uncertainties were applied to the data measured during recent surveillance tests, the minimum flow and discharge pressure requirements may not have been met.

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Instrument uncertainties were not considered in the determination of the pump performance criteria mentioned above, nor are they typically considered in establishing performance criteria for.other pumps.in the

DBNPS Inservice Testing Program.

Reasons for not considering instrument uncertainties are 1) the pumps typically operate vell within the established design limits and the relatively minor variations introduced by instrument uncertainty are considered insignificant; 2)

i the analyses of design basis events use conservative inputs and, as such, are insensitive to minor variations caused by instrument

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uncertainty; and 3) there is no specific industry or regulatory guidance regarding application of instrument uncertainty to process

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measurement devices. Existing industry guidance (i.e., Regulatory Guide 1.105 and Instrument Society of America (ISA) Standard S67.04)

for setpoint deterrination apply to instruments.that provide automatic protective functions and not to process measuring equipment. Vith respect to ISA S67.04, a setpoint is defined as "a predetermined level

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at which a bistable device changes state to indicate that the quantity under surveillance has reached the selected value."

In response to the inspectors' concerns, TE reviewed the results of the

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last 12 quarterly surveillance tests for both AFV pumps. This reviev took into account calculated and/or actual measured instrument i

I uncertainties of the test instruments.

In each~ case, the pump

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performance criteria vere above the established minimum values and the pump was considered operable.

It is TE's intent to increase the operating speed of AFV Pump'l-1.

This vill raise the pump operating parameters to a point vell above the

minimum values such that instrument uncertainties are not significant.

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Until the pump speed can be increased, TE vill revise procedures DB-SP-03151 and DB-SP-03160 to change the acceptance criteria for AFV l

pump testing to allow for instrument uncertainties and to specify that mensured pump flow and discharge pressure vill be used to demonstrate

pump operability. The procedure changes will be made prior to the

performance of the next quarterly surveillance tests.

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Docket Number 501346

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j License Number NPF-3 Serial Number 1-1014 Page 3 Should you have any. questions or require additional information, please~

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contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at

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(419) 249-2366.

Very truly.yours,

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Louis 1 Storz Vice President - Nuclear NKP/dle I

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J. B. Hopkins, NRC Senior Project Manager d'. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

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