L-86-404, Forwards Revised Relief Requests Re Frequency of Flow Measurement Testing for Listed Pumps,Including Boric Acid Makeup Pumps 2A & 2B,Auxiliary Feedwater Pumps 2A,2B & 2C & LPSI Pumps 2A & 2B

Forwards Revised Relief Requests Re Frequency of Flow Measurement Testing for Listed Pumps,Including Boric Acid Makeup Pumps 2A & 2B,Auxiliary Feedwater Pumps 2A,2B & 2C & LPSI Pumps 2A & 2B

ML17216A735
Person / Time
Site:	Saint Lucie
Issue date:	10/13/1986
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	Thadani A Office of Nuclear Reactor Regulation
References
L-86-404, NUDOCS 8610240008
Download: ML17216A735 (16)

Text

REGULA Y INFORMATION DISTRIBUTI SYSTEM (R IDS)

ACCESSION NBR: 8610240008 DOC. DATE: 86/10/13 NOTARIZED:

NO FACIL:50-389 St.

Lucie Planti Unit 2i Florida Power 8c Light Co.

AUTH. NAME AUTHOR AFFILIATION WOODY> C. O.

Florida Power Zc Light Co.

REC IP. NAME RECIPIENT AFFILIATION THADANIeA. C.

PWR Prospect Directorate 8

SUBJECT:

Forwards revised relief requests re frequency of flow measurement testing for listed pumps~ including Boric Acid Makeup Pumps 2A 8c 2Bi Auxiliary Feedwater Pumps 2*i2B 8c 2C LPSI Pumps 2A 5 2B.

DISTRIBUTION CODE:

A047D COPIES RECEIVED: LTR ENCL SI ZE:

TITLE:

OR Submittal:

Inservice Inspection/Testing NOTES:

DOCKET 0 05000389 RECIPIENT ID CODE/NAME PWR-B ADTS PWR-B PD8 LA TOURIQNYiE INTERNAL: ADM/LFMB ELD/HDS2 NRR/TAMB RQN2 COPIES LTTR ENCL 1

1 1

0 1

1 1

0 1

0 1

1 1

1 RECIPIENT ID CODE/NAME PWR-B EB PWR-B PD8 PD 01 AEOD/PTB NR RO/EIB REQ FIL 04 COPIES LTTR ENCL 1

1 5

5 EXTERNAL: LPDR NSIC 03 05 1

1 1

1 NRC PDR 02 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 19 ENCL 16

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FLORIDAPOWER & LIGHTCOMPANY A)CTOBER 1S 1986 L-86-000 Office of Nuclear Reactor Regulation Attention:

Mr. Ashok C. Thadani, Director PWR Project Directorate 88 Division of PWR Licensing -B U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Thadani:

Re:

St. Lucie Unit P/2 Docket No. 50-389 Relief from Parts of ASME Section XI

Dear Mr. Thadani:

Your letter dated 3anuary 13, 1986 denied a relief request from the requirements of IWP-0600 of ASME Section Xl regarding flow measurement for certain pumps.

Subsequent correspondence resulted in an interim relief from these requirements until the Fall 1987 refueling outage.

Since that time, we have again reviewed our systems

design, 10CFR50.55a and the requirements of Section XI. As a result of these efforts, we have revised the relief requests pertaining to frequency of flow measurement testing for the following pumps:

1. Boric Acid Makeup (BAM) Pumps 2A

• 2B

2. Auxiliary Feedwater (AFW) Pumps 2A, 2B dc 2C

3. Low Pressure Safety Injection (LPSI) Pumps 2A R 2B

0. High Pressure Safety Injection (HPSI) Pumps 2A 4 2B The enclosed specific relief request relates to frequency of inservice tests (IWP-3000).

We propose testing on a cold shutdown or refueling shutdown basis instead of on a three month basis.

Also enclosed is the basis for excepting the following pumps from certain testing requirements of the Code, i.e. flow measurements.

1. Containment Spray (CS) Pumps 2A and 2B

2. Diesel Generator Fuel Oil Transfer Pumps 2A and 2B 8bi0240008 8b1019 PDR ADOCK 05000389 P

PDR MCIl:1 PEOPLE... SERVING PEOPLE

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Mr. Ashok C. Thadani Page 2 Exception is taken to the flow measurement requirement of the Code for these pumps since system design does not provide a flow path for flow rate measurement.

The acceptability of not meeting the Code requirements for flow rate measurement is discussed in the enclosure Since the system design does not allow for such flow measurement; the above two systems would need to be modified.

This redesign and alteration would result in an extreme hardship and expense without a compensating increase in the level of quality and safety.

Additionally, alterations to installed systems introduce new variables which may result in increased complexity with limited benefit gained.

Since current testing provides a clear assessment of the flow capacities of the above

pumps, the limited benefit gained by system modification does not appear to be sufficient to offset the increased potential for compromising the system safety function through misalignment, misoperation or component failure.

The information provided on the requested relief and exceptions is intended to amplify and support our earlier submittals on this topic.

The attachment is intended to replace the Pump Test Program as submitted in our letter L-83-510, dated October 6, 1983.

Please contact us ifyou have any questions about this submittal.

Very truly yours, O. Woody roup Vice President Nuclear Energy COW/EJ W/kc Enclosure cc:

Dr. 3. Nelson Grace, Region II, USNRC Mr. Alan Schubert, Florida Dept. of Health and Rehabilitative Services

, Harold F. Reis, Esquire MCI1:1

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FLORIDAPOWER 8 LIGHTCOMPANY Page I of 2 PUMP INLET PRESSURE PUMP NO.

P; DIFFERENTIAL PRESSURE h P SPEED N

FLOW RATE Q

VIBRATION V

TEMP RELIEF BRG Tb+

REQUEST NO.

Boric Acid Makeup Pumps 2A 28 Yes Yes Yes Yes NA NA Yes Yes Yes Yes Yes Yes Component Cooling Water Pump 2A 2B 2C Yes Yes Yes Yes Yes Yes NA NA NA Yes Yes Yes Yes Yes Yes Yes Yes Yes Containment Spray Pump 2A 2B Yes Yes Yes Yes NA NA No (I)

No(l)

Yes Yes Yes Yes See Attached Exceptions Charging Pump 2A 2B 2C Yes Yes Yes Yes Yes Yes NA NA NA Yes Yes Yes Yes Yes Yes Yes Yes Yes Intake Cooling Water Pump 2A 2B 2C Yes Yes Yes Yes Yes Yes NA NA NA Yes Yes Yes Yes Yes Yes Yes Yes Yes Diesel Oil Transfer Pump 2A 2B Yes Yes Yes Yes NA NA No (I)

No(l)

Yes Yes Yes Yes See Attached Exceptions PROGRAM: St. Lucie Unit No. 2 TITLE: PUMP TEST PROGRAM TABLE IV TEST PARAMETERS

FLORIDA POWER &LIGHTCOMPANY Page 2 of 2 PUMP INLET PRESSURE PUMP NO; P;

DIFFERENTIAL SPEED FLOW RATE PRESSURE

~ P N

Q VIBRATION V

TEMP BRG Tb RELIEF REQUEST NO.

Auxiliary Feedwater Pump 2A 2B 2C Yes Yes Yes Yes Yes Yes

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NA NA Yes Turbine Driven Yes Yes Yes Yes Yes Yes Yes Yes Yes 2

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Low Pressure Safety Injection Pump 2A 28 Yes Yes Yes Yes NA NA Yes Yes Yes Yes Yes Yes High Pressure Safety Injection Pump 2A 2B Yes Yes Yes Yes NA Yes Yes Yes Yes Yes Yes Hydrazine Pump 2A 2B No No No No NA NA Yes Yes Yes Yes Yes Yes NOTE: (I)

Fixed Hydraulic resistance system test performed on recirculation.

Bearing Temperature, Tb, is measured only on the annual test.

PROGRAM: St. Lucie Unit No. 2 TITLE: PUMP TEST PROGRAM TABLE IV TEST PARAMETERS

BELIEF BASIS 1.

Putrps:

Boric Acid lAke-up Purrp No. 2A Boric Acid Make-up Perp No.

2B Test Requirern nt:

1%P-3000 "Frequency of Tests" Relief Requested:

Requesting relief frcm testing frequency.

Basis for Relief:

Alternate Testing:

Due to the inability to directly naasure

flow, these pumps cannot be tested quarterly in accordance with the requirern nts of the 1980 code during norrral operation.

This is because testing the boric acid rrake-up putrps would result in the addition of excess boron to the reactor coolant system resulting in a reactor shutdown.

The boric acid rrake-up purps will be tested in accordance with 1%P-3100 and 1%P-0600 during cold shutdowns (rrude 5) using the existing flow-rate rn ters.

Additional Testing:

The boric acid rrake-up purps will be tested quarterly in accordance with the 1970 Code Edition and Technical Specification 0.1.2.6 using the fixed hydraulic resistance (bypass loop) recirculation flow path.

Evaluation of the results of the quarterly boric acid rrake-up pmp tests and the results of boric acid rrake-up pmp tests using the existing flow rn ter flow path will provide a rn ans for detecting significant changes in the hydraulic'haracteristics of the boric.acid rrake-up ptJrp.

Further, the rn asurerrant and evaluation of boric acid rrake-up pump vibration amplitude will provide a

rraans for detecting significant changes=-

in the rn.chanical characteristics of the boric acid rrake-up pmys.

2.

Pumps Auxiliary Feedwater Perp No. 2A Auxiliary Feedwater Purp No.

2B Auxiliary Feedwater Purp No.

2C Test Requirement:

1%P-3000 Frequency of Inservice Tests Relief Requested:

Requesting relief fran testing frequency.

Basis for Relief:

Due to the inability to directly rreasure flow these pmys cannot be tested quarterly in accordance with the requirerrents of the 1980 code during normal operation and hot shutdown because testing the Auxiliary Feedwater Purp (AFW) would result in the injection of cold water at arrbient terperature 85 oF fran the Condensate Storage Tank (CST) into the feedwater line to the associated steam generator which is nomally operating at a

terrperature of approxirrately 035 oF.

This would result in an abnomal severity and frequency of therrral shock to the feedwater system.

Alternate Tests:

The AFW pcs will be tested in accordace with 1%P-3100 and 1%P-0600 during cold shutdowns (mode 5) using the existing flow-rate rraters installed in the flow path that is used when the AFW pmp is performing its safety-related function.

Additional Testing:

The AFW pcs will be tested quarterly, in accordance with the 1970 Code Edition and Technical Specifications 0.7.1.2.1 and 0.7.1.2.2,

. using the fixed hydraulic resistance recirculation (bypass loop) flow path.

Evaluation of the results of the quarterly AFW purp tests and the results of ARY purp tests using the safety-related flow path will provide a

rn ans for detecting significant changes in the hydraulic characteristics of the AFW purp.

Further, the measurement and evaluation of AFW puvp vibration arrplitude will provide a rraans for detecting significant changes in the mechanical characteristics of the AFW pmys.

3.

Purps Low Pressure Safety Injection Purp No. 2A Low Pressure Safety Injection Purrp No.

2B Test Requirem nt:

1%P-3000 Frequency of Inservice Tests Relief Requested:

Requesting relief frcm testing frequency.

Basis for Relief:

Alternate Testing:

Due to the inability to directly rn asure flow these purps cannot be tested quarterly in accordance with the requirements of the l980 code during norrral operation.

This is because the Low Pressure Safety Injection (LPSI) purps do not develop sufficient discharge pressure to establish a

flow path frcm the Refueling Water Tank (RWI') to the Reactor Coolant System (RCS).

The LPSI purrps will be tested in accordance with I%P-3100 and 1%P-0600 during cold'hutdowns (rrade 5),

when the system is aligned for shutdown

cooling, using the existing flow rn ters installed in the flow path that is used when the LPSI purp is performing its safety-related function.

Additional Testing:

The LPSI purps will be tested quarterly, in accordance with the l970 Code Edition and Technical Specification 0.5.2.g.2, using the fixed hydraulic resistance recirculation (bypass loop). flow path.

Evaluation of the results tests and the results of safety-related flow path detecting significant characteristics of the LPSI of the quarterly LPSI purp LPSI purp tests using the will provide a

rn ans for changes in hydraulic purp o

Further, the rn asurem nt and evaluation of LPSI purp vibration anplitude will provide a rn ans for detecting significant changes in the rrechanical characteristics of the LPSI purps.

High Pressure Safety Injection Purp No. 2A High Pressure Safety Injection Pm@ No.

2B Test Requirenant:

1%P-3000 Frequency of Inservice Tests Relief Requested:

Requesting relief fran testing frequency.

Basis for Relief:

Due to the inability to directly rn asure flow these pcs cannot be tested quarterly in accordance with the requirem nts of the l980 code during norrral operation.

This is because the High Pressure Safety Injection (HPSI) pumps do not develop sufficient discharge pressure to establish a flow path fran the Refueling

%hter Tank (RVf) to the Reactor Coolant System (RCS).

Alternate Testing:

Further, the HPSI pcs cannot be tested at cold shutdown (mode 5) because it could subject the Reactor Pressure Vessel (RPV) and the PCS to conditions exceeding the pressure-tarperature limits of Technical Specification 3.0.9.l.

The HPSI pmps will be tested in accordance with 1%P-3100 and I%P-0600 during refueling shutdown (mode 6),

while filling the refueling cavity with the RPV head

revolved, using the existing flow meters installed in the flow path that is used when the HPS I perp is performing its safety-related functon.

Additional Testing:

The HPSI pumps will be tested quarterly, in accordance with the 1970 Code Edition and Technical Specification 0.5.2.g.l, using the fixed hydraulic resistance recirculation (bypass loop) flow path.

Evaluation of the results of the quarter'ly HPSI putrp tests and the results of HPSI purp tests using the safety-related flow path will provide a

rraans for detecting significant changes in the hydraulic characteristics of the HPSI purp.

Further, the rraasurement and evaluation of HPSI purp vibration arrplitude will provide a rreans for detecting significant changes in the mechanical characteristics of the HPSI purrps.

ST. LUCIE UNIT PP2 PUMP AND VALVEPROGRAM EXCEPTIONS In accordance with 10CFR50.55a, the rules of Table IWP-3100-1 "Inservice Test Quantities" and Subarticle IWP-3000 "Frequency of Inservice Tests", which require the measurement of Flow, Q, at a 3-month frequency, are not applicable to the ASME Class 2 Containment Spray Pumps 2A and 2B or the ASME Class 3 Diesel Oil Transfer Pumps 2A and 2B.

10CFR50.55a (g)(3)(iv) states that "Pumps and Valves which are classified as ASME Code Class 2 and Class 3 shall be designed and be provided with access to enable the performance of inservice testing of the pumps and valves for assessing operational readiness set forth in Section XIof editions of the Boiler and Pressure Vessel Code and Addenda applied to the construction of the particular pump or valve or'he Summer 1973 Addenda, whichever is later."

In the case of St. Lucie Unit N2, the latest ASME Section Code edition and addenda which can be considered to apply to the design of systems is 1970 Edition through Summer 1975 Addenda.

Footnote 1 to Table IWP-3100-1 "Inservice Test Quantities" states, "In a fixed resistance system it is required to measure P or Q, not both.

In a variable resistance

system, both shall be measured."

'The Containment Spray and Diesel Oil Transfer "minimum recirc" lines are each equipped with a fixed orifice; current testing methods measure P. The applicable design requirement is thus satisfied.

10CFR50.55a (g)(0) states, "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Class 1, Class 2 and Class 3 shall meet the requirements,

~exce t design and access provisions and preservice examination requirements, set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda that become effective subsequent to editions specified in paragraphs (g)(2) and (g)(3) of this section and are incorporated by reference in paragraph (b)

"'f this section, to the extent practical within the limitations of design, geometry and the materials of construction of the component.

In summary, the Containment Spray Pumps and the Diesel Oil Transfer'Pumps are excepted from the ASME Section XI requirement to measure flow directly in order to assess operational readiness of pumps since:

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ST. LUCE UNIT 82 PUMP AND VALVEPROGRAM EXCEPTIONS Page 2

2) 3)

the ASME Code applicable to the design of the systems did not require flow to be measured in fixed orifice systems, the design of the system components satisfies the requirements for design as specified in 10CFR50.55a (g)(3)(iv) and; IOCFR50.55a (g)(0) excepts design from having to be changed to meet the requirements of later Editions and Addenda of Section XI which become effective, and the design of the subject system components would have to be changed and alterations performed to the system components to make flow measurement possible and; 10CFR50.55a (g)(0) requires that ASME Class 1, Class 2 and Class 3

components meet the requirements set forth in Section XIof editions of the ASME Boiler and Pressure Vessel Code and Addenda that become effective subsequent to editions specified for original purchase to the extent practical.

The required flow measurement is clearly impractical based upon the design of the system, since a flow path providing for adequate flow measurement does not exist.

In the case of the Containment Spray Pumps and Diesel Generator Fuel Oil Transfer

Pump, the redesign and modifications necessary to satisfy the requirement would result in costs exceeding $550,000.00.

Even if the test requirement were to be considered applicable to the subject pumps, the existing design limitations render the changes necessary to meet the requirement impractical and unnecessary for the following reasons:

2)

Since the pumps involved are 'single-stage centrifugal

pumps, the measurement of the other test quantities of,Table IWP-3100-1 and satisfying the requirements of Technical Specification 0.6.2.1b and 0.8.1.1.2a.3, provides sufficient data to assess the operational readiness of these pumps and assure an adequate level of quality and safety.

This includes measurement of pump P with a fixed resistance

system, satisfying the original design requirements for the system components, as specified in 10CFR50.55a (g)(3)(iv).

Alteration of installed systems introduces new variables which may result in the unnecessary complexity of the systems.

The limited benefit gained by adding flow measurement to the quantities currently used in assessing the operational readiness of the Containment Spray Pumps and Diesel Fuel Oil Transfer Pumps does not appear sufficient to offset the increased potential for compromising the system safety function through misalignment, misoperation or component failure'.

3)

The redesign and alteration of installed systems as necessary to accomplish the performance of flow measurement at the specified frequency would result in an extreme hardship, expense and unnecessary burden without a compensating increase in the level of quality and safety.

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